This Advice Document has been prepared to provide guidance to the City of Brandon, the Proponent, in the preparation of an Environment Act Proposal for an alteration to their industrial wastewater treatment facility (I-WWTF) to be filed under The Environment Act concurrently with a proposed alteration to be filed by Maple Leaf Foods Inc. respecting the upgrading of the Maple Leaf Pork plant in Brandon from a 1-shift per day operation to a 2-shift per day operation, together with such modifications to the plant as may be necessary. Maple Leaf Foods have already been licenced for a 2-shift operation of the Maple Leaf Pork plant through Environment Act Licence No. 2311 S2R, however, their Licence restricts the operation of that plant to only 1-shift per day operation until the City of Brandon's I-WWTF has received an Environment Act operating licence authorizing the facility to accept the wastewater generated by a 2-shift operation of the Maple Leaf Pork plant.

The 2-shift per day operation of the Maple Leaf Pork plant and the expansion/upgrading of the I-WWTF will, if approved, necessitate revisions to (3) current Environment Act Licences:

1. Licence No. 2311 S2R, issued to Maple Leaf Foods Inc., respecting the Maple Leaf Pork processing plant;
2. Licence No. 2367 S2R, issued to The City of Brandon, respecting the I-WWTF dedicated to the hog processing plant; and
3. Licence No. 2351 S2R, issued to the City of Brandon respecting the municipal wastewater treatment facility (MUN-WWTF), which was temporarily linked to Licence No. 2367 S2R on the management of ammonia loadings into the Assiniboine River until the MUN-WWTF could be operated reliably as a continuous discharge facility as per the "City of Brandon Wastewater Treatment Plant Master Plan Final Report" dated July 1999.

In addition, Environment Act Licence No. 2506 issued to the City of Brandon for the land application of biosolids from the anaerobic basin of Brandon's I-WWTF may need to be reviewed in the context of the increased quantity of biosolids that will need to be applied to land versus the long-term sustainable availability of sufficient suitable private agricultural land that may be offered for this purpose by local land owners.

The existing City of Brandon's I-WWTF, its proposed alteration to accommodate the 2-shift per day operation of the Maple Leaf Pork plant, and the process wastewater pre-treatment facility owned and operated by Maple Leaf Foods Inc., will hereafter in this guidance document be referred to simply as "the proposed Development". The term "Proposal" will refer to the City of Brandon I-WWTF proposal to be filed concurrently under The Environment Act with the process wastewater pretreatment facility alteration to be filed by Maple Leaf Foods Inc.

All environmentally significant proposed Developments in Manitoba are regulated by The Environment Act (C.C.S.M. c. E125). Manitoba Regulation 164/88 under this Act sets out the types of Developments which are automatically subject to an assessment and licencing process prior to their construction, operation or alteration. The Proposal will be considered pursuant to Section 11 of the Act. A Clean Environment Commission hearing will be held.

An interdepartmental Technical Advisory Committee (TAC) has been established to provide advice and guidelines for the assessment of potential environmental effects and the preparation of an appropriate Environmental Assessment (EA) report, and to evaluate the final EA report prepared by the Proponent. This TAC consists of provincial department technical staff and Federal representation as a matter of protocol, by agreement between the Province of Manitoba and the Federal Government through "A Canada-Wide Accord on Environmental Harmonization" and its "Sub-agreement on Environmental Assessment", in order to facilitate a coordinated approach to the review of proposed projects where both the provincial and the federal jurisdictions have a legislated requirement or interest in the environmental assessment and review of such projects.

During the EA process and the preparation of the EA report, the Proponent is encouraged to work closely with the TAC assembled for the project. This committee can provide the proponent with any required interpretation of the advice document, and can provide on-going feedback to the Proponent concerning the content and methodology of the assessment. In this way, any problems or new issues that were not accounted for in the EA guidelines can be dealt with, and the Proponent will have the opportunity to fill in deficiencies as the assessment is proceeding rather than after it has been completed.

Persons preparing the EA shall have an appropriate combination of formal education, skills, experience and training to conduct a technically sound and rational EA.

