Annual Environmental Report. For. Skerries Balbriggan Agglomeration, Waste Water Discharge Licence No. D

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1 Annual Environmental Report For Skerries Balbriggan Agglomeration, Waste Water Discharge Licence No. D Annual Environmental Report Skerries Balbriggan Rev 2 Page 1 of 22

2 Table of Contents 1 Executive Summary 3 2. Summary of Monitoring Reports 2.1 Summary Table of Influent Monitoring Discharges from the agglomeration Barnageeragh WWTP Secondary Discharges Ambient Monitoring Summary Data Collection and Reporting requirements under the Urban Waste Water Treatment Directive Pollutant Release and Transfer Register PRTR Proposal for current year Operational Summary 3.1 Complaints Summary Reported Incidents Infrastructural assessments and Programme of Measures 4.1 Treatment Capacity Storm water overflow identification and inspection report Report on progress made and proposals being developed to meet the improvements programme requirements Environmental Liability and Financial Provisions 5.1 Annual Statement of measures Licence Specific Reports 6.1 Predicted Impacts Report Assessment of predicted impacts on habitats Development infrastructural works summary Toxicity report Environmental Liabilities Risk assessment Certification by Director of Services 24 APPENDIX 1 APPENDIX 2 APPENDIX 3 PRTR Infrastructural Assessments & Programme of Measures Assessment of impact on Shellfish Waters Annual Environmental Report Skerries Balbriggan Rev 2 Page 2 of 22

3 1 Executive Summary The Balbriggan Skerries agglomeration lies in the north-east of Fingal. The agglomeration is divided into two main sub-catchments of Balbriggan and Skerries. The sewage from the two catchments is pumped to a 70,000pe Wastewater Treatment Plant that is situated on the northern outskirts of Skerries at Barnageeragh and discharges via a long (2km) sea outfall to the Irish Sea. Fingal County Council applied for a Waste Water Discharge Licence (WWDL) for the agglomeration under the Waste Water Discharge (Authorisation) Regulations (S.I. 684 of 2007). The Licence, D , was issued by the EPA on 22 nd Oct Condition 6.11 of the Licence requires Fingal County Council to submit to the EPA, by the 28 th February of each year, an Annual Environmental Report (AER) covering the previous calendar year. This AER is prepared for the period 1 st Jan 2011 to 31 st Dec 2011 in accordance with Condition 6.11 and Schedule D of the Licence, and in accordance with the Guidance on the Preparation & Submission of the Annual Environmental Report (AER) for Waste Water Discharge Licences for 2011, Issue No. 2, Rev No. 2, as issued by the EPA 15/02/2011. The Barnageeragh WWTP is a CASS (Continuous Activated Sludge System) plant using four Sequential Batch Reactors (SBRs) to treat the influent. The plant is a Design Build Operate Contract with AECOM Design Build Ireland LTD as the Contractor. The plant is manned 9am to 5pm Monday to Friday, with a visit on Saturdays and Sundays. The plant is fully automated with a system for dialling out to an operator in the event of an emergency outside normal working hours. The effluent from the plant met the requirements of the Licence on all occasions during the year except the faecal coliform requirement of 1,000cfu/100ml on two occasions in March. The cause of these failures are not known, but it is noted that on the 23 rd March, FCC took a sample at the same time and within 1m of the sample taken by AECOM, which when tested by the Central Labs met the requirements. AECOM in response to these sample results have operated two UV banks at all times instead of one duty and one standby as previously. No further failures were recorded. The village of Loughshinney is included in this agglomeration. At present, the effluent from Loughshinney is collected and passed through a septic tank before discharge to the North Western Irish Sea. The results for Loughshinney indicate that primary treatment only is being given to the effluent prior to discharge to the sea. There are no ELVs in the Licence. There was no sampling at the other secondary discharge points. The EPA stated that they have not had the time or resources to process the 2011 ambient monitoring data yet. Data from 2010 is included, as well as Marine Institute ambient monitoring for The results of the testing indicate that the discharge from the agglomeration is not affecting the ambient waters. Annual Environmental Report Skerries Balbriggan Rev 2 Page 3 of 24

4 The Bathing Water Quality results for 2011 show that the waters met the EU mandatory requirements at all times and were safe to bathe in. The waters did not meet the more stringent Guide (Blue Flag) standards on 7 occasions; twice in Balbriggan, once in Skerries and on 4 occasions in Loughshinney. Short-term and very intensive rainfall at these location may have contributed to results that did not met the Blue Flag standards. There are also a number of factors which may have influenced the bathing water quality: agricultural discharges, overflows from the sewer network following heavy rainfall events, discharges from local septic tanks and onsite treatment plants in the catchment, misconnections, concentration of bird populations, activities in local harbours and beach activities (dog walkers and horses). Seven incidents were reported to the EPA. Two were due to planned maintenance, two were due to power failure at a pump station, one was a pumping station malfunction, one was due to a major rainfall event and the last was an alert to the EPA for an event that in the end was cancelled. A total of seven environmental complaints were received. None of these were from causes attributable to the Local Authority. The targets set in the Specified Improvement Programmes (under Schedule A & C of the Licence) were not met. The funding for the major Works has not been included in the Water Services Investment Program The connection of Kellys Bay PS directly to the treatment plant which is being funded by Fingal County Council has been delayed due to problems in procuring pumps. The necessary civil works are completed, and the connection is expected to be working by end Q Annual Environmental Report Skerries Balbriggan Rev 2 Page 4 of 24

