OFFICE OF CLIMATE, LICENSING, RESOURCES & RESEARCH

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1 This report has been cleared for submission to Director/Board by Breen Higgins. Grainne Power, 03/11/ :44 OFFICE OF CLIMATE, LICENSING, RESOURCES & RESEARCH INSPECTORS REPORT ON A WASTE WATER DISCHARGE LICENCE APPLICATION To: Directors From: Michael Martin Environmental Licensing Programme Date: 03/11/2015 RE: Application for a Waste Water Discharge Licence from Irish Water, for the agglomeration named Granard, Reg. No. D Application & Agglomeration Details Agglomeration Name: Granard (Appendix 1) County: Schedule of discharge licensed: Longford Licence application received: 29/09/2008 Discharges from agglomerations with a population equivalent of 2,001 to 10,000. Notices under Regulation 18(3)(b) 1 issued: 01/04/2009 & 29/04/2015 Information under Regulation 18(3)(b) received: Site notice check: 15/10/2008 Site Visit: 12/05/2015 Submission(s) Received: 29/06/2009, 12/10/2009 & 22/06/2015 None Design Population Equivalent: 3200 Actual Population Equivalent: 1850 Type of treatment: Wastewater treatment plant (WWTP) description: Secondary with phosphorus removal The plant consists of an inlet works with screening, two aeration tanks, a clarifier, phosphorus removal, two trickling filters (not in use), picket fence thickener and storm water holding tank. 1 Waste Water Discharge (Authorisation) Regulations, 2007, as amended. Page 1 of 7

2 1. Discharges to waters The following table outlines the main considerations in relation to discharges to waters from this agglomeration. Table 1: Discharges to waters Primary discharge point Receiving water name Manmade ditch leading to Lough Hanagower marsh lands. Type of receiving water Freshwater / Possibly to Groundwater Note 1. Normal flow Maximum flow 370 m 3 /day 2247 m 3 /day Storm water overflow(s) Storm water overflow(s) Receiving water name(s) Yes - one Freshwater / Possibly to Groundwater Note 1. Manmade ditch leading to Lough Hanagower marsh lands. Emergency overflow(s) Emergency overflow(s) None Note 1: It is the determination of the Agency s Office of Environmental Assessment that the waters in the marshlands and Lough Hanagower are substantially sourced by groundwater springs and there is the potential for treated effluent from the Granard agglomeration to enter the groundwater sources. Schedule A: Discharges & Discharge Monitoring of the recommended licence (RL) specifies the Emission Limit Values (ELVs) to which the discharge from the Granard agglomeration must conform. Monitoring of the discharges will take place as per this schedule of the RL. There is a large variation noted between the normal and maximum flows recorded from the primary discharge point. This variation can be attributed to the combined nature of the collection network. 2. Receiving waters and impact Consultation was undertaken with Matt Morgan of the Agency s Office of Environmental Assessment (OEA) to determine the source and nature of the receiving waters in the manmade ditch to which the discharge from the agglomeration is made. The surrounding marsh lands and Lough Hanagower, which with an area of just km 2 is not classified as lake waterbody by the Agency. It is the determination of the OEA that the waters in the marshlands and Lough Hanagower are substantially sourced by groundwater springs. Due to the disperse nature of the discharge it is considered by the Agency that there is the potential for treated effluent from the Granard agglomeration to enter the groundwater sources. Due to the potential risk being posed by the discharge to groundwater, Condition 3.7 of the RL requires the existing discharges from the Granard agglomeration to cease as soon as possible and no later than 30th June The licensee is required in the interim period to investigate alternative means of disposal of the treated effluent from the agglomeration. Prior to commencement of any alternative discharge, the licensee shall apply for a review of the Waste Water Discharge Licence. Page 2 of 7