The Proponent is also strongly encouraged to undertake a public consultation process with local and downstream citizens, First Nation bands and environmental interest groups, that may be affected or concerned by the proposed Development so as to: provide a clearer awareness and understanding of the proposed Development; to receive feedback on the environmental issues of particular importance to the potentially affected or concerned parties; and to respond, whenever possible, to questions from the public.

The purpose of these EA Guidelines is to provide the Proponent with an outline for an EA Report that the Director requires to make a licencing decision. These guidelines are intended to address the broadest range of information. The items listed should be considered but not all may necessarily apply to the proposed Development.

In order to assess the impacts of the proposed Development, it is necessary to establish a current environmental baseline of the environmental conditions at the proposed site and in the receiving environment. Furthermore, in the case of this Proposal, the total cumulative effect, not just the incremental additional amount due to the 2-shift per day production implementation, will need to be examined.

Where upon the Proponent finds it difficult to compile some of the following requested information in a timely fashion, the Proponent should consult with the Chairperson of the TAC. The EA report produced as a result of the assessment process should clearly document that information which is lacking and the rationale for not being able to provide it in the EA report. Also, the EA report should outline the options and time frames whereby the lacking information can be collected, evaluated, interpreted and presented to the Department within a practical time frame following the licencing of the proposed Development. New information acquired after the proposed Development is licenced may be used to revise the prevailing Licence through the provisions of The Environment Act.

The EA report should include the following components:
(Note: Existing data and reports can be used to the extent available and appropriate)

1.   Introduction

Describe the nature and scope of the Proposal, together with the rationale and objectives for the Proposal.

2.   General Site Description

Describe the proposed site for the proposed Development, its physical and environmental setting, and identify human, flora and fauna receptors and background environmental quality of the surrounding area.

Factors to address should include:

• surface and subsurface soils and geology extending to and including the zone of the local upper aquifer;
• groundwater conditions at the site, including the groundwater quality, direction and rate of groundwater movement in the local upper aquifer, and extent of groundwater use at the proposed site and in the local area;
• topographic information and facility elevation relative to normal and high (flood) water levels in adjacent waterways and bodies of water;
• surface drainage patterns in relation to any immediate drainage ditches, natural surface waterways and water bodies;
• the relative location of the site to local natural resource uses, agricultural uses, and to any other developments that may be potentially impacted by this proposed Development;
• local land and water features and background quality, particularly sensitive land and water features, including available information on the flora and fauna that may be impacted by the proposed Development;
• available monthly statistical information on the local meteorology (i.e. wind speed and direction, temperature, precipitation and evaporation);
• regional demographic features including population density, transportation patterns, drinking water sources, schools, institutions, and other high-density situations, and sensitive populations;
• upon specific request, baseline health status respecting potential illness outcomes directly related to liquid discharges or air emissions from the proposed Development;
• the existing background ambient air, surface water and groundwater quality; and
• other existing sources of emissions or discharges (example: releases from the MUN-WWTF, Manitoba Hydro’s Brandon Generating Station, and Simplot's Development) that may impact the same shared environment.

This Section should be complemented with:

• a scaled site plan of the proposed Development, showing all the major structures and features in relation to the legal property boundaries;
• a scaled area plan depicting the land use designation and zoning boundaries of the site of the existing and proposed Development and the surrounding local developed areas;
• a scaled regional area map, encompassing an area within 10 kilometres radius of the site of the proposed Development, identifying:

• the locations of existing demographic features (residential, institutional, commercial, industrial, and transportation patterns), and proposed features that are being proposed by virtue of the local planning program;
• resource use areas that would be potentially impacted by the proposed Development and/or impact the same shared environment within this area; and
• ambient air and water quality monitoring stations;

• a more detailed, larger-scaled local area map, encompassing an area within 3 kilometres radius of the site of the proposed Development, identifying:

• the locations of existing demographic features (residential, institutional, commercial, industrial, and transportation patterns):
• resource use areas, that are potentially impacted by the plant operation and/or impact the same shared environment within this area; and
• groundwater wells including monitoring wells;

• a topographic plan of the proposed site for the proposed Development, showing elevation contours, the surface runoff drainage pattern and major drainage release points to local drainage ditches, waterways and water bodies; and
• vertically scaled well logs, or scaled stratigraphic profiles, depicting the depth and types of subsurface soils and the water table elevation of the local upper aquifer.