5 2. Monitoring Reports Summary 2.1 Summary table of Influent Monitoring, Barnageeragh WWTP Note: All samples, unless otherwise stated, were taken by Fingal County Council and tested at Dublin City Council s Central Laboratories, which is INAB accredited to ISO BOD (mg/l) COD (mg/l) SS (mg/l) TP (mg/l) TN (mg/l) Hydraulic Loading (m 3 /day) Organic Loading (PE/day) Number of samples Maximum Result ,415 41,453 Annual Mean ,316 30,688 There are no Licence requirements for influent. Annual Environmental Report Skerries Balbriggan Rev 2 Page 5 of 24

6 2.2 Discharges from the agglomeration WWDL ELV (Schedule A) ELV with Condition 2 Interpretation included No. of sample results No. of sample results above ELV No. of sample results above ELV with Condition 2 interpretation included. Annual Mean (for parameters where a mean ELV applies) Overall compliance (Pass/Fail) BOD COD SS TP TN ph (mg/l) (mg/l) (mg/l) (mg/l) (mg/l) Conductivity FOG Nitrate Nitrite Ammo nia Orthophosphate Faecal e- Entero PCB Colour Salinity coliforms coli cocci <1000* Pass Pass Pass Pa ss Pass Pass * This limit is contained in the Scheme approval from DoEHLG, not in Licence. Annual Environmental Report Skerries Balbriggan Rev 2 Page 6 of 24

7 Barnageeragh WWTP - Discussion of Results: The influent results averaged over the year show the following: BOD COD SS Total N Total P 268mg/l 576mg/l 296mg/l 42mg/l 6.6mg/l The effluent results averaged over the year show the following: BOD COD SS Total N Total P 5mg/l 35mg/l 12mg/l 9mg/l 3.0mg/l The average results for the year for influent and effluent indicate that the load is being reduced as follows: Parameter Percentage Reduction (%) BOD 98 COD 94 SS 96 Total N 78 Total P 55 The table above indicates that the plant is meeting the requirements for reduction of BOD, COD and SS, and even though it is not discharging to a sensitive area, Total Nitrogen. The results show that the plant met the requirement of the Licence and the Urban Waste Water Treatment Regulations for BOD, COD and Suspended Solids on every occasion during The plant failed to meet the faecal coliform requirement of 1,000cfu/100ml on two occasions in March. The cause of these failure are not known, but it is noted that on the 23 rd March, FCC took a sample at the same time and within 1m of the sample taken by AECOM, which when tested by the Central Labs met the requirements. AECOM in response to these sample results have operated two UV banks at all times instead of one duty and one standby as previously. No further failures were recorded. Annual Environmental Report Skerries Balbriggan Rev 2 Page 7 of 24

8 2.2.2 Secondary discharge points Loughshinney, Killalane & Hoars Rock. Loughshinney effluent: Date Type B.O.D. C.O.D. Suspended Solids ph Ammonia mg/l mg/l mg/l mg/l as N 03/02/2011 Effluent > /02/2011 Effluent /03/2011 Effluent /06/2011 Effluent > /10/2011 Effluent /11/2011 Effluent /12/2011 Effluent The effluent results averaged over the year show the following: BOD 174mg/l COD 376mg/l SS 130mg/l ph 7.7 Ammonia 25mg/l Using the average results for the year for influent in Barnageeragh and the average effluent results above, the table below indicates that the load is being reduced in the order of: Parameter Estimated Percentage Reduction % BOD 35 COD 35 SS 56 ph - Ammonia - Killalane: No monitoring required. Hoars Rock: No monitoring required. Loughshinney: Discussion of Results The results for Loughshinney indicate that primary treatment is being given to the effluent prior to discharge to the sea. There are no ELVs in the Licence. Fingal County Council engaged in a major corporate restructuring in Tasks and personnel were changed, and in the confusion, the sampling of the outlying plants, including Loughshinney, were interrupted. Thus there are only 7 samples for Annual Environmental Report Skerries Balbriggan Rev 2 Page 8 of 24

9 2.3 Ambient Monitoring Summary There was no ambient monitoring carried out by Fingal County Council in Below are the latest available results of the ambient monitoring carried out by the EPA in the area. The location of the sampling stations is also given below. Station DB780S DB780B DB780S DB780B DB780S DB780B DB780S DB780B Survey Date 01/02/ /02/ /05/ /05/ /07/ /07/ /09/ /09/2010 DB800S DB800B DB800S DB800B DB800S DB800B DB800S 01/02/ /02/ /05/ /05/ /07/ /07/ /09/2010 Depth Bed Sample Depth Salinity % Temp C ph DO % Sat B.O.D. mg/l O Chloroph yll a mg/m DIN mg/l N Note: S suffix in Station indicates surface sample, B suffix indicates a bottom sample. Annual Environmental Report Skerries Balbriggan Rev 2 Page 9 of 24

10 The results of sampling carried out by the Marine Institute in 2011 are given below: Sample Date Shellfish Area Latitude Longitude Water Depth (m) Sample Depth (m) Temp ( C) p H Salinity DO (%sat) dissolved COLOR particulate SUSP(mg/l) 44 30/01/11 Balbriggan\ Skerries 45 31/01/11 Balbriggan\ Skerries 47 01/02/11 Balbriggan\ Skerries /06/11 Balbriggan\ Skerries /07/11 Balbriggan\ Skerries /08/11 Balbriggan\ Skerries < <4 < <4 <2 The location of the samples is shown on the following page. The sample results were compared to the requirements of the European Communities (Quality of Shellfish Waters) Regulations S.I. 268 of 2006 and the European Communities Environmental Objectives (Surface Water) Regulations S.I. 272 of The results of the testing as shown above indicate that the discharge from the agglomeration is not affecting the ambient waters. Annual Environmental Report Skerries Balbriggan Rev 2 Page 10 of 24

