dunmore east agglomeration · 2014. 12. 16. · dunmore east agglomeration annual environmental...

Dunmore East Agglomeration

WWDL Register Number: D0170-01

Annual Environmental Report for 2012

2

Document Control Sheet:


Annual Environmental Report 2012

Waterford County Council

Water Services

Civic Offices

Dungarvan

Co. Waterford.

Issued: Water Services Section

Waterford County Council

Date:

16th September 2013

Originator:

D. Whelan E.E

Final Approver:

P. Daly A/DoS

Revision 0 Description: Final Draft

Date: 26/09/2013

3

Table of Contents

Executive Summary: ................................................................................................................................ 6

1. Introduction .................................................................................................................................... 7

1.1 Licence Register Number: ....................................................................................................... 7

1.2 Name: ...................................................................................................................................... 7

1.3 Site Location: ........................................................................................................................... 7

1.4 Description of activities at the site: ........................................................................................ 7

1.5 Company Environmental Policy (where available): ................................................................ 8

1.6 Company Organisational Chart for Environmental Management: ......................................... 8

2. Summary Information ................................................................................................................... 10

2.1 Monthly Influent Monitoring: ............................................................................................... 10

2.2 Discharges from the Agglomeration: .................................................................................... 11

2.3 Treatment Efficiency Report: ................................................................................................ 12

2.4 Treatment Capacity Report: .................................................................................................. 12

2.5 Ambient Monitoring Report: ................................................................................................ 13

2.6 Data Collection and Reporting Requirements under the Urban Waste Water Treatment

Directive: ........................................................................................................................................... 15

2.7 Pollutant Release and Transfer Register (PTRR) – Report for 2012: ..................................... 15

2.8 Pollutant Release and Transfer Register (PTRR) – Report for 2013: ..................................... 15

3. Operational Reports Summary ..................................................................................................... 16

3.1 Complaints Summary: ........................................................................................................... 16

3.2 Reported Incidents Summary: .............................................................................................. 17

4. Infrastructural Assessments and Programme of Improvements .................................................. 18

4.1 Storm water overflow identification and inspection report: ................................................ 18

4.2 Report on progress made and proposals being developed to meet the improvement

programme requirements: ............................................................................................................... 20

4.2.1 Summary of Improvement Programme: .............................................................................. 20

4.2.2 Update of Improvement Programme Report: ..................................................................... 21

4.2.2.1 Schedule C of the licence - C.1 Improvement Programme for Primary Discharge ........... 21

4.2.2.2 Schedule C of the licence - C.2 Improvement Programme for Secondary Discharge ....... 22

4.2.2.3 Schedule C of the licence - C.3 Improvement Programme for Storm Water Overflows .. 22

4.2.2.4 Schedule A of the licence - A.3 Discharges to be discontinued. ....................................... 23

4.2.3 Summary Report Tables: ...................................................................................................... 24

4

5. Environmental Liability and Financial Provisions .......................................................................... 28

5.1 Statement of Measures: ....................................................................................................... 28

5.2 Environmental Liabilities Risk Assessment: .......................................................................... 28

6. Licence Specific Reports ................................................................................................................ 29

6.1 Priority Substances Assessment: .......................................................................................... 29

6.2 Drinking Water Abstraction Point Risk Assessment: ............................................................ 29

6.3 Shellfish Impact Assessment Report: .................................................................................... 29

6.4 Toxicity / Leachate Management: ........................................................................................ 30

6.5 Toxicity of the Final Effluent Report: .................................................................................... 30

6.6 Pearl Mussel Measures Report: ............................................................................................ 30

6.7 Habitats Impact Assessment Report: .................................................................................... 30

7. Certification and Sign Off .............................................................................................................. 31

8. Appendices .................................................................................................................................... 33

Appendix A: EPA Audit: ..................................................................................................................... 33

A.1 EPA Site Audit 11th

December 2012: .......................................................................................... 33

Appendix B: PRTR Data ..................................................................................................................... 34

Appendix C: WCC Bathing Water Quality Results: Dunmore East Strand (with assessment) ....... 41

Appendix D: Responses to the Agency’s Assessment of the 2011 AER. ........................................ 42

D.1 Ambient Monitoring Data Summary: ......................................................................................... 42

D.2 Complaints Summary: ................................................................................................................ 43

D.3 Treatment Capacity Report: ....................................................................................................... 43

D.4 Improvement Programme Progress: .......................................................................................... 43

D.5 License Specific Reports - Priority Substances Investigation: ..................................................... 43

D.6 Assessment of Licence: ............................................................................................................... 43

Appendix E: Priority Substances Screening Report ....................................................................... 44

Appendix F: Environmental Liability Risk Assessment .................................................................. 51

Content ................................................................................................................................................. 53

Introduction ............................................................................................................................................ 1

General ................................................................................................................................................ 1

Background ......................................................................................................................................... 1

Environmental Sensitivity ....................................................................................................................... 3

Environmental Sensitivity of Receiving Water .................................................................................... 3

Groundwater Protection ..................................................................................................................... 3

Protected Ecological Sites and Species ............................................................................................... 3

5

Human Health ..................................................................................................................................... 4

Risk Assessment ...................................................................................................................................... 6

Risk Prevention/ Mitigation .................................................................................................................. 10

Statement of Measures ........................................................................................................................ 11

Financial Provisions ............................................................................................................................... 14

Estimation of Remediation Costs ...................................................................................................... 14

Details of Financial Provision/ Insurance .......................................................................................... 17

6

Executive Summary:

The report relates to the Dunmore East Agglomeration which is subject to Discharge Licence No.