Describe the proposed Development, and any major off-site facilities to be associated with the management of waste substances from this proposed Development. In describing the on-site facilities, address in detail the following items (where applicable):

• overall Maple Leaf Pork plant process wastewater pretreatment facility and I-WWTF site layout;
• road and rail access infrastructure;
• power transmission lines;
• other utility lines;
• storm water, process wastewater and sewage routing facilities;
• existing and proposed pretreatment facilities at the Maple Leaf Pork plant;
• existing and proposed treatment facilities at the I-WWTF;
• influent and effluent wastewater quality monitoring facilities at the I-WWTF;
• the type, location and accuracy of any wastewater flow measurement devices to be used to monitor the volume of the influent and effluent waste streams associated with the I-WWTF;
• input/output storage areas for fuels, chemicals and petroleum products, etc.;
• locations of on-site and off-site storage and/or disposal areas used for any solid, sludge and general garbage wastes (distinguish between those off-site facilities which are and are not operated by the Proponent);
• point source air emission control facilities;
• fugitive air emission minimization techniques; and
• point source air emission monitoring facilities.

Describe the proposed construction schedule for the proposed Development.

This Section should be complemented with appropriate scaled site plans and figures which illustrate the locations and relevant details of the above items and highlight the physical changes (location and detail) which will occur to existing facilities or infra-structure through the proposed Development.

Describe the existing and proposed process wastewater pretreatment and treatment processes at the proposed Development, including such information as:

• a functional description of the pretreatment and treatment processes and facilities, along with their design capabilities, limitations and design performance efficiencies relating to airborne, liquid, and solid waste reduction capabilities; and
• pollutant handling/treatment process flow charts.

Describe the proposed inputs to, and outputs from the processes described in Section 4. All descriptions should relate to quantifiable characteristics, where possible.

Respecting inputs:

• describe all inputs (i.e. process wastewater and sewage) directed into the I-WWTF, quantify the expected daily average inflow rates, characterize the expected quality of the process wastewater streams in terms of maximum daily and maximum weekly loading rates and temperature, and characterize the sewage being directed into the I-WWTF;
• describe any other inputs to the proposed Development (e.g. fuels, chemical reagents, etc.) and quantify the rate at which these substances would be used on-site;
• where any inputs to the proposed Development, whether or not directly related to the processes, are Dangerous Goods as described in Regulation 282/87 of the Manitoba Dangerous Goods Handling and Transportation Act, identify all such dangerous goods by their: shipping name, class, PIN (product information number), packing group, storage location on site, storage vessel type, material and size, secondary containment provision (yes/no), annual mass/volume received, maximum quantity on site at any time, and their likely vector for accidental release to the environment, with specific Material Data Safety Sheets or their equivalent to be made available upon request; and
• include a brief discussion on the procedures to be followed with respect to housekeeping, inspection, recording, spill reporting of dangerous goods used at the site of the proposed Development.

Respecting outputs:

• identify the nature, quantity and fate of those substances removed from the raw process wastewater in the course of its pre-treatment stage;
• identify and quantify all the residual post-treatment pollutants (bacterial, physical and chemical) that will be discharged into the Assiniboine River, emitted to the atmosphere or otherwise managed or disposed of in connection with the various processes and activities on the site of the I-WWTF, whereby and wherever possible, the information should is based on the proposed maximum weekly, 2-shift per day production rate for the Maple Leaf Pork plant and on acquired operating data to date at the proposed Development, pertaining to:

• Emissions to the atmosphere, including:

• identification of all air emissions, including:

• identification of their sources by location and characterization of the chemical constituents of the air emission;
• pre-treatment and post-treatment emission rates, concentrations and other measurable levels of pollutants as to their gaseous, particulate, noise and odour characteristics (can be obtained from literature or from the operating data from other similar facilities, except that, if emission factors are used to determine the emission rates, these emission factors should be justified); and
• the characterization and quantification of atmospheric greenhouse gas emissions; NOx, VOC and other ozone precursors emissions, and acid precipitation precursors.