11 Annual Environmental Report Skerries Balbriggan Rev 2 Page 11 of 24

12 The results of the Shore Monitoring carried out in 2011 are shown in the table below. Annual Environmental Report Skerries Balbriggan Rev 2 Page 12 of 24

13 The Bathing Water Quality limits are shown below: microbiological parameters Guide Mandatory E.Coli (no/100ml) <=100* <=2 000*** Enterococci (no/100ml) <=100** The sample results were compared to the requirements of the Bathing Water Quality Regulations S.I. 79 of The test results show that the waters met the EU mandatory requirements at all times and were safe to bathe in. The waters did not meet the Guide (Blue Flag) standards on 7 occasions; twice in Balbriggan, once in Skerries and on 4 occasions in Loughshinney. There are known misconnections in Balbriggan which discharge to the end of the bathing beach via the Matt or Bracken River, and also in Loughshinney which discharge directly onto the beach via the surface water network. These misconnections are being addressed by Fingal Council Council s Drainage Operations staff and Pollution section, who have issued a Warning Notice under the Water Pollution Act in Loughshinney. There are other issues which may also have caused the Blue Flag exceedances. Short-term and very intensive rainfall at this location may have contributed to noncompliant results. There are also a number of factors which may have influenced the bathing water quality: agricultural discharges, overflows from the sewer network following heavy rainfall events, discharges from local septic tanks and onsite treatment plants in the catchment, misconnections, concentration of bird populations, activities in local harbours and beach activities (dog walkers and horses). 2.4 Data Collection and Reporting requirements under the Urban Waste Water Treatment Directive. The returns as required by the Urban Waste Water Treatment Directive have been returned to the EPA. 2.5 Pollutant Release and Transfer Register Submitted to EPA website on 27 th Feb Paper copy included in Appendix I. 2.6 PRTR proposal for current year. This requirement has been addressed in the electronic submission to the EPA. Annual Environmental Report Skerries Balbriggan Rev 2 Page 13 of 24

14 3 Operational Summary 3.1 Complaints Summary Number Date Nature of Complaint Response to Complaint Closed? /2/2011 Dumping of tanker into drains /03/2011 Oil in surface water drains /03/2011 Oil in Balbriggan Harbour /05/2011 Raw sewage in Balbriggan Harbour /06/2011 Slick noticed about emergency overflow in Hampton Cove for last week /08/2011 Failing percolation in Turkinstown, Balbriggan /08/2011 Oil spill in Skerries Harbour Tanker owners traced and contacted. Dumping denied. Inspections carried out. No oil in SW drains, but evident in foul system. No cause found. Area inspected. Boat filling with diesel overfilled and spilled into harbour. Warning letter sent to those responsible. Visual inspections, checked the telemetry records, no evidence/record of an overflow. Warning letter issued. Area inspected, no responsible body found. Oil dispersed naturally. Annual Environmental Report Skerries Balbriggan Rev 2 Page 14 of 24

15 3.2 Reported Incidents Seven incidents were reported to the EPA during the year as set out below: Date and Time 11 th March :45 to 15:05 22 nd March :00 to 14:00. Incident Description Pump station overflow in operation at Rush Rd Isaacs Bower overflowed to Irish Sea, Rush Rd PS pumped to Shenick Island for discharge. Cause Corrective action Authorities contacted ESB outage at Rush Rd PS. Controlled shutdowns to PSs to allow connection to rising main. 21 st June 2011 Proposed day long ESB shutdown. Planned ESB outage 10 th Aug :00 to 1700 (approx) 6 th Sept :45 to 09:15 30 th Sept 2011 to 2 nd Oct 2011 Pump station overflow in operation at Rush Rd ESB outage at Rush Rd PS. Reported to EPA (/No) Closed? None possible EPA by phone All possible actions taken to ensure speedy completion of connection. Following representations from FCC the ESB carried out their works without cutting off power to Rush Rd PS. Pump station overflow at Isaacs Bower PS Ragging of pumps Pumps reversed, rags cleared, normal operations resumed. Overflows from the pumping stations at Isaacs Rain event None possible. Storm tanks Bower and Rush Road and overflow from the storm at Quay St, Balbriggan and at water holding tank at Barnageeragh WWTP. Pump Barnageeragh WWTP filled. station overflows in operation, and storm tank overflows from 20: 00 to 22:00 on 30 th Sept 2011 and from 04:00 1 st Oct 2011 to 04:00 2 nd Oct Possible breach of ELVs during storm tank overflows Swimming club in Skerries, Residents Ass in Isaacs Bower EPA, MI, SFPA, Skerries swimming club. None possible EPA EPA, MI, SFPA, BIM EPA, MI, SFPA, BIM Annual Environmental Report Skerries Balbriggan Rev 2 Page 15 of 24

16 Date and Time 5 th Oct :45 to 14:15 Incident Description Pump station overflows operated from 09:45 to 13:50 at Isaacs Bower and from 10:30 to 14:15 at Rush Rd. Isaacs Bower PSO discharged directly to the Irish Sea, Rush Rd discharged to the old Rush Rd PS which pumped the overflow to the old septic tank on Shenick Island and hence to the Irish Sea. Cause Corrective action Authorities contacted Planned maintenance required at inlet chamber of Barnageeragh WWTP. Reported to EPA (/No) Closed? None possible EPA Summary of Incidents Table: Number of incidents in Number of incidents reported to the EPA in Explanation of any discrepancies between the two numbers above Annual Environmental Report Skerries Balbriggan Rev 2 Page 16 of 24