D00170-01 as issued by the EPA on the 8th

February 2011. This Annual Environmental Report is

prepared in accordance with EPA guidance documents to cover the “reporting year”, 1st

January

2012 to 31st December 2012.

Dunmore East is served by a sewerage scheme that was most recently upgraded in the 1970’s and is

a combined system. Wastewater gravitates from three catchments to the Main Harbour from where

it outfalls untreated to the Suir Estuary/Waterford Harbour via emergency storm water overflows, or

via two pumping stations to a single outfall point at Black Knob, which is the designated Primary

Discharge Point, SW1. [SW1 is located at 269187E, 099868N].

As a popular seaside community, there is a considerable increase in population during the summer

season. The annual average population equivalent for the agglomeration is estimated as, 4,348.

The northern and western catchments serve the Waterford Road, Killea, Nymphall and the Lower

Village and flows gravitate to the Strand Pump Station adjacent to the Public Toilets. They are then

pumped from here to the Main Harbour prior to discharge via SW1. There is a storm overflow

associated with the Strand Pump Station which discharges to the Main Strand at SW3 [268875E,

100689N].

The central catchment serves the southern part of the main village, the Dock and the Pier and the

wastewater gravitates to the Dock Pumping Station from where it is pumped to the Harbour prior to

discharge to Waterford Harbour via SW1. There is an emergency overflow from this pump station to

the harbour.

The southern catchment serves the southern half of the village which is located on high ground and

includes Coxtown, Convent Avenue and part of the Circular Road. The wastewater from this

catchment flows by gravity directly to the Main Harbour before discharging via SW1. There is a

stormwater detention tank which overflows to Waterford Estuary just east of the Pier at SW8

[269162E, 099892N].

A major waste water improvement programme is planned for Dunmore East agglomeration, initially

a new collection system will be built (works commenced in mid 2013), and a new WWTP will provide

secondary treatment. The entire upgrade works are scheduled to be completed by the end of 2015.

The monitoring and analysis carried out during 2012 indicates that the agglomeration is not having

any significant deleterious effect on the receiving waters at present, but the programme of

improvement works must be advanced to ensure that the environmental impacts of the wastewater

from the Dunmore East Agglomeration are mitigated as far as possible to protect and improve the

water quality in the receiving waters.

7

1. Introduction

1.1 Licence Register Number:

D0170-01

1.2 Name:


1.3 Site Location:

Dunmore East, Co. Waterford

1.4 Description of activities at the site:

The Dunmore East Agglomeration currently has no secondary treatment of wastewater. There are

three catchments in the village that all ultimately discharge to the Suir Estuary through the Primary

Discharge Point (SW1) at Blackknob, just east of the Main Harbour. There are also four secondary

discharge points in the agglomeration that discharge to the sea in addition to the Primary Discharge

Point. These are located at the Dock (SW2), the Main Strand (SW9), Oonagh (SW6) and the Main

Harbour (SW8). Some other secondary discharges in the agglomeration also discharge through the

Main Strand and Main Harbour overflow points.

The future proposals for the improvement of the Dunmore East Agglomeration’s environmental

performance is the upgrade of the Collection System to separate foul and storm flows as far as

possible, and the construction of a new Wastewater Treatment Plant at Coxtown East with an

associated new marine outfall at Red Head, just south of the Main Harbour. These works are being

advanced as part of the Waterford Grouped Towns & Villages Sewerage Scheme. The Collection

System contract was tendered in December 2011 and commenced works on site in August 2013. The

WWTP will be constructed as part of a single Design, Build & Operate contract for 7 No. WWTPs and

this is due to commence in early 2014.

8

1.5 Company Environmental Policy (where available):

Waterford County Council is committed to environmental protection and improvement as part of its

role in Local Government and its statutory obligations. It does not have a specific environmental

policy as all such policies are included in the Councils Strategic plan, but not in a format suitable for

extract to this document.

1.6 Company Organisational Chart for Environmental Management:

The organisational structure was developed in 2013. Waterford County Council has divided the

Water Services Operations & Maintenance Team into three relevant individual teams namely;

• the Waste Water Team,

• the Pollution Control and River Basin District Team and

• the Drinking Water Quality & Supply Team.

All of the above listed team members have duties in other areas of work under the umbrella of

Water Services Operations & Maintenance.