• Direct discharges to waterways, including:

• identification of all proposed or potential wastewater streams directed off the property of the proposed Development by the location and nature of each wastewater stream;
• post-treatment quality and quantity of pollutants as to the physical, chemical, thermal and aquatic toxicity characteristics of each released wastewater stream;
• a breakdown on monthly variations, where applicable.

• Surface runoff discharges to waterways, including:

• identification of all major runoff sources and the pollutants which they may accumulate and transport;
• design capacities of collection and containment facilities expressed quantitatively as well as in precipitation event probabilities (i.e. 1 in 25 yr., 1 in 100 yr., etc.); and
• identification of approximate quantities and qualities of uncontrolled runoff released directly, and/or runoff released from any runoff containment areas.

• Solid and sludge wastes, including:

• the characterization and quantification of such wastes as accumulating sludge in the anaerobic digestor cell(s) which would be periodically removed from the cell(s) for disposal as biosolids onto agricultural land (under separate Licence);

• Other wastes, including:

• hazardous waste as defined in Manitoba Regulation 282/87 of the Manitoba Dangerous Goods Handling and Transportation Act; and
• other miscellaneous solid, liquid or sludge wastes not captured above.

(Quantification of the attributes and the amounts of pollutants released into the environment is considered essential).

• identify all the bi-products or recyclable substances which will be generated and how they will be collected, stored and further managed;
• identify the degree of recycling and waste minimization or re-utilization practices being proposed, and emphasize any proposed innovations to the proposed Development's processes which are expected to result in increased levels of recycling and waste minimization or re-utilization above and beyond that normally achieved at other similar Developments with regards to water use, energy use and waste management; and
• include such information as materials balances and water balances.

The intent of the environmental impact assessment is to identify any significant effect on the environment, and on the social, economic, environmental health and cultural conditions that influence the lives of people or a community in so far as they are caused by environmental effects attributed to the proposed Development. The required environmental impact assessment will involve the following steps:

• Identify all of the sources of both probable and certain impact (whether positive or negative) related to the proposed pollutant releases and activities, associated with the proposed Development.
• Identify the magnitude and duration of these impacts by describing them as major and minor impacts, direct and indirect impacts, short-term and long-term impacts, and the time frame in which these impacts will occur in the future. Estimations should be made of the effects to the receptors either directly or indirectly as a result of air emissions.
• Evaluate and interpret the potential impact of all of these sources for each "Impact Category" described below.
• Evaluate the worst case scenarios of the impacts and their probability of occurrence.
• Support assessment conclusions and statements with data or modeling information.
• Where computer models are utilized to predict the impacts from air emissions, an initial screening should be conducted as a first stage approach to estimate severe emission impacts. The appropriate model and modeling characteristics will depend on the site parameters. Discussion with Manitoba Conservation must take place to ensure the modeling output satisfies the intent of the environmental impact assessment. Depending on the outcome the initial screening, additional detailed modeling may be required.

Impact Categories

a)  Environment

Usually referred to as the "natural" environment, this includes:

• surface and groundwater;
• fish and other aquatic organisms, including the habitats that support them;
• air;
• wildlife;
• vegetation both natural and agricultural;
• soils; and
• historic (heritage) resources.

The impacts on the environment should include human, flora and fauna impact of nuisance, annoyance and avoidance caused by the emissions or discharges.

The impacts on the water quality in the Assiniboine River should be assessed relative to the standards, objectives and guidelines contained in the "Technical Draft, Manitoba Water Quality Standards, Objectives, and Guidelines" (MWQOG), dated February 1, 2001, along with the recommended implementation policies including those for design flows, mixing zones and acute lethality, whereby:

1. the principle variables of concern are bacteria, protozoa, biochemical oxygen demand, dissolved oxygen, toxic forms of nitrogen such as ammonia and nitrate-nitrite, and plant nutrients including all forms of nitrogen and phosphorus, without excluding any other additional important variables that may be identified;
2. suspended solids and 5-day biochemical oxygen demand are each normally regulated at not greater than 30 milligrams per litre;
3. the information generated from the Assiniboine River Monitoring Study conducted by the Proponent over the past several years, and the river water quality model developed over the same period, should be used by the Proponent to:

1. derive daily effluent loading limits for ammonia as would be applicable and specific to each month of the year whereby no more than a 75% allocation of the calculated total assimilative capacity of the river, at a transect immediately upstream of the effluent outfall from the proposed Development, is utilized (this may necessitate the modeling of impacts from major ammonia inputs upstream of the proposed Development relative to the ambient water quality upstream of the City of Brandon whereby each major ammonia discharger would be entitled up to the same % allocation of the total assimilative capacity available at their respective outfall to the Assiniboine River, excepting those outfalls already restricted by fixed caps); and
2. adequately demonstrate that the effluent discharges resulting from the Proposal will not cause exceedances with respect to each applicable criterion laid out in the MWQOG;

4. the Proponent should submit a summary report and interpretation of the findings of the nutrient studies conducted on the Assiniboine River over the past several years as part of the Assiniboine River Monitoring Study; and
5. no further net increase in total nitrogen and total phosphorus due to the proposed Development will occur to the Assiniboine River unless it can be clearly shown from the river studies and the water quality model that no effect will be observed on algal growth, while bearing in mind that upon the completion of Manitoba’s Nutrient Management Strategy, it may be necessary to further reduce concentrations of nitrogen and phosphorus releases to the river.

Impacts upon the receiving waterway due to the release of any identified pollutants should also be assessed by addressing the cumulative effects of pollutant releases upon the ecology and downstream uses of the receiving waterway.

The impacts on air quality due to emissions identified in Section 5 should include:

• the impact of the proposed Development's peak daily, monthly average, and project life average projections on the existing ambient air quality beyond the site of the proposed Development for all pollutant releases compared to Manitoba's "Ambient Air Criteria" and "Guidelines for Sound Pollution", and where applicable, to flora and fauna tolerance levels;
• the impact of the atmospheric greenhouse gas emissions from the proposed Development, expressed in terms of annual mass and annual percentage of the total estimated greenhouse gas emissions generated in Manitoba (as provided by Manitoba Conservation); and
• the broader impact of the whole spectrum of air emissions relative to acid rain, ozone depletion, vegetation, soil residuals, local nuisance conditions, cumulative effects, etc.

b)  Land Use

This involves assessing the impact of location and operation of the proposed Development relative to the local land use planning program.

c)  Natural Resource Uses

This involves assessing the impact of the proposed Development on the current use(s) and identified future use(s) of water and land based resources, including but not limited to:

• surrounding lands, especially those having designated uses (i.e. agricultural, residential, commercial, parks, etc.);
• existing natural resources such as groundwater used by any authorized residents, institutions, or industries sharing the same aquifer;
• existing surface water resources used for irrigation water by downstream authorized users of the Assiniboine River up to and including the City of Portage la Prairie;
• existing surface water resources used directly or indirectly as a drinking water source by communities and First Nations located downstream along the Assiniboine River up to and including the City of Portage la Prairie; and
• existing natural resources such as fisheries, wildlife, forests and other habitat.

d)  Traffic Pattern Changes

This involves assessing the impact of the proposed Development upon the comfort, well being and livelihood of the residents, institutions and commercial operations located along the main transportation and haulage roads proposed to serve the proposed Development, as well as any added potential risk to safety due to any increased traffic brought about by operating the proposed Development.

e)  Environmental Health

This involves assessing the health risks of pollutants released through the construction and operation of the proposed Development on the environmental health of neighbouring human receptors.

f)  Aboriginal People

This involves assessing any effect on the current use of lands and resources for traditional purposes by aboriginal people.

g)  Socio-economic

This involves assessing any social and economic effects resulting from the environmental impacts identified through the preceding assessment sub-sections 6(a) to 6(f), and would not be restricted to a 10 kilometre distance from the site of the proposed Development.

Describe the measures and/or technologies that will be implemented to prevent, mitigate or eliminate the impacts identified in the course of the environmental impact assessment. Discuss the expected effectiveness of the mitigative measures. Anticipated residual impacts which will remain after all reasonable mitigation measures have been undertaken need to be identified, and their significance assessed. Mitigative measures may include changes in design, chemical reagents or other capital measures, as well as non-capital measures such as changes in process or layout of the process train, improved recycling, re-scheduling and other practices.

Where potential impacts have been identified and no mitigation is contemplated, an explanation is required.