17 4. Infrastructural Assessments and Programme of Measures 4.1 Treatment Capacity Hydraulic Capacity Design/As Constructed (m 3 /day) 16,100 Hydraulic Capacity Current loading (m 3 /day) 7,316 Hydraulic Capacity remaining (m 3 /day) 8,784 Organic Capacity Design/As Constructed (PE) 70,000 Organic Capacity Current Loading (PE) 30,688 Organic Capacity remaining (PE) 39,312 Will the capacity be exceeded in the next three years No (/No) 4.2 Storm Water overflow identification and inspection report Please see attached report in Appendix 3 How many SWOs are listed in the Schedule A4 of the WWDL? 11 How many additional SWOs are listed in the agglomeration? 0 Total number of SWOs in the agglomeration? 11 How many SWOs are listed as compliant with the DoEHLG Guidance? 0 For each SWO identified as non-compliant with the DoEHLG Guidance is there 0 a Corrective action plan included in the Programme of Improvements? Does the SWO assessment include the requirements of Schedules A3 & C3? 0 Have the EPA been advised of any additional SWOs/changes to Schedule C3 and No A4 under Condition 1.7? 4.3 Report on progress made and proposals being developed to meet the improvements programme requirements An Infrastructural Assessments & Programme of Improvements Report was included in the 2010 AER. The Report is again included in Appendix 2 with updates in italics. Annual Environmental Report Skerries Balbriggan Rev 2 Page 17 of 24

18 Schedules A3 and C Improvement Programme summary report. Specified Improvement Programmes (under Schedule A & C of WWDL) Discharge from Killalane septic tank shall cease from 31 December 2010 Discharge from Loughshinney septic tank shall cease from 31 December 2010 Discharge from SW6 at Hoar s Rock, Skerries shall either cease or revert to a surface water overflow by 31 December 2010 Balbriggan/Skerries Wastewater Treatment Scheme (Phase III) Sewer Network Upgrade. Infrastructure to direct wastewater from Loughshinney and Killalane to Barnageeragh WWTP. Upgrading of sewer network to ensure Storm Water Overflows comply with the criteria outlined in the DoEHLG Procedures and Criteria in relation to Storm Water Overflows, 1995 Connection of Kelly s Bay PS to Barnageeragh WWTP. Discharge point SW6 shall either cease or Licence Schedule (A or C) Licence Completion Date Date Expired? Status of Works A3 31 st Dec 2010 Y Delayed due to lack of funding. A3 31 st Dec 2010 Y Delayed due to lack of funding. A3 31 st Dec 2010 Y Work ongoing. C1 31 st Dec 2010 Y Delayed due to lack of funding. C2 31 st Dec 2010 Y Delayed due to lack C3 Refer to Condition 4.11 of funding. C3 31 st Dec 2010 Y Work ongoing. revert to a SWO. Any other works notified in writing by the Agency. C1, C2, C3 As agreed None notified. Comments Licensee Timeframe for Completing the Works Not on WSIP Q Not on WSIP Q Civil works complete, pumps ordered, not delivered yet. Q Not on WSIP Q Not on WSIP Q Not on WSIP Q Civil works complete, pumps ordered, not delivered yet. Q Annual Environmental Report Skerries Balbriggan Rev 2 Page 18 of 24

19 Preferred format for Schedule A3 and C Improvement Programme Summary report. Does the Improvement Programme include an assessment of the integrity of the existing wastewater works (WWTP & network) for the following: Capacity of the works Leaks from the works What % of leakage is reported? Misconnections between foul sewer to surface water drainage What % of misconnection is reported? Surface water infiltration Groundwater infiltration Comment Does the Improvement Programme require an assessment of secondary Discharges (e.g. cease discharge/upgrade to meet requirements) for the following: Receiving water body designation Downstream abstractions and uses of water Water quality objectives for the water body Comment Are the findings of the SWO Identification and Inspection Report included in the Improvement Programme (upgrades to meet licence requirements) Comment For each improvement identified does the Improvement Programme include an implementation plan that: Identifies and describes each improvement including a timeframe for implementation? (Cond. 5.3) Specifies the parameters that will be affected by the improvement? Estimates the costs and source of the funding? Estimates the water quality improvement associated with the Improvement? Comment Not available Not available No SWO inspections not carried out yet. Annual Environmental Report Skerries Balbriggan Rev 2 Page 19 of 22

20 5. Environmental Liability and Financial Provisions 5.1 The following are a list of the measures taken to prevent environmental damage in the Balbriggan Skerries agglomeration: a) A 35m plant has been constructed in Barnageeragh to cater for a p.e. of 70,000. The plant currently caters for a p.e. of approx. 31,000. The plant and the main lift pumping stations in Skerries and Balbriggan are operated by the DBO Contractor AECOM Design Build Ireland Ltd for Fingal County Council at an annual cost of the order of 1.6m b) Fingal County Council employs a Water Services Operational Section with a staff of 51 to maintain and service the sewer network. c) Fingal County Council employs a Mechanical Section to maintain and service the pump stations in the agglomeration and the Telemetry system which monitors them. d) Fingal County Council maintains an out-of-hours capability for dealing with mechanical breakdowns and sewer chokes/environmental incidents. Fingal County Council does not maintain a specific financial provision in relation to underwriting of costs for remedial action following environmental incidents. Annual Environmental Report Skerries Balbriggan Rev 2 Page 20 of 24

21 6. Licence Specific Reports Licence Specific Reports Summary Table: Licence Specific Report Required in 2011 AER Priority Substance Assessment Drinking Water Abstraction Point Risk assessment Habitats Impact assessment Shellfish Impact assessment Toxicity/Leachate Management No No No Included in 2011 AER No No No Location in 2011 AER Summary of findings on page 20, full Report in Appendix 3. No No 6.1 Predicted impacts Report Not required under this licence. 6.2 Assessment of predicted impacts on habitats. Shellfish Impact Assessment summary table: Is a Shellfish Impact Assessment required? Organisations consulted when preparing the assessment Does the assessment identify that any of the discharges from the works are impacting on the microbiological quality of the shellfish? List impacts identified Is there a requirement to install UV/other disinfection equipment on any of the discharges? Has this been completed? If not yet complete what is the expected date for completion? Is there a programme in place to demonstrate the efficiency of any disinfection system in place? Is there a shellfish monitoring programme in place? BIM, MI, EPA, SFPA No impact on designated shellfish. No N/a N/a, by SFPA Annual Environmental Report Skerries Balbriggan Rev 2 Page 21 of 24