9

Conor Foley

Senior Executive Engineer

Paul Carroll

Executive Scientist

EWWSS

Water / Wastewater

Water Pollution

Environment / Landfills

WATER

SERVICES

AREA

ENGINEERS

Tom Butler

Technician 1

Michael Maher

EWWSS Plant

Superintendent

Pat Lennon

Water

Conservation

Team

David Whelan EE

West County

David Hanratty EE

East County

6 FULL TIME WATER

SUPPLY CARETAKERS /

3 Full Time Sewerage

Caretakers

7 FULL TIME WATER

SUPPLY CARETAKERS /

3 Full Time Sewerage

Caretakers

Declan Halpin (Tech II)

Sue Cooke (Tech II)

WATER SERVICES STRUCTURE 2013

Eamon Morrissey

WATER FITTER

Reactive / Emergency

Maintenance

Bobby Ross

Tommy Wade

WASTEWATER FITTERS

3 Wastewater

Inspectors

Water East GSS

Tony O’Leary

Water West GSS

Stephen Browne

Michael Quinn DOS

Pat McCarthy SE Operations

Richard Barry Foreman

+ 7 Plant Operators

Colum Flynn EE

Wastewater

Timmy Bourke

S E Tech

WCC Machinery Yard – Fitter Resource

Foreman Plumber

plus two plumbers

3 Water Services

Gangs (x 2 MEN)

Foreman Plumber

plus two plumbers

3 Water Services

Gangs (x 2 MEN)

VisioDocument

Mary Hayes

ASO

PJ Kindregan

A/SE

Capital Projects

Ann-Marie Casey

EE

J Mansfield SEE

Suzanne Gough

ASO

John Leonard EE

Capital Projects Team

Noreen O’Neill

SSO Part-time

10

2. Summary Information

2.1 Monthly Influent Monitoring:

There is no influent monitoring currently available for this licence because there is no influent monitoring

chamber in place. Thus, influent flow monitoring is not possible. The Health & Safety implications involved

in trying to sample from the existing system mean that it is not possible to obtain a representative sample

of influent either, so influent composition has to be estimated.

Influent monitoring will be installed as part of the proposed WWTP, as required in Licence Condition 4.14.

The catchment only has a very small amount of trade effluent located in the harbour itself which relates

to fish processing. Two Section 16 Licences are in place but only one of these premises is currently

operational. The active premises have a licence to discharge 5m³/day with limits of 600mg/l of BOD and

600mg/l of Suspended Solids. This equates to 3kg of BOD per day and 3kg of Suspended Solids per day.

This effluent is almost entirely wash-water from the fish processing. Given that the total flow and BOD

loads per day are 675m³ and 225kg respectively, the trade effluent has no undue effect on the

wastewater to be discharged. Therefore it is reasonable to assume that the overall discharge from the

agglomeration can be considered to be purely domestic-type sewage. As the influent is 100% domestic-

type sewage, it is assumed to have the same properties as domestic sewage. Thus, it is assumed that

there is 60g BOD/person/day and 180 litres/person/day entering the network.

Table 2.1.1 Influent Monitoring Monthly Results

Date cBOD mg/l

COD mg/l

SS mg/l

Total Nitrogen mg/l

Total Phosphorous

mg/l

No. of Samples 0 0 0 0 0

Annual Mean N/A N/A N/A N/A N/A

Annual Max N/A N/A N/A N/A N/A

11

2.2 Discharges from the Agglomeration:

The discharges from the Agglomeration in 2012 are mostly as existing at the time of application for the

licence, as detailed in the licence application and are largely unchanged in character and type.

There has also been a change in the loading on the existing sewerage scheme when compared with the

licence application. Owing to the fact that Dunmore East is a popular tourist destination in summer, the

population equivalent varies during the winter and summer months. A review has been held with the

Consulting Engineers for the proposed Dunmore East WWTP with respect to the population equivalents at

the different times of the year. The winter population equivalent is 3,754 while the summer population

equivalent is 6,111, therefore the annual average population equivalent for agglomeration is estimated as,

4,348.

We do not feel that a Technical Amendment to the licence is required on this matter as the licence type is

for; “Discharges from agglomerations with a population equivalent of 2,001 to 10,000.”

Table 2.2.1

Effluent Monitoring Summary

BOD

(mg/l)

COD

(mg/l)

TSS

(mg/l)

Total

DIN

(mg/l)

Total

ON

(mg/l)

Ammonia

NH3-N

(mg/l)

Comment

WWDL ELV (Schedule A)

25 125 35 35 35 15

N

o d

isch

arg

e m

on

ito

rin

g r

esu

lts

av

ail

ab

le

ELV with Condition 2 Interpretation

included

50 250 52.5 42 42 18

Number of sample results

0 0 0 0 0 0

Number of sample results above

WWDL ELV

N/A N/A N/A N/A N/A N/A

Number of sample results above

ELV with Condition 2 Interpretation

included


Annual Mean (for parameters

where a mean ELV applies)


Overall Compliance (Pass/Fail)


12

2.3 Treatment Efficiency Report:

No treatment facility is in place for the reporting year.

Table 2.3.1

Treatment Efficiency Report

Summary Table

BOD

(kg/day)

COD

(kg/day)

SS

(kg/day)

Total P

(kg/day)

Total N

(kg/day)

Comment

Influent Mass Loading (kg/day) N/A N/A N/A N/A N/A

No

tre

atm

en

t

faci

lity

in

pla

ce

Effluent Mass Loading (kg/day) N/A N/A N/A N/A N/A

% Efficiency

(% reduction of influent load) N/A N/A N/A N/A N/A

2.4 Treatment Capacity Report:

No treatment facility is in place for the reporting year.

