Objection to Notice of Study Completion Cornwall WPP Secondary Intake EA

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Dear Editor
Last week, in response to the Notice issued 12Aug2022, I wrote a letter to the Minister of Environment, the EA Approvals branch and the City WPP Supervisor expressing my concern of the option selected, a mix of Alternatives “F” and”G” with a $40 million capital cost and $74 million 100-year life cycle cost. I agree that an alternative intake must be installed before the existing infrastructure fails. I applaud Cornwall for addressing this risk. However, I object to the fact that my Preferred Alternative was summarily dismissed and not properly costed and assessed, especially as a significant sum of taxpayers’ money is involved. This EA must be delayed for revaluation.

In March 2022 I attended the public meeting and followed up in writing my Preferred Alternative based on many years of experience at the Domtar Mill. My Preferred Alternative is a new pipe from the Closure Structure Gate along the bottom of the Old Cornwall Canal and then following the old CNR right of way to the west side of the WPP – a distance of 4km. As a retired engineer, I am unqualified to properly cost this alternative, that is the job of the engineering firm hired by the City. However, I am sure the capital cost is less than $20 million and the 100-year life cycle cost proportionately less than $74 million. My Preferred Alternative is much simpler. It delivers water to the WPP without the use of pumps and uses a right-of-way already owned by Transport Canada. Alternative “F” and “G” ignores the geographical advantage Cornwall enjoys (using the head provided by Lake St Lawrence to deliver water under pressure to the WPP for free). My Preferred Alternative was dismissed and not costed based on frazil ice concerns. Ironically, the Selected Alternatives “F” and “G” fail to address frazil ice and zebra mussel concerns. It fails to consider the 70 years of expertise gained by Transport Canada as they annually manage the formation of ice on Lake St Lawrence to protect the 32 turbine intakes along the Moses Saunders Powerhouse. In my experience the operation and maintenance of an intake in a fast moving part of the river and a pump house on the north bank of the canal will be an operational and costly nightmare for the life of the project.

For unknown reasons, the Notice was reissued 13Sep2022 with comments to be received by 13Oct2022. By this letter I am requesting Cornwall citizens to act accordingly and express their concerns to the appropriate authorities.

J.N. Cox
Cornwall ON

Attached: Letter of 11Sep2022 to Minister, EA Approvals and Supervisor of Cornwall WPP

Response to Cornwall Water Intake Notice of Study Completion August 2022 dated 11Sep2022 11 September 2022

To: Minister David Piccini, Minister of Environment, Conservation and Parks
5th Floor, 777 Bay St, Toronto ON M7A 2J3

To: Director, Environmental Assessment and Permissions Branch, Ministry of Env, Con and Parks, Environmental Approvals Branch
135 St Clair Ave West, Toronto ON M4V 1P5

To: Mr Owen O’Keefe, Supervisor WPP, City of Cornwall
861 Second St West, Cornwall ON K6J 1H5

Cc: Mr Marco Vincelli, V-P EVB Engineering
800 Second St West, Cornwall ON K6J 1H6

Cc: Mr Glen Grant, Mayor, City of Cornwall and all members of Cornwall City Council
PO Box 877, Cornwall ON K6H 5T9


Re: Notice of Study Completion, Cornwall WPP Secondary Intake Environmental Assessment

Dear Sirs:
The Notice of Study Completion issued 12 August 2022 confirmed the selection to be Alternative “G”. Further, concerns regarding this project must be submitted on form “012-2206E” within 30 days of the date of the notice (stated date is 14 September 2022).

As I am unable to secure a copy of the required form, this letter is written directly to the Minister of Environment, Conservation and Parks; the Director of the Environmental Approvals Branch; Cornwall WPP Supervisor, with copy to EVB Engineering as directed in the Notice. I am also copying the mayor and members of Cornwall City Council.

I am concerned that my alternative (described below) was not properly engineered, costed and evaluated against the preferred alternative.

My alternative should have both a lower installation cost and a lower 100-year life cycle cost.

My alternative uses the head provided by Lake St Lawrence in place of a low lift station. In my experience, all pump houses are both costly to install and to operate. Cornwall needs to take advantage of this benefit of geography and the reduced impact on the Environment.

While my alternative was dismissed by the frazil ice argument, the preferred alternative fails to address either frazil ice or zebra mussel concerns.

I am concerned that this assessment ignores the expertise about the formation of frazil ice and the daily management of frazil ice formation garnered by the federal Transport Canada (specifically the Board that advises

the International Joint Commission that controls the flow of the St Lawrence River) over the past 70 years.
By this letter I am requesting that each of you, as an appropriate authority, to delay the next step in this EA process until my alternative has been properly engineered, costed and ranked according to Technical Performance, Project Implementation, Natural Environment, Social Environment and Economics.