22 Fingal County Council submitted an assessment of the impact of the discharge(s) on the microbiological quality of the adjacent designated shellfish waters to the EPA on by 17 th June A copy is included in Appendix 3. The Report concluded: The testing carried out by Fingal County Council for this report indicate that there is a better than 99.6% reduction in e-coli in the treatment and disinfection given the raw sewage in the Barnageeragh WWTP prior to discharge to a designated Shellfish Area. This confirms results of ongoing testing carried out by FCC and the O & M contractor. The reduction in FRNA bacteriaphage is of the same order. However, the reduction for Norovirus genogroups GI and GII are not as clear. The results of the ongoing sampling by the Seafood Protection Agency and from the Rockabill Shellfish Ltd indicate that the razor clams for which the area is designated a Shellfish Area meet the criteria for the A Classification. Shellfish from A Classification areas can be taken for direct human consumption without further processing. Based on the testing carried out by Fingal County Council, the SFPA, the Marine Institute and others, Fingal County Council are satisfied that the designated Balbriggan Skerries Shellfish Area is not being adversely affected by the effluent from the Balbriggan Skerries Agglomeration primary discharge, as the designated species is achieving an A Classification. 6.3 Development infrastructural works summary. Please see attached report in Appendix Toxicity report This report is not required under this Licence. 6.5 Environmental Liabilities Risk assessment This Assessment was carried out and submitted to the EPA on the 19 th Oct A review of the ELRA was carried out in early 2012 and as no significant change to the volume or character of the effluent discharge has occurred, no changes were made to the ELRA. Annual Environmental Report Skerries Balbriggan Rev 2 Page 22 of 24

23 Licence Specific Reports Summary Table: Licence Specific Report Required in 2011 AER Priority Substance Assessment Drinking Water Abstraction Point Risk assessment Habitats Impact assessment Shellfish Impact assessment Toxicity/Leachate Management No No No Included in 2011 AER No No No Location in 2011 AER Summary of findings on page 20, full Report in Appendix 3. No No Annual Environmental Report Skerries Balbriggan Rev 2 Page 23 of 24

24 7.0 Certification This AER contains the following: Introduction and background to 2011 AER Monitoring reports summary Operational reports summary Infrastructural Assessment and Programme of Improvements Environmental Liability and Financial Provision Licence specific reports Certification and sign off Appendices Does the AER include an executive summary? Does the AER include an assessment of the performance of the Waste Water Works (i.e. have the results of assessments been interpreted against WWDL requirements and/or Environmental Quality Standards? Is there a need to advise the EPA for consideration of a technical amendment/review of the Licence Reason? Is there a need to request/advise the EPA of any modifications to the existing WWDL? (See Condition 1.7 (changes to works/discharges) & Condition 4 (changes to monitoring location, frequency etc)) List reason (e.g. failure to complete specified works within dates specified in the licence, changes to monitoring requirements) Have these processes commenced? (i.e. request for technical amendment/licence review/change request) Are all outstanding reports and assessments from previous AERs included as an appendix to this AER? No One SWO removed. No funding for Specified Improvement Program (under Schedule A & C of Licence) No I hereby certify that this Annual Environmental Report for the Skerries Balbriggan agglomeration, Waste Water Discharge Licence No. D , for 2010 is representative and accurate. Paul Graham, Senior Executive Engineer, Water Services, Fingal County Council. Authorised under Manager s Order FWS/214/2011 to deputise on behalf of the DoS for the purposes of certifying reports submitted to the EPA as may be required under Waste Water Discharge Licences and Certificates. Annual Environmental Report Skerries Balbriggan Rev 2 Page 24 of 24

25 Appendix 1 PRTR 2011

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30 Appendix 2 Infrastructural Assessments & Programme of Measures

31 Infrastructural Assessments & Programme of Improvements Infrastructural Assessments a) Barnageeragh WWTP. The WWTP is assessed as being more than adequate at present. The design p.e. is 70,000, the actual load is of the order of 30,000. The plant is still less than 5 years old and the equipment is suited to the demands placed on it. The level of treatment is meeting the emission limit values as specified in the original design and the WWD Licence. Due to the design of the plant, even though it is not required to, it is also reducing total nitrogen and total phosphorus by 76% and 55% respectively. Having discussed the matter with the O & M Contractor, he is of the opinion that while it is possible to increase the reduction in total nitrogen and total phosphorus using the existing design, to do so would run the risk of upsetting the statutory parameters. The receiving water is the Northern Western Irish Sea which is classed as High status under the Eastern River Basin Plan (ERBP) Management Plan. Testing carried out by the Marine Institute and the EPA on the waters indicates that the discharge from the agglomeration is not affecting the ambient waters. The receiving waters are also are designated Shellfish Waters. They are Class A, which means that no treatment is needed on shellfish harvested in the area. This would also indicate that the discharges from the agglomeration are not affecting the ambient waters. b) The Waste Water Works. (i) The capacity of the waste water works can be estimated/measured by the number of overflows. This will be dealt with under the SWO section. (ii) There is no evidence of leaks from the waste water works other than the SWOs. (iii) As part of an investigation into bathing water quality issues on Balbriggan beach, misconnections from foul sewers to the surface water drainage networks were identified in 2010 in Balbriggan. The sources of some of these misconnections have been identified and are being pursued by the Pollution Control Section. There is no evidence of major misconnections of foul to surface water elsewhere in the waste water works. (iii), (iv) & (v) It is evident from the flow records into the WWTP that there are issues with misconnections from surface to foul, groundwater infiltration and areas within the older parts of the system with combined sewers. The Greater Dublin Strategic Drainage Study (GDSDS) report in 2006 estimated that there was between 21% and 48% of surface water infiltration in the system. This is extremely difficult to deal with and Fingal County Council has no plans at present to tackle it.