Table 2.4.1 Treatment Capacity Report Summary Table

Criteria Value As % terms

Hydraulic Capacity (Design)

(m3/day) N/A N/A

Hydraulic Capacity

(Current Loading)

(m3/day)

N/A N/A

Hydraulic Capacity (Remaining)

(m3/day) N/A N/A

Organic Capacity (Design) PE N/A N/A

Organic Capacity –

Current Loading PE N/A N/A

Organic Capacity – Remaining PE N/A N/A

Will the capacity be exceeded in

the next three years? N/A N/A

2.5 Ambient Monitoring Report:

The Licence requires Ambient Monitoring at five locations in Dunmore East. The first is located at the

Main Strand and is carried out on behalf of Waterford County Council by the Health Services Executive

(HSE) as part of our Bathing Water Monitoring.

The Licence requires 4 samples be taken between mid May and the end of August. The following are the

results of the Bathing Water Monitoring for 2012.

Table 2.5.1

Treatment

Efficiency

Report

Summary Table

Total coli forms Faecal coliforms Faecal streptacocci

Date No./ 100 ml No./ 100 ml No./ 100 ml

23-May-12 44 44 24

19-Jun-12 200 200 2

16-Jul-12 27 27 15

28-Aug-12 138 138 6

The complete set of monitoring results for this location is provided in Appendix C of this report.

Bathing water quality is in compliance with National and European requirements.

The other four specified ambient monitoring point are at;

• aSW1u (E268926, N099516),

• aSW1d (E269208, N099914),

• SR 620 (E270776, N100264) and

• SR650 (E269663, N098392)

The Licence requires 1 sample to be taken annually at each location.

Due to the geographic location of each of these points, the Council have not been able to sample due to

Health and Safety concerns raised by the Council’s Safety Advisor.

14

The locations of these four sampling points are as follows:

Table 2.5.2 Ambient Monitoring Location: H&S Issues

Name Easting Northing H&S Concern

SR620 270773 100264 In open sea, circa 1.5km offshore, requires boat

to sample.

SR650 269663 098392 In open sea, circa 1.5km offshore, requires boat

to sample.

aSW1u 268926 099516 Sloping uneven rocky shore access, unsafe

except during very calm conditions.

aSW1d 269208 099914

Very close to existing outfall. Slippery rocky

shore access, unsafe except during very calm

conditions.

To provide assessment of Ambient Monitoring, Waterford County Council sampled at the proposed

ambient monitoring locations that will become active when the WWTP is commissioned.

Note: Waterford County Council have consulted directly with the EPA with regard to the H&S issues

concerning the licence ambient monitoring points, and the proposal to commence monitoring at the

future locations points.

Table 2.5.3 Ambient Monitoring Location: Future locations currently tested

Name Easting Northing H&S Concern

SW1u 267451 98859 Portally Cove

SW1d 269263 100115 End of Dunmore Pier

Table 2.5.4 Ambient Monitoring Results

Parameter SW1u SW1d Units EQS (Coastal Water Body)

Date 17/12/12 17/12/12 - -

pH 7.50 7.50 Scale Not specified

DO 95.00 96.00 % 120% < 95%ile > 80%

Salinity 33 33 Permille Not specified

BOD <2 <2 Mg/l Not specified

Ammonia <0.01 <0.01 Mg/l Not Specified

DIN 0.013 0.016 Mg/l ≤0.17mg/l High Status

TON <0.1 <0.1 Mg/l Not specified

15

Table 2.5.3 Ambient Monitoring Report Summary Table

Ambient Monitoring Point from

WWDL (or as agreed with EPA)

Irish Grid

Reference

EPA Feature

Coding Tool

code

Does assessment of the ambient

monitoring results indicate that the

discharge is impacting on water quality

Dunmore Strand (SW3d) 268920,

100708

BPBLF3100000

50001 No

Portally Cove (SW1u) 267451,

098859

CW31002

096SR7009 No

End of Dunmore Pier (SW1d) 269263,

100115

CW31002

096SR7010 No

The foregoing ambient monitoring data would appear to show that there is a low impact on the receiving

waters by the current sewerage system with respect to the Surface Water Regulations, 2009.

2.6 Data Collection and Reporting Requirements under the Urban Waste Water

Treatment Directive:

As there is no primary or secondary treatment facility in place in Dunmore East, data collection for the

Urban Waste Water Directive does not currently apply.

2.7 Pollutant Release and Transfer Register (PTRR) – Report for 2012:

A Pollutant Release and Transfer Report (PRTR) has been prepared for 2012. However, owing to the lack

of treatment processes, only preliminary treatment is in place and there is no influent or effluent

monitoring data available. Therefore the PRTR was prepared with only estimates of the pollutants

released and transferred. It was assumed that all releases to air and waters were fugitive as there was no

treatment of the effluent. A nominal figure of 1m³ was used for treated effluent in order to ensure that

the PRTR calculation tool was able to provide an output.

There were no releases to sewers or other wastewater networks nor any releases to lands. There was no

on-site treatment or off-site transfers of wastes.

A copy of the uploaded PRTR report is attached in Appendix B.