J. N. Cox
202-321 Water St West, Cornwall ON K6J 1A5

Sequence of events

In response to a public notice in the local newspaper, on 18 July 2020 I wrote a letter to Mr. Marco Vincelli at EVB Engineering to provide some public input into an alternate water supply for the Cornwall water treatment plant. I included my personal background as a long-time employee at Domtar, my knowledge of the Domtar water supply system, frazil ice concerns, previous backup plans to supply the Cornwall WTP. At that time, I agreed that pump from the river directly to a new WTP would be the ideal solution. However, other alternatives were possible. I suggested three and made myself available for further discussion.

On 11 March 2022 I received a response advising that the preferred solution was to pump water from the riverbed through a low lift pumphouse on or near the Domtar site (identified as Alternatives “F” and “G” in the 22 March 2022 presentation. My alternative to pump water out of the Old Cornwall Canal was dismissed as an alternative to “F” and “G”. My alternative to locate a second intake in close vicinity of the existing intake was dismissed as both could be impacted by frazil ice simultaneously.

On 22 March 2022 I attended the public meeting held to provide public input to the Cornwall Water Purification Plant Secondary Intake Environmental Assessment. Of the nine alternative solutions originally considered, four options had been selected, engineered, costed and ranked according to Technical Performance, Project Implementation, Natural Environment, Social Environment and Economics. At that time Alternatives F (new intake on former Domtar site) and G (new intake from King Street) were clearly the most favoured at $40M capital cost and $74M 100-year life cycle cost.

At the public meeting and by a follow up letter dated 24 March 2022, I proposed my preferred alternative and asked EVB Engineering to consider it due to a considerably lower capital and life cycle costs.

When notice was published 12 August 2022, I contacted Mr. Marco Vincelli for additional information. Mr Owen O’Keefe was on vacation.

My alternative comprised of:
• a pipe drilled through the Old Cornwall Canal Closure Gate, 20’ below the surface of Lake St Lawrence and south of the existing intake compliant with the expertise of the Transport Canada dealing with frazil ice.
• a removable coarse screen on the west side of the Gate.
• a shut off valve on the east side of the Gate.
• chemical injection system for zebra mussel control (similar to existing intake)
• a raw water transmission pipe vertically down to the bottom of the Old Cornwall Canal which is 14’ deep and never freezes.
• a transmission pipe horizontally east on the bottom of the canal (about 3.4km or 11,300’) to the western boundary of the former Domtar property.
• continue the transmission pipe underground (about 0.6km or 2,000’) to the WPP plant. My preference would be to use the same easement as the former CN tracks across the Domtar property rather than along the west boundary and Second St.
• I believe the ease of operation and improved reliability and reduced impact on the environment significantly favour my alternative over the EA preferred alternative.
• I believe the cost of my alternative to be much, much lower than the $40M capital cost and $74M 100-year life cycle cost assigned to the EA preferred alternative.

The EA preferred alternative (shown as a mix of Alternatives “F” and “G” based on a conversation with Mr Marco Vincelli of EB Engineering on 25 August 2022) comprises of:
• Alternative “G” has a 4-nozzle intake manifold lying on the bottom of the river in a well mixed and fast flowing part of the river, about 20’ deep and at least 20’ offshore. It does not include provision for zebra mussel control or frazil ice formation.
• a horizontal 1200mm pipe drilled under the Old Cornwall to a wet sump located on the north side of the Canal. This pipe is at least 150’ long and the bottom of the sump at least 40’ below grade of the north bank.
• 4 pumps in the wet sump lift the water from river level and deliver it underground to the Water Purification Plant. Details were not given, but this sump will need to be at least 15’ square, located in building at least 40’ square, equipped with an overhead crane, three phase power supply, back up power supply and an all-weather access road. The addition of a bar screen and chemical injection for zebra mussel control would be in addition.
• continue the transmission pipe underground (about 0.6km or 2,000’) to the WPP plant (same as in my alternative). The routing of this pipe is the difference between Alternatives “F” and “G”.