32 (vi) as part of the Operate and Maintain (O & M) Contract for the Barnageeragh WWTP, a survey of the sea outfall has to be carried out once a year. A survey was carried out in late 2010 and a DVD provided. The buoys and lights were inspected in Feb They were cleaned of mussel infestation and had minor repairs carried out. The mooring chains were replaced. There have been no complaints of the buoys in There has been some minor vandalism of the shore light, but there have been no complaints of its operation. (vii) No other aspects specified. c) Secondary Discharges Loughshinney, Killalane & Hoars Rock. (i) & (ii) The secondary discharges at Loughshinney and SW6, Hoars Rock Skerries, both discharge to the Irish Sea. This has been designated High status by the ERBD Management Plan and the test results of the coastal waters by the EPA and the Marine Institute as presented in Section 2.3 of this AER indicates that the discharge from the agglomeration is not affecting the ambient waters. However, Bathing water quality testing on Skerries north beach showed some breaches of the Blue Flag guideline figures during the season, and on Loughshinney beach there were breaches of the Blue Flag guidelines and of the mandatory limits. The secondary discharges may be contributing to these Bathing Water Quality failures. The septic tank at Killalane discharges to groundwater. There has been no monitoring of groundwater in the area. The discharge is in the Mill Stream catchment which is rated at Good status in the ERBD Management Plan which indicates that the discharge is not affecting the surface waters in the area. d) Storm Water Overflows. The number and volume of discharges from the SWOs was estimated for the Licence application using the local knowledge of the area inspector and the area Engineer. It was intended that flow monitors would be used in 2010 to determine the actual flows and number of discharges and whether the SWOs complied with the definition of a SWO as set out in the publication of the DoEHLG: Procedures and Criteria in Relation to SWOs. However, inadequate resources prevented this from been carried out. Fingal County Council propose to carry out the flow monitoring in 2012 instead and will report fully in the 2013 AER. e) Emergency overflows. The emergency overflows are associated with pumping stations in the agglomeration. The P.S. s are all linked to the Regional telemetry system and the number of overflows can be quantified from this. The volume of overflows is harder to estimate. A trial was arranged with one PS in the County to attempt to measure the volume of overflow, due to inadequate resources, the trial was not carried out. Fingal County Council proposes to implement monitoring of frequency and volume of emergency overflows in 2012 instead and will report fully in the 2013 AER.

33 Programme of Improvements: WWTP: The WWTP is well within its capacity and is achieving compliance with its Environmental Limit Values. The testing of the coastal waters by the EPA and the Marne Institute indicate that the discharge is not posing an environmental risk to the receiving waters. An assessment of the impact of the discharge on the microbiological quality (including viruses) of the shellfish in the adjacent designated shellfish waters has been carried out and a report submitted to the EPA in June The assessment reveals no major deleterious affect on the designated shellfish. There are no plans for improvements to the WWTP within the near future. Secondary Discharges: Loughshinney: (i) Under Phase III of the Balbriggan Skerries Wastewater Treatment Scheme, it is proposed that the existing septic tank and discharge at Loughshinney will be removed. The wastewater from this part of the agglomeration will be diverted to a Pumping Station adjacent to the beach in Loughshinney and pumped to Skerries. An upgraded and expanded Rush Road P.S. will pump the wastewater to the existing WWTP at Barnageeragh in Skerries. The detailed design of the proposed Loughshinney P.S. encountered a problem with the pumping head. A second P.S. is therefore proposed at an intermediate point and the process of obtaining the necessary planning permission for the second P.S. has been completed. However, Phase III of the Balbriggan Skerries Wastewater Treatment Scheme has not been included in the WSIP for 2010 to Fingal County Council has written to the DoEHLG requesting that this decision be reversed, but to date there has been no response. This secondary discharge will therefore continue until at least (ii) The emissions of ph, cbod, COD, SS and Ammonia will be affected by the implementation of the improvement. (iii) The cost of the overall Balbriggan Skerries Wastewater Treatment Scheme Phase III is estimated at 20 million. The cost of the portion of Phase III dealing with Loughshinney is estimated at 1.5m. Funding will be 40% through the DoEHLG s Water Services Investment Programme (WSIP) and 60% from Fingal County Council s own resources, from development levies and water pricing. (iv) The coastal waters into which this secondary discharge discharges has been rated as High status under the ERBD Management Plan. There is no anticipated change