3 The River Rhine (IE_SH_26_1082) outflows from the Lough Hanagower marsh lands. The following table summarises the main considerations in relation to the River Rhine downstream of the primary discharge. Table 2: Receiving waters Characteristic Classification Comment Receiving water River Rhine (Approx. 150m name downgradient of SW001) (WFD Code: IE_SH_26_1082) Lough Forbes Complex SAC (Site code: ) (40 km downstream) Ballykenny Fisherstown Bog SPA (Site code: ) Designations (Not hydrologically connected) Lough Kinale and Derragh Lough SPA (Site code: ) (Not hydrologically connected) Ardagullion Bog SAC (Site code: ) (Not hydrologically connected) Receiving water monitoring stations D0187SW001discharge (EPA RS Code: RS26R040000) Approx. 150m d/s of SW001 on River Rhine Biological quality rating (Q value) Q3 Moderately Polluted 2.4 km d/s of WWTP on River Rhine WFD status Poor (2015) Restore 2021 The Camlin-Rinn Water Management Unit Action Plan (WMUAP) identifies the WWTP in Granard as a point pressure on the River Rhine catchment. Measures identified in the plan are to investigate the need for tertiary treatment or for the relocation of the outfall. The WWTP serving the Granard agglomeration currently provides secondary treatment with phosphorus removal. As mentioned above, Condition 3.7 of the RL requires the existing discharges from the Granard agglomeration to cease as soon as possible and no later than 30 th June In line with the requirements of the Urban Wastewater Treatment Directive, the RL sets Emission Limit Values (ELVs) of 125mg/l for COD, 25mg/l for BOD and 35mg/l for suspended solids (SS) which will apply from date of issue of licence. Under the requirements of the Water Framework Directive, the River Rhine (IE_SH_26_1082) must be restored to Good Status by As discharges from the Granard agglomeration must cease no later than 30 th June 2017 and the Licensee is required to apply for a review of the licence prior to commencement of an alternative discharge on or before 1 st July 2017, ELV s have not been recommended for Orthophosphate or Ammonia at this time and will be determined as part of the review process. 3. Ambient Monitoring Schedule B: Ambient Monitoring of the RL specifies the parameters, analysis method and frequency for which ambient monitoring of the primary discharge shall be carried out. The requirements for ambient monitoring in Schedule B: Ambient Monitoring are sufficient to ensure that there will be no deterioration in the status of the receiving water as a result of the discharge. 4. Combined Approach The Waste Water Discharge (Authorisation) Regulations, 2007, as amended, specify that a combined approach in relation to licensing of waste water works must be taken, whereby the emission limits for the discharge are established on the basis of the stricter of either or both, the limits and controls required under the Urban Waste Page 3 of 7

4 Water Treatment Regulations, 2001, as amended, and the limits determined under statute or Directive for the purpose of achieving the environmental objectives established for surface waters, groundwater or protected areas for the water body into which the discharge is made. The RL as drafted gives effect to the principle of the Combined Approach as defined in Waste Water Discharge (Authorisation) Regulations, 2007, as amended. 5. Programme of Improvements There is a programme of improvements in place for the agglomeration. As stated above, the RL requires that the existing discharges from the agglomeration cease by 30 th June 2017 and prior to the commencement of an alternative discharge, the licensee shall apply for a review of the licence. In the interim, Condition 5.1 of the RL requires the licensee to prepare and submit to the Agency a programme of infrastructural improvements to maximise the effectiveness and efficiency of the waste water works. The WWTP in Granard provides secondary treatment with phosphorus removal for wastewater from the Granard agglomeration and the conditions and emission limit values specified in the RL will ensure no deterioration in the quality of the receiving waters as a result of the discharge. 6. Compliance with EU Directives In considering the application, regard was had to the requirements of Regulation 6(2) of the Waste Water Discharge (Authorisation) Regulations, 2007, as amended, notably: Table 4: Compliance with EU Directives/Regulations Compliance with Directives/Regulations Urban Waste Water Treatment Directive [91/271/EEC] Description and Conditions in RL Compliant in Water Framework Directive [2000/60/EC] Good status to be achieved by EC Environmental Objectives (Surface Water) Regulations 2009 (S.I. No. 272 of 2009), as amended Drinking Water Abstraction Regulations Bathing Water Directive [2006/7/EC] Dangerous Substances Directive [2006/11/EC] Environmental Impact Assessment Directive [85/337/EEC] Schedule A of RL sets ELVs to contribute towards achieving the environmental quality objectives. There are no drinking water abstractions downstream. No bathing waters present Condition 4 requires screening for priority substances. An EIS was not required for Granard WWTP. Page 4 of 7