My qualifications to propose this alternative are as follows:
• graduated as a Chemical Engineer from Queen’s University.
• initially employed as a Process Engineer in the Domtar Pulp and Paper Mill in 1965.
• Supervisor and subsequently Manager of the Digester House, Bleach Plant and Chemical Plant including significant process upgrades.
• Manager of the Domtar Waste Water Treatment Plant and the Big Ben solid waste landfill site.
• Manager during the installation and start up of the $61M Secondary WWTP.
• Manager responsible for all Domtar environmental emissions – air, liquid and solid.
• retired from active employment in 2001.
• Long time public member of various local environmental committees including the St Lawrence River Restoration Council, Cornwall Clean Air Committee, Aevitas PLC.
• My many years of operating experience at Domtar included the operation of:
• The mill raw water supply including pumps that drew 125,000 m³/day from the Old Cornwall Canal (three times the City WPP flow), chemical injection to control zebra mussels and both coarse and fine screens to remove suspended solids.
• The mill effluent sump with bar screen and 4 lift pumps that pumped up to 200,000 m³/day of mill effluent and storm water into the Primary Clarifier, associated quality measurement, and the effluent diffuser on the bed of the north channel of the river.
• The design, installation (in 1995) and operation of a conventional Activated Sludge Secondary Treatment Plant including many large diameter underground pipes, sumps and many process and lift pumps.
• Fortunately, in 35 years of operation, only one incident resulted in the complete shut down of the Mill by the Effluent Treatment Plant. It was the result of the failure of electrical switchgear located inside the Pumphouse servicing the of the Primary Lift Pumps.
• The operation of the pumphouse supplying process water from the Canal to the Mill was an ongoing operations and maintenance concern.
• My main take aways are:
a. that continuous operation of any pumphouse is a high cost and high risk operation that should be avoided whenever possible.
b. zebra mussel control is expensive maintenance headache, necessary but doable.
c. frazil ice formation is of much lower concern if the initial installation is designed properly.

Need for professional design, costing and assessment of My Alternative.

I have been retired too long and am sufficiently out of date to properly engineer and cost a project such as this. Like most members of the public, city managers and our elected municipal leaders, I must rely on the current expertise of qualified engineering firms such as EVB that has been hired by the city. This is the main reason I requested a proper evaluation of my proposed alternative.

At the 22 March 2022 meeting I was advised of several facts that were needed to develop an estimate of the cost of my proposed alternative. My follow-up letter of 24 March 2022 states:
• The existing 42” diameter pipe can supply 3-4 times the average requirement of 40,000 m³/day. Consequently, it can easily be relined for future service and the replacement pipe could be somewhat smaller.
• The cost to install an underground pipe of sufficient size was estimated to be $2,000/m. The bottom of the Old Cornwall Canal requires little trenching or backfilling, and the easement already belongs to the federal government. Consequently, the cost to install 3.4km of pipe on the bottom of the Old Cornwall Canal and 0.6 km over the old CN easement should not exceed $8M.
• I estimate the construction cost of $10-12M compared to $40M capital cost for Alternative “G”. This is significant even if I am wrong by 100%.
• I have insufficient knowledge to estimate the 100-year life cycle cost.
• I requested that my proposed alternative be properly engineered, cost estimated and included in the next step of the EA process.

Follow-up to publication of the Notice of Study Completion:

The Notice of Study Completion issued 12 August 2022 confirmed the selection to be Alternative “G”. Further, concerns regarding this project must be submitted on form “012-2206E” within 30 days of the date of the notice.

As no mention was made of the assessment of my alternative made in my letter of 24 March 2022, I phoned Mr. Marco Vincelli, discussed the project in depth and requested help securing a copy of “012-2206E” as I was unable to find it on the internet as directed in the Notice. I subsequently received from him an email dated 29 August 2022 addressing my comments during our conversation. In summary:
• The preferred solution is a new intake in the north channel of the river, a low lift station on Transport Canada property west of Domtar, raw water transmission main to the WPP via King, Young and Second Streets.
• Possible savings of $500K are possible if the main is across the Domtar property.
• My proposed option was evaluated and rejected – “… the installation of second intake in close proximity will be subjected to the same natural risks related to frazil ice and water quality impairment due to localized spills.”
• While my alternative was not costed, some cost comparison was provided using the costs developed for Alternative “E” – a 4.4km gravity feed from the west end of Guindon Park. A $73.8M capital cost and $79.4M 100-year life cycle cost.
• Our conversation also raised the concern that this project should also include costs and timing to rehabilitate the existing intake (intake valve, zebra mussel control, pipe relining and frazil ice prevention) as the project is incomplete until two separate intake lines are in place and ready to operate. In fact, responsible operation would be to cycle each line on a monthly basis. Mr. Vincelli informed me that the City is assessing these concerns separately.
• I was also advised that rules related to bump-up requests based on Aboriginal and treaty rights were changed on 1 January 2022. Also, while the Director of the Environmental Assessment Branch can issue a Notice of Proposed Order, the Minister has a further 30 days to impose conditions. I am not sure how these changes impact my concerns. However, I will address my concerns to the Minister, Director of the EAB and Owen O’Keefe, Supervisor of the Cornwall WTP as directed in this email.
• Many attempts to retrieve Form “012-2206E’ from the Forms Repository Website have failed. Consequently, this request is by direct letter to all parties involved.