34 to the rating due to the discharge ceasing. The Bathing Water Quality of the adjacent designated beach at Loughshinney is expected to improve. However, there are other pressures which will still affect the quality eg the harbour, the horse riding and dogwalking on the beach etc. Killalane: (i) Under Phase III of the Balbriggan Skerries Wastewater Treatment Scheme, it is proposed that the existing septic tank and percolation area at Killalane will be removed. The wastewater from this part of the agglomeration will be captured by a Pumping Station and pumped to Skerries, where it will be treated at the existing WWTP at Barnageeragh. However, Phase III of the Balbriggan Skerries Wastewater Treatment Scheme has not been included in the WSIP for 2010 to This secondary discharge will therefore continue until at least (ii) The emissions of cbod, COD, SS and Ammonia will be affected by the implementation of the improvement. (iii) The cost of the overall Balbriggan Skerries Wastewater Treatment Scheme Phase III is estimated at 20 million. The cost of the portion of Phase III dealing with Killalane is estimated at 0.6m. Funding will be 40% through the DoEHLG s Water Services Investment Programme (WSIP) and 60% from Fingal County Council s own resources, from development levies and water pricing. (iv) There has been no monitoring of groundwater in the area. The discharge is in the Mill Stream catchment which is rated at Good status in the ERBD Management Plan which indicates that the discharge is not affecting the surface waters in the area. The groundwater body in the area is also rated as Good in the ERBD Management Plan which indicates that the discharge is not affecting the groundwaters in the area. There is therefore likely to be no discernible improvement in the receiving waters. Hoars Rock, SW6 (i) Kellys Bay housing estate is on the northern outskirts of Skerries. The wastewater flows to a P.S. where it is pumped southwards into the head of the Skerries gravity system. This causes overflows during rainfall events from SW 6, an overflow constructed in Hoars Rock to alleviate flooding in houses and gardens. Originally, Kellys Bay P.S. was designed to pump directly to the treatment plant via its own dedicated rising main. However, the houses were occupied before the treatment plant was built, so a temporary solution was arrived at as above, pumping into the gravity system. The dedicated rising main was only partially laid and was never completed by the developers. To alleviate the overflows in SW6, Fingal County Council proposes to complete part of the rising main and connect it to the existing rising main from Rush Rd P.S. to the treatment plant. New pumps will be installed into the Kellys Bay P.S.

35 Fingal County Council s Direct Labour crew completed the rising main and made the connection in Mar Pressure monitoring was then carried out on the existing Rush Road rising main to aid in the design of the new pumps for Kellys Bay P.S. However a delay was encountered in the design and procurement of the pumps, and the pumps have not been delivered as of Feb The date for completion of this work is now Q (ii) The emissions of cbod, COD, SS and Ammonia from SW6 will be affected by the implementation of the improvement. (iii) The cost of the works to connect Kellys Bay P.S. to Barnageeragh WWTP is estimated at 300,000. At present, the works are being funded through Revenue, but Water Pricing and Development Levies will also be used. (iv) The coastal waters into which this secondary discharge discharges has been rated as High status under the ERBD Management Plan. There is no anticipated change to the rating due to the discharge ceasing. The Bathing Water Quality of the adjacent non-designated beach at Skerries North beach is expected to improve. However, there are other pressures which will still affect the quality eg the harbour, dogwalking on the beach etc. Storm Water Overflows and Emergency Overflows. As discussed in the assessment above, it was intended to determine whether the SWOs complied with the definition of a SWO as set out in the publication of the DoEHLG: Procedures and Criteria in Relation to SWOs, and the effectiveness of the emergency overflows, during However, inadequate resources prevented this from being carried out during 2010 or Funds have been set aside in 2012 to have the assessments carried out by private contractors. Fingal County Council will report fully in the 2013 AER. The waste water works: All items under Schedule C: Specified Improvement Programme of this licence have been discussed above.

36 Appendix 3 Report on Assessment of Impact on Shellfish Waters

37 Balbriggan Skerries Agglomeration Assessment of Impact on Shellfish Waters Waste Water Discharge Licence No. D Fingal County Council Apr 2011

38 Introduction: The Waste Water Discharge (Authorisation) Regulations 2007 (S.I. No. 684 of 2007) were introduced in Oct 2007 for the purpose of preventing and reducing the pollution of waters by waste water discharges. A Waste Water Discharge Licence, Licence Register No. D , was issued by the EPA to Fingal County Council on the 22 nd Oct 2009 for the Balbriggan/Skerries Agglomeration. Conditions 5.6 and 5.7 of the Licence are set out below: 5.6 The licensee shall carry out an assessment of the impact of the discharge(s) from the waste water works on the microbiological quality (including viruses) of the shellfish in the adjacent designated shellfish waters, in consultation with the Sea Fisheries Protection Authority, the Marine Institute and Bord Iascaigh Mhara. The assessment shall be submitted to the Agency within eighteen months of the date of grant of the licence. 5.7 Where the assessment outlined in Condition 5.6 indicates that the discharge(s) are having a deleterious microbiological (including viruses) effect on the quality of shellfish in the adjacent designated shellfish waters, the licensee shall propose appropriate measures, which shall be implemented within a timeframe to be agreed by the Agency. This Report details the assessment carried out by Fingal County Council on the impact of the discharge from the Balbriggan Skerries agglomeration on the designated Balbriggan Skerries Shellfish Waters.