5 Birds Directive [2009/147/EC] & Habitats Directive [92/43/EEC] The Granard WWTP discharges indirectly via the River Rhine, Kileen Lough, Ballinlough River, Ballin Lough, Corbaun River, Cloonfin Lough and Camlin River into the Lough Forbes Complex SAC 2 (Site code: ). The site is protected for priority habitats listed under Annex 1 of the Habitats Directive. It is also selected for protection of species listed under Annex II of the same directive. The site is also designated an SPA 3 Ballykenny Fisherstown Bog SPA (Site code: ) under the Birds Directive for the conservation of wild birds. Ardagullion Bog SAC (Site code: and Lough Kinale and Derragh Lough SPA (Site code: ) are also in the vicinity of the primary discharge, (4 kms to the South West and 4.7 kms to the East respectively). A screening for Appropriate Assessment was undertaken to assess, in view of best scientific knowledge and the conservation objectives of the site, if the activity, individually or in combination with other plans or projects, is likely to have a significant effect on any European Site. In this context, particular attention was paid to the European sites at Lough Forbes Complex SAC, Ballykenny Fisherstown Bog SPA, Ardagullion Bog SAC and Lough Kinale and Derragh Lough SPA. The Agency considered, for the reasons set out below, that the activity is not directly connected with or necessary to the management of any European site and that it can be excluded, on the basis of objective information, that the activity, individually or in combination with other plans or projects will have a significant effect on any European site, and accordingly the Agency determined that an Appropriate Assessment of the activity was not required. This determination is based on the following: 1. The absence of hydrological connectivity between the discharges from the agglomeration and the Ardagullion Bog SAC and the Lough Kinale and Derragh Lough SPA. 2. The good water quality status of the downstream receiving water (Camlin River IE_SH_26_39_27) under the Water Framework Directive. 3. The distance of the Lough Forbes Complex SAC and the Ballykenny Fisherstown Bog SPA downstream of the primary discharge (approximately 37 km). 7. Cross Office Liaison Advice and guidance issued by the Waste Water Technical Working Group (WWTWG) was followed in the assessment of this application. Advice and guidance issued by the WWTWG is prepared through a detailed cross-office co-operative process, with the concerns of all sides taken into account. The Board of the Agency has endorsed the advice and guidance issued by the WWTWG for use by licensing inspectors in the assessment of wastewater discharge licence applications. As mentioned previously, consultation was undertaken with Matt Morgan of the Agency s Office of Environmental Assessment with regard to the hydrological synamic in the vicinity of the discharge. 8. Submissions No submissions were received in relation to this application. 2 SAC: Special Area of Conservation designated under the Habitats Directive, Council Directive 92/43/EEC of 21 May 1992 on the conservation of natural habitats and of wild fauna and flora. 3 SPA: Special Protection Area designated under the Birds Directive, Directive 2009/147/EC of the European Parliament and of the Council of 30 November 2009 on the conservation of wild birds. Page 5 of 7

6 9. Charges The RL sets an annual charge for the agglomeration at 4, and is reflective of the monitoring and enforcement regime being proposed for the agglomeration. 10. Recommendation I recommend that a Final Licence be issued subject to the conditions and for the reasons as set out in the attached Recommended Licence. Signed Michael Martin, Inspector. Environmental Licensing Programme Page 6 of 7

7 Appendix 1: Map showing location of Granard WWTP and associated primary discharge point. Lough Kinale and Derragh Lough SPA - ~ 4.7 kms east Granard WWTP and Primary Discharge Point Lough Forbes Complex SAC & Ballykenny Fisherstown Bog SPA ~37.5 kms west River Rhine Approximate delineation of marshlands & Groundwater springs in the vicinity of the primary discharge point Ardagullion Bog SAC - ~ 4 km South West Page 7 of 7