Reassessment Requested:
At this time I believe that both My Alternative the EA Preferred Alternative (Alternative “G”) should be engineered, costed and reassessed. This reassessment must include the following:
• In the 65 years since the installation of the Moses Saunders Dam, the IJC and Transport Canada has accumulated considerable expertise into the formation of frazil ice. Under the right conditions, super cooled ice crystals on the surface can form solid ice as deep as 40’ below the surface. Every winter the formation of frazil ice is controlled by the installation of ice booms near Prescott to prevent ice jams, lowering the gates at the Iroquois Control Dam to protect the lock, river flow reductions to promote the formation of surface ice on Lake St Lawrence to protect the 32 turbine intakes in the powerhouse and the formation of surface and frazil ice upstream of the Cedar Rapids and Beauharnois powerhouses and the Beauharnois Canal. Further, while frazil ice has formed in the past on both the City water intake and the Old Cornwall Canal Intake, both of these were designed and installed in 1957. `below the water surface and the design of the intake and coarse screen. The Transport Canada experts must be consulted.
• Alternative “G” has a 4-nozzle intake manifold lying on the bottom of the river in a well mixed and fast flowing part of the river, about 20’ deep and at least 20’ offshore. It does not include provision for zebra mussel control. As zebra mussels grow on every solid surface, in the dark and exposed to a constant flow of water, this intake is a perfect habitat for continual zebra mussel growth. At Domtar the intake was through a coarse screen on the canal wall with periodic chemical injection. In my experience, the Domtar intake was a maintenance nightmare. I am concerned that an intake located off-shore on the river bottom and long distance from the low lift pump station will be almost impossible to maintain. Assessment of Alternative “G” must address zebra mussels.
• Alternative “G” does not include provision for frazil ice buildup. Even with a modern design intake as discussed above, the location in the fast-flowing section of the river, some 20’ below the surface and at least 20’ from shore will make It almost impossible to service. Assessment of Alternative “G” must address frazil ice.
• Alternative “G” proposes a) the installation of a long pipe under the Canal to a wet sump at least 40’ below the surface on Transport Canada land north of the canal; b) the installation of four lift pumps, electrical power supply, backup power supply, maintenance crane, a building to house the above and an all-weather access road for daily inspection and maintenance; c) an underground to the WPP. In my experience at Domtar, the operation of several similar wet sumps with multiple pumps and a continuous operating mandate were some of the most difficult installations to manage. Assessment of Alternative “G” must address the installation and operation of a wet sump some distance from the existing WPP.
• Alternative “G” proposes pumping all the water to the WPP up at least 40’. It requires energy, daily maintenance and increased risk to supply. My Alternative uses the natural head of Lake St Lawrence to deliver all the water to the WPP. Cornwall should be taking advantage of this gift of geography. Assessment of Alternative “G” must address this natural advantage.
• Should frazil ice form on the upstream coarse screen of the existing city water intake, several measures should be installed to allow rapid operator response. First is a moveable mechanical scrapper. Second is a pipe to flush water across the face of the screen. Third is a pump and series valves to back flush the entire line from the WTP. In the past, a diver was employed to clear the intake screen. These ideas must be included in the planned rehabilitation of the existing water intake.
• As far as I can determine, none of the Alternatives assessed include seismic activity. The major earthquake that occurred September 1939 centered on the fault that runs under the No.6 Generator from the north end of the Moses Saunders powerhouse. This was prior to the construction of the St Lawrence Seaway. While another quake is unlikely to destroy the concrete powerhouse, it is more likely to breach the earthworks that stretch more than 10km on both the north and south banks of the river enclosing Lake St Lawrence. Should this EA address seismic activity?
• My Alternative includes the installation of 3.4km of pipe on the bottom of the Old Cornwall Canal. This easement is already owned by Transport Canada, so land acquisition is unnecessary. Secondly, the bottom of the Old Canal is already at a constant 14’ below the surface of the water. Thirdly, routing through Old Lock #19 should pose little obstruction as the gates were removed long ago. Fourth, due to the mandated 4m³/s flow, it will not freeze during the winter. Fifth, as a man-made waterway, the Old Canal is not subject to the stricter regulations imposed on the construction of structures crossing natural waterways. Sixth, the presence of one constant water level aids the construction of a continuous pipe first floated on the surface and carefully sunk to the bottom of the canal. These points must be included in the engineering, costing and assessment of My Alternative.

By hard copy to those addressed and by email to those carbon copied where email addresses are known.
EVB Engineering is the custodian of all relevant documentation and correspondence.

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