39 Balbriggan Skerries Shellfish Waters: The Shellfish Directive (2006/113/EC) is implemented in Ireland by the European Communities (Quality of Shellfish Waters) Regulations 2006 (SI No 268 of 2006) as amended by the European Communities (Quality of Shellfish Waters) (Amendment) Regulation 2009, SI 55 of The aim of the Shellfish Waters Directive is to protect or improve shellfish waters in order to support shellfish life and growth. It is designed to protect the aquatic habitat of bivalve and gastropod molluscs, which include oysters, mussels, cockles, scallops and clams. The Directive requires Member States to designate waters that need protection in order to support shellfish life and growth. The designated Balbriggan/Skerries Shellfish Area is shown on the map on the following page. The protected species are razor clams. The legislative standard for shellfish is set out below. This table is taken from the Code of Practice for the Microbiological Monitoring of Bivalve Mollusc Production Areas May Table 1.1 Criteria for the classification of bivalve mollusc harvesting areas under Regulation (EC) No 854/2004, Regulation (EC) 853/2004 and Regulation (EC) 2073/2005. Classification A B C Prohibited Standard per 100g of LBM flesh and intra-valvular fluid <230 E. coli per100g of flesh and intra-valvular liquid 1 LBMs must not exceed the limits of a five-tube, three dilution Most Probable Number (MPN) test of 4,600 E. coli per 100 g of flesh and intra-valvular liquid 2 LBMs must not exceed the limits of a five-tube, three dilution MPN test of 46,000 E. coli per 100 g of flesh and intra-valvular liquid. >46,000 E. coli per 100g of flesh and intra-valvular fluid 3 Treatment required None Purification, relaying in class A area or cooking by an approved method Relaying for a long period or cooking by an approved method Harvesting not permitted Notes: 1. By cross-reference from Regulation (EC) No 854/2004, via Regulation (EC) No 853/2004, to Regulation (EC) 2073/2005. Areas for which the limit of 230 E coli per 100g are not exceeded in 90% of samples shall continue to be classified as Class A. 2. By way of derogation from Regulation (EC) No 854/2004, the competent authority may continue to classify as being of Class B areas for which the relevant limits of 4,600 E. coli per 100g are not exceeded in 90% of samples. 3. This level is not specifically given in the Regulation but does not comply with classes A, B or C. The current Classification for the Balbriggan/Skerries Shellfish Area is A. Shellfish from A classification areas can be taken for direct human consumption without further processing.

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41 Balbriggan Skerries Agglomeration: The Balbriggan Skerries Agglomeration is adjacent to the designated Balbriggan/Skerries Shellfish Waters. It consists of the two towns of Skerries and Balbriggan and their respective hinterlands. Further areas about Balbriggan and Loughshinney are due to be incorporated into the agglomeration when funding is available from the DoEHLG for the Balbriggan Skerries Waste Water Treatment Scheme Phase III. The Balbriggan/Skerries agglomeration is served by a Waste Water Treatment Plant (WWTP) at Barnageeragh on the northern outskirts of Skerries. It is built to cater for 70,000p.e. The WWTP is a CASS (Continuous Activated Sludge System) plant using four Sequential Batch Reactors (SBRs) to treat the influent. It consists of an inlet works of inlet screening and grit removal. The screenings and grit are washed and disposed of offsite. The screened influent flows by gravity to the SBRs which have a cyclic routine of filling, aerating, settling and decanting. The final effluent is discharged by gravity to the Irish Sea by a 2km outfall pipe with diffusers at the discharge point. The total quantity discharged is approx 7,600 cubic metres per day at present. Tertiary treatment in the form of Ultra Violet (UV) sterilisation of the effluent is in place. The effluent must meet the criteria laid down in the Urban Waste Water Treatment Regulations 2001 (SI 254 of 2001) of 25mg/l BOD 5, 125mg/l COD and 35mg/l of Suspended Solids, as well as meeting the faecal coliform target of less than 1,000cfu/100ml. The results of testing on the effluent from the Barnageeragh WWTP for the period 2009 to date are shown in Appendix A. These results indicate that, except for one period in Dec 2010 where an extended period of temperatures well below freezing caused the plant to malfunction, the plant is performing well and meeting the effluent requirements. The results from the testing for faecal coliforms indicate that the average was 42 cfu/100ml for faecal coliforms throughout 2010, except for one result on Dec 8 th when the plant malfunctioned during the very severe freezing conditions that occurred then.

42 Process of Assessment: The Licence for the Balbriggan Skerries Agglomeration was issued on 22 nd Oct Conditions 5.6 and 5.7 were noted and discussed internally. The views of the Marine Institute, Bord Iascaigh Mhara and the Sea-Fisheries Protection Authority were canvassed and a meeting with representatives of these three agencies was held in late May A method for assessing the impact of the discharge from the waste water works on the microbiological quality of the shellfish was discussed. The need for such an assessment was questioned as the shellfish from the area were Classified A. The meeting was unable to suggest a method for assessing the impact of the discharge from Barnageeragh. The EPA was approached for advice. The advice received was to look at what other Local Authorities were doing, especially Mayo County Council at the Newport WWTP. However the work being carried out by Mayo did not appear to be relevant to the situation in the Balbriggan Skerries agglomeration. In the meantime, results of testing were obtained from the Marine Institute, the SFPA and from the local fishing business, Rockabill shellfish Ltd, were obtained, and are contained in Appendices II and III. These results confirm the status of the shellfish as being Class A. Further discussions were held with the Marine Institute and the SFPA and the eventually the method for making the assessment was decided to be the use of the Noro virus as a marker. The Noro virus or winter vomiting bug genogroup GI and GII is a human virus and its presence would be indicative of sewage contamination. The testing on the samples was to be for Escherichia coli, FRNA bacteriaphage and Norovirus GI and GII genogroup. It was decided that 5 rounds of sampling would be taken. On each round, samples of the raw influent and the post-uv would be taken from the composite samplers at the WWTP and sent to the Marine Institute laboratory in Oranmore, Co Galway. At the same time, samples of razor clams from the designated shellfish areas would be obtained from the local fishermen and sent to the same place. Samples of the influent and effluent were taken at two weekly intervals between February and April However it was discovered that the fishermen when they captured the razor clams put them in buckets of fresh seawater, which was felt might compromise the results by the testing laboratory. Furthermore, the razor clams could only be obtained from the factory, 24 hours or more after capture. Again it was felt that this would impact on the validity of the test results. The preferred sampling method was for the fishermen to bag a sample of the razor clams after capture, note the capture position with SatNav and hand the sample over at the quayside. This proved impossible to arrange. Eventually through the good offices of the SFPA a sample of razor clams from the Skerries Shellfish Area was obtained. The location is plotted as point A on the accompanying drawing, Fig 1, shown below.

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