2.8 Pollutant Release and Transfer Register (PTRR) – Report for 2013:

There are no new proposals for PRTR reporting in 2013. The proposed WWTP will not be completed in

2013. Note: works have commenced onsite on the new collection system.

16

3. Operational Reports Summary

3.1 Complaints Summary:

Section 6.5 of the licence states that:

“The licensee shall record all complaints of an environmental nature related to the discharge(s) to waters

from the waste water works in accordance with the national environmental complaints procedure. Each

such record shall give details of the date and time of the complaint, the name of the complainant (if

provided), and the nature of the complaint. A record shall also be kept of the response made in the case of

each complaint.”

Table 3.1.1 Complaints Summary Table

Number Date Nature of

Complaint

Cause of Complaint Actions taken to

resolve issue

Status

23/05/2012 “raw sewerage

being pumped into

the harbour at the

stormwall in

Dunmore East at

around 12:00 on

Monday 21st May

2012.

The material referred to was

sand and grit arisings from a

grit collection chamber in

advance of a pumping station.

The photos supplied by the

complainant show a yellow

coloured plume of material in

the sea water, this is the sand

and grit referred to.

WCC

investigated the

matter and

reported back to

the EPA on 29th

May 2012.

Closed

17

3.2 Reported Incidents Summary:

Section 6.1 of the licence states that:

“The licensee, shall notify the Agency by both telephone and facsimile, to the Agency’s headquarters in

Wexford, or to such other Agency office as may be specified by the Agency, as soon as practicable after the

occurrence of any incident (as defined in this licence). The licensee shall include as part of the notification,

date and time of the incident, summary details of the occurrence, and where available, the steps taken to

minimise any discharges.”

No incidents of this type occurred during reporting year.

Table 3.2.1 Summary of Incidents:

Date &

Time

Incident

Description

Cause Corrective

Action

Authorities

Contacted Note 1

Reported to EPA

(Yes/No)

Closed

(Y/N)

None

Number of Incidents in 2012 0

Number of Incidents reported to the EPA via EDEN in 2012 0

Explanation of any discrepancies between the two numbers above

N/A

18

4. Infrastructural Assessments and Programme of Improvements

4.1 Storm water overflow identification and inspection report:

“4.11.1 The licensee shall, prior to the date for submission of the second AER (required under Condition

6.11), carry out an investigation for the identification and assessment of storm water overflows. A report

on the storm water overflows shall be submitted to the Agency as part of the second AER. The assessment

shall include a determination of compliance with the criteria for storm water overflows, as set out in the

DoEHLG ‘Procedures and Criteria in Relation to Storm Water Overflows’, 1995 and any other guidance as

may be specified by the Agency.”

Report:

Existing SW4:

SW8 is a proposed storm water over flow adjacent to the existing SW1.

SW8 will replace SW4 as part of the collection works contract which commenced works in August 2013.

SW8 will be compliant with DoEHLG “Procedures and Criteria in Relation to Storm Water Overflows’, 1995.

The current SW4 does not comply with DoEHLG “Procedures and Criteria in Relation to Storm Water

Overflows’, 1995.

SW8 will be commissioned when the WWTP has been constructed, the WWTP work is currently at Tender

Assessment Stage and is scheduled to commence onsite in early 2014.

Existing SW5:

SW9 is a proposed replacement storm overflow for the existing SW5.

SW9 will be constructed as part of the collection works contract which commenced works in August 2013.



Overflows’, 1995.

SW9 will commissioned when the WWTP has been constructed, the WWTP work is currently at Tender


19

Existing SW7:

SW9 is a proposed replacement storm overflow for the existing SW7.

SW9 will be constructed as part of the collection works contract which commenced works in August 2013.



Overflows’, 1995.

SW9 will commissioned when the WWTP has been constructed, the WWTP work is currently at Tender


Existing SW6:


Overflows’, 1995.

SW6 will be decommissioned when the WWTP has been constructed, the WWTP work is currently at

Tender Assessment Stage and is scheduled to commence onsite in early 2014.

Table 4.1.1 SWO Identification and Inspection Summary Report Table A:

WWDL Name

/ Code for

Storm Water

Overflow

Irish Grid

Reference

Included in

Schedule

A4 of the

WWDL

Compliance

with

DoEHLG

Criteria

No. of

times

activated

in 2012

(No. of

events)

Estimated

/Measure

d data

Total

volume

discharged

in 2012 (m3)

Estimated

/Measured

data

SW4 269162E

099892N Yes

Not

Compliant Not Known Not Known Not Known N/A

SW5 268864E

100758N Yes

Not


SW6 268967E

099639N Yes

Not


SW7 268557E

100377N Yes

Not


Table 4.1.2 SWO Identification and Inspection Summary Report Table B:

Is each SWO identified as non-compliant with DoEHLG Guidance included in the

Programme of Improvements? Yes

The SWO assessment includes the requirements of Schedule A3 & C3 Yes

Have the EPA been advised of any additional SWOs / changes to Schedule C3 and

A4 under Condition 1.7? N/A

20

4.2 Report on progress made and proposals being developed to meet the

improvement programme requirements:

4.2.1 Summary of Improvement Programme:

Licence Condition 5.1: The licensee shall, as a part of the second AER (required under Condition 6.11),

prepare and submit to the Agency a programme of infrastructural improvements to maximise the

effectiveness and efficiency of the waste water works in order to:

a) achieve improvements in the quality of all discharges from the works; The Waterford Grouped

Towns and Villages Sewerage Scheme comprises of the provision of waste water collection and

treatment facilities for seven locations in the County, including Dunmore East.

Onsite works have commenced on the collection system in Dunmore East in August 2013.

With regard to the WWTP, this part of the project is currently at Tender Assessment, with onsite

works set to commence in early 2014, with a construction and commissioning period of

approximately 24 months.

The estimated cost for the WWTP and Collection System is approximately € 7.9million.

b) meet the emission limit values specified in Schedule A: Discharges, of this licence; as outlined in the

foregoing, the WWTP is scheduled to be commissioned in late 2015.

c) give effect to Regulation 2 of the Waste Water Discharge (Authorisation) Regulations 2007 (S.I. No.

684 of 2007); Section 2 of S.I.684 is a statement of the purpose of the said regulations and is quite

general. It is the Council’s opinion that other than the ongoing collection system, and proposed

WWTP works, there are no additional works currently required to give effect to this regulation.

d) Reduce Total Phosphorous loadings in the discharge to the maximum practicable extent; the

proposed WWTP is not specified for nutrient removal, however space for such processes has been

accounted for in the design works. The proposed WWTP is expected to give a 93.5% reduction in

total phosphorous.

e) reduce Total Nitrogen loadings in the discharge to the maximum practicable extent: the proposed

WWTP is not specified for nutrient removal, however space for such processes has been

accounted for in the design works. The proposed WWTP is expected to give a 96.5% reduction in

total nitrogen.

f) meet the obligations of Condition 1.7. As the WWTP is yet to be constructed, the capacity of the

treatment plant cannot be ascertained.

4.2.2 Update of Improvement Programme Report:

Report on progress made and proposals being developed to meet the improvement programme

requirements namely those set out in Schedule C of the licence. This summary report shall provide detail

on all measures proposed and undertaken under Water Services Investment Programme for

agglomeration, including progress reports on infrastructural works and a statement of compliance with

timeframes set out in this licence.

4.2.2.1 Schedule C of the licence - C.1 Improvement Programme for Primary Discharge

Eliminate secondary discharges to the Dunmore East Streams:

Collection works have commenced onsite, this particular element of the project is scheduled to be

complete by 31st August 2014.

Dunmore East waste water treatment plant (WWTP), ancillary works and treated effluent outfall:

Dunmore East WWTP forms part of a Contract for the Design, Build and Operation of a number of

facilities in County Waterford. This contract is currently at Tender Assessment stage, with the winning

contractor expected to commence work in early 2014, the expected contract duration is 24 months.

Dunmore East waste water collection system:

Collection works commenced onsite in August 2013, the scheduled duration of this project is 17 months.

Any other works notified in writing by the Agency:

None notified.

4.2.2.2 Schedule C of the licence - C.2 Improvement Programme for Secondary Discharge

4.2.2.3 Schedule C of the licence - C.3 Improvement Programme for Storm Water Overflows

Specified Improvement:

Upgrading of waste water works, as required to ensure Storm Water Overflows comply with the criteria

outlined in the DoEHLG ‘Procedures and Criteria in relation to Storm Water Overflows, 1995’.

Each of these elements of work form part of the current collection system contract which is currently

under construction.

This work commenced in mid August 2013, and is scheduled to have a duration of 17 months.

• Strand P.S Storm Water Overflow (SW5) discharging at SW9:

This project is currently onsite, the schedule for this element to be completed is 31st

August 2014.

• Harbour P.S Storm Water Overflow (SW4) discharging at SW8:

This project is currently onsite, the schedule for this element to be completed is 31st December

2014.

• Ard na Coille Storm Water Overflow (SW7) discharging at SW9:


August 2014.

• Overflow from storm tank at WWTP discharging at SW1-Future:


December

2014.

• Any other overflows notified in writing by the Agency:

None notified.

4.2.2.4 Schedule A of the licence - A.3 Discharges to be discontinued.

Disconnection of the above discharges form part of the collection system and WWTP works, the collection

system part is currently onsite, the WWTP contract is currently at Tender Assessment stage, the

scheduled completion date for the WWTP is 31st

December 2015.

24

4.2.3 Summary Report Tables:

These summary tables are requested in EPA “Guidance on the Preparation & Submission of the Annual

Environmental Report (AER) for Waste Water Discharge Licences for 2012 Issue No.3, Revision No. 1

14/12/2012.

Table 4.2.3.1 Improvement Programme Summary Report:

Specified

Improvement

Programmes

(under Schedule A

and C of WWDL)

Licence

Schedule

(A or C)

Licence

Completion

Date

Date

Expir

ed?

(N/

NA/

Y)

Status of

Works ((i) Not

Started; (ii) At

planning

stage; (iii)

Work ongoing

on-site; (iv)

Commissionin

g Phase; (v)

Completed;

(vi) Delayed;)

%

Completed

Licensee

Timeframe

for

Completing

the Work

Comments

The following

Discharges to be

discontinued:

SW1, SW3, SW6

A3

SW1

31/12/2013

SW3:

15/05/2013

SW6:

31/07/2013

Y

Work

ongoing

onsite

10%

31st

December

2015

Collection

system

works

onsite.

WWTP

works to

commence

early 2014

Storm water

overflows to be

constructed to

replace existing

overflows

A4

Not specified

in Schedule

A.4

N/A

Work

ongoing

onsite

10%

31st

December

2015

Refer to

Section 4.1

Upgrading of

waste water

works as required

to ensure Storm

Water Overflows

comply with the

criteria outlined

in the DoEHLG

“Procedures and

Criteria in relation

to Storm Water

Overflows, 1995”

C3

SW5 - SW9:

15/05/2013

SW4 - SW8:

31/07/2013

SW7 – SW9:

31/07/2013

WWTP SW1-

Future:

31/07/2013

Y

Work

ongoing

onsite

10%

31st

December

2015

Collection

system

works

onsite.

WWTP

works to

commence

early 2014

25

It should be noted that a complete change in prioritising of, and funding for Water Services projects

Nationally is scheduled from 1st

January 2014.

Table 4.2.2 Sewer Integrity Risk Assessment Tool Improvement Programme Summary Report A:

Element

Risk Assessment

Rating

{ie. Risk Category as

given in “Summary”

worksheet of Sewer

Integrity Tool

Risk

Assessment

Score

Reference to relevant

section of AER

Hydraulic Risk

Assessment Score N/A N/A

NOTE:

As the Dunmore East

Agglomeration sewer

network is currently

being upgraded, it is

not possible to

undertake this

exercise.

Environmental Risk


Structural Risk


Operation &

Maintenance risk

Assessment Score

N/A N/A

Overall Risk Score for

the agglomeration N/A N/A

Table 4.2.3 Sewer Integrity Risk Assessment Tool Improvement Programme Summary Report B:

Are the findings of the Sewer Integrity

Risk Assessment included in the

Improvement Programme?

N.b. each licensee should prioritise the findings of the risk assessment in

the Improvement Programme starting with High Risk aspect.

Replacement of a substantial part of the

Dunmore East collection system is

currently underway.

Yes 10% Complete

(Construction Stage)

Refer to Section

4.2.1 for

Summary of

Improvement

Works

What % of leakage is reported /

estimated? Unknown

What % of misconnections is reported /

estimated? Unknown

Comment

26

Table 4.2.4 Improvement Programme (Works) Summary Table

The Improvement Programme should include an

assessment of the integrity of the existing wastewater

works for the following:

Licensee self- assessment

check to determine whether

all relevant information is

included in the Programme

of Improvements


section of the

Improvement

Programme.

Capacity of the works Yes / No

Refer to Section

4.2.1 for Summary of

Improvement Works

Leaks from the works Yes / No

What % of leakage is reported? %

Misconnections between foul sewer to surface

water drainage Yes / No

What % of misconnections is reported? %

Surface water infiltration Yes / No

Groundwater infiltration Yes / No

Comment

Table 4.2.5 Improvement Programme (Secondary Discharges) Summary Table:

The Improvement Programme should

include an assessment of Secondary

Discharges (e.g. cease discharge /upgrade

to meet requirements) for the following :

Licensee self-

assessment check to

determine whether all

relevant information is

included in the

Programme of

Improvements


section of the

Improvement

Programme. Date for

completion

Receiving water body designation

NO SECONDARY

DISCHARGE

Not Applicable

Downstream abstractions and uses of

water

Water quality objectives for the water

body

Comment

27

Table 4.2.6 Improvement Programme (Storm Water Overflows) Summary Table:

The findings of the SWO Identification and

Inspection Report should be included in the

Improvement Programme (upgrades to meet licence

requirements)

Licensee self- assessment check

to determine whether all relevant

information is included in the

Programme of Improvements


section of the Improvement

Programme.

SW8 Yes Refer to Section 4.2.1

for Summary of

Improvement Works,

and Section 4.2.2.3

Schedule C of the

licence - C.3

Improvement

Programme for Storm

Water Overflows

SW9 Yes

SW1-Future Yes

Table 4.2.7 Improvement Programme (Licence Specific Reports) Summary Table:

The findings of the Licence Specific Reports should

be included in the Improvement Programme (i.e. any

identified upgrades to meet licence requirements)

Licensee self- assessment check

to determine whether all relevant

information is included in the

Programme of Improvements


section of the Improvement

Programme.

Include a row for each licence specific report finding

No Licence Specific Reports

Required

Comment

Table 4.2.8 Improvement Programme (Implementation Plan) Summary Table:

For each improvement identified the Improvement

Programme should include an implementation

plan that :

Licensee self- assessment

check to determine whether all

relevant information is included

in the Programme of

Improvements


section of the

Improvement Programme.

Identifies and describe each improvement

including a timeframe for implementation? (Cond.

5.3) Yes

Refer to 4.2.1

Summary of

Improvement

Programme

Specifies the parameters that will be affected by

the improvement? Yes

Estimates the costs and source of funding? Yes

Estimates the water quality improvement

associated with the Improvement? Yes

Comment -

28

5. Environmental Liability and Financial Provisions

5.1 Statement of Measures:

7.2.1 The licensee shall as part of the AER provide an annual statement as to the measures taken or

adopted in relation to the prevention of environmental damage, and the financial provisions in place in

relation to the underwriting of costs for remedial actions following anticipated events (including closure)

or accidents/incidents, as may be associated with discharges or overflows from the waste water works.

The statement of measures and assessment of risks associated with Dunmore East Agglomeration is

contained in the ELRA attached, as far as it is possible to ascertain these risks.

The collection system works are currently onsite and therefore funding is ring fenced for completion of

this work.

With regard to the WWTP, this project is currently at Tender Assessment Stage with the contract

expected to be awarded before 31st

December. To-date, Local Authorities have been assured by Irish

Water that any projects that are “in-flight” on 31st December 2013 will be completed. Therefore there

should be no obstruction to the WWTP works commencing.

5.2 Environmental Liabilities Risk Assessment:

7.2.2 The licensee shall arrange for the completion, by an independent and appropriately qualified

consultant, of a comprehensive and fully costed Environmental Liabilities Risk Assessment (ELRA) to

address the liabilities from present or planned discharges. A report on this assessment shall be submitted

to the Agency for agreement as part of the second AER (required under Condition 6.12). The ELRA shall be

reviewed as necessary to reflect any significant change to the volume or character of effluent discharged,

and in any case every three years following initial agreement (the results of the review shall be notified as

part of the AER).

The Environmental Liabilities Risk Assessment has been completed and attached in Appendix F of this

report.

6. Licence Specific Reports

Table 6.0.1 Licence Specific Reports Summary Table:

Licence Specific Report Required in 2012 AER or outstanding from previous AER

Included in 2012 AER

Reference to relevant section of AER (e.g. Appendix 2 Section4.

Priority Substances Assessment

No No

Drinking Water Abstraction Point Risk Assessment

No No

Habitats Impact Assessment

No No

Shellfish Impact Assessment

No No

Pearl Mussel Report No No

Toxicity/Leachate Management

No No

Toxicity of Final Effluent Report

No No

6.1 Priority Substances Assessment:

Not required by Licence.

6.2 Drinking Water Abstraction Point Risk Assessment:

Not Required by Licence.

6.3 Shellfish Impact Assessment Report:

Condition 5.6 of the Licence specifically requires an assessment of the impact of the discharges from the

waste water works on the microbial quality of the shellfish in the adjacent designated shellfish waters in

consultation with the relevant authorities. However, this assessment is to be provided within 18 months

of the provision of the WWTP. As the WWTP is not yet constructed, this assessment has not been

provided in this AER and is not likely to be required until the 2018 AER at the earliest.

Schedule D of the Discharge Licence:

30

Results have been received from the Sea Fisheries Protection Authority (SFPA) for monitoring of

microbiological quality in the shellfish in Waterford Harbour for the period January 2010 to January 2013

and these, in conjunction with future monitoring results, will be used as baseline figures for comparison

with the situation post-construction of the WWTP. However, it should be noted that the SFPA’s

monitoring points are upstream of Dunmore East at Cheekpoint, Ballyhack and Arthurstown, although

clams are monitored at Harrylock Bay, Co. Wexford which is approximately 6km north east of Dunmore

East.

All results for Harrylock Bay clams from February 2009 to June 2011 are summarised as follows:

Table 6.3.1 Clams Summary of Results Jun 10-Jan13:

Harry Lock Bay

Previous Classification - A

Seasonality of B/C results

Category Number Max % of Total

Results

Spring

Mar-May

Summer

June-Aug

Autumn

Sept-Nov

Winter

Dec-Feb

A Results 9 82%

B Results 2 700 18% 2

C Results 0 0%

Total

Results 11 N/A N/A

Proposed Classification - B

Source: Sea Fisheries Protection Authority

6.4 Toxicity / Leachate Management:


6.5 Toxicity of the Final Effluent Report:


6.6 Pearl Mussel Measures Report:


6.7 Habitats Impact Assessment Report:


31

7. Certification and Sign Off

Table 7.1 AER Submission Checklist:

Does the AER include an executive summary? Yes

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)?

Yes

Is there a need to advise the EPA for consideration of a technical amendment / review

of the licence? Yes

List reason e.g. additional SWO identified

Extension of Improvement Works Completion Timelines

Yes

Is there a need to request/advise the EPA of any modifications to the existing WWDL?

Refer to Condition 1.7 (changes to works/discharges) & Condition 4 (changes to

monitoring location, frequency etc.)

No

List reason e.g. failure to complete specified works within dates specified in the

licence, changes to monitoring requirements (insert lines as required)

Improvement Works are not complete as scheduled funding for the works were not

forthcoming from the Department of Environment, Community and Local Government.

Yes

Have these processes commenced? (i.e. Request for Technical Amendment / Licence

Review / Change Request) No

Are all outstanding reports and assessments from previous AERs included as an

appendix to this AER? Yes

List outstanding reports (insert lines as required) Refer to Appendix D

of his report

32

As per condition 6.11 of the Discharge Licence D0015-01, I certify that the above reports accurate and

representative:

Prepared By: David Whelan --------------------------------

(Executive Engineer) Signature

Reviewed By: Colum Flynn --------------------------------

(A/ Senior Executive Engineer) Signature

Approved By: Paul Daly --------------------------------

(A/ Director of Services) Signature

33

8. Appendices

Appendix A