Identify alternative technologies which could mitigate the impacts, together with the reasons for which they were or are rejected.

Describe the proposed environmental management practices to be employed to prevent or mitigate adverse implications from the environmental impacts on environmental health.

Describe, as well, further mitigation that could be used if, once the proposed Development is operational, residual impacts are found to be higher than predicted and are found to be unacceptable.

For acute situations, describe contingency planning (and where possible, actual plans) to be applied in the event of a non-routine occurrence which could adversely affect the environment or public health or safety. Include consideration of the following, where applicable:

• malfunction of process equipment;
• malfunction of emission control equipment or wastewater treatment or pretreatment facilities;
• fire;
• accidental spills or releases of dangerous goods or hazardous wastes;
• transportation accidents;
• surface runoff from an extreme (1 in 100 yr.) rainfall event; and
• level of risk and potential consequences of pollutant transport by floodwater, and if applicable, measures to mitigate the associated impacts.

For chronic situations such as:

• an extended disruption of the I-WWTF;
• an extended disruption of the hog slaughterhouse and processing plant and/or the wastewater pretreatment facilities; or
• an extended disruption of services by the contracted hauler or disposer of the biosolids from the anaerobic cell(s) of the I-WWTF;

describe the contingency planning for disposing of wastewaters and biosolids from the I-WWTF.

In the event that, upon the completion of Manitoba’s Nutrient Management Strategy, it may be necessary to further reduce concentrations of nitrogen and phosphorus to the Assiniboine River, the proponent should outline a strategy whereby, if required, the nutrient contributions from the proposed Development to the Assiniboine River could be reduced.

Describe the proposed environmental monitoring facilities, the parameters proposed to be measured, the rationale for selecting these parameters, and the frequency of measurement proposed for obtaining statistically valid monitoring data on the following, where applicable:

• ambient environmental quality:

• air quality (particulate, gaseous, volatile organics, odour and noise respecting air emissions);
• surface receiving water (upstream and downstream); and
• groundwater (up gradient and down gradient);

• point source particulate and gaseous air emissions;
• liquid influent to the I-WWTF;
• liquid effluent from the I-WWTF;
• groundwater subject to potential impact;
• any other point source surface liquid discharges off the site of the proposed Development; and
• plant site property surface runoff.

Provide drawings showing all the proposed sampling locations, along with associated facilities, for the collection of wastewater, groundwater, ambient water quality, point source air emission and ambient air samples.

Outline the proposed technique and equipment to be used for collecting the samples, and for measuring the volumetric rates of discharge of stack emissions and major wastewater streams, where applicable.

Elaborate on the life expectancy of the proposed Development and the projected plans concerning the eventual decommissioning of the proposed Development, including all waste storage and treatment facilities.

Address each of the ten principles and six fundamental guidelines of Sustainable Development, listed in the publication of the Manitoba Round Table on Environment & Economy titled "Towards A Sustainable Development Strategy For Manitobans", by providing a summary paragraph on each principle and guideline, describing how the Proposal endeavors to satisfy the respective principle and guideline.

Describe the program of public awareness and public input which has been undertaken in respect of the proposed Development, and include the results of that public participation. If such a program has not been undertaken, this should be stated together with an explanation for why not.

All assessment conclusions should be backed up by credible technical or scientific information. Previous studies and reports may be utilized if they still have relevance. Properly referenced information could include:

• technical studies of similar facilities and processes which are operating elsewhere;
• original studies performed by qualified engineers, scientists and other professionals commissioned by the proponent specific to the proposed facilities;
• facility design documents as prepared by qualified engineers; and/or
• peer reviewed scientific reports and papers on topics relevant to the facility.

Deficiencies in the technical or scientific evidence should be clearly delineated. All null impact conclusions must be supported by credible analysis and documentation.

The EA report should include an executive summary and should be written with a minimum of technical jargon. Where highly technical portions are essential to the document, definitions or explanations should be included. A glossary of terms should also be provided.

The information presented in the document should maximize the use of maps, charts, diagrams, and photographs to present the information. Maps and diagrams should preferably be presented at a common scale wherever possible to allow direct overlay for ease of reference. Specifically, maps indicating zones of impact to land and water use areas and habitat areas should be of a common scale.

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June 10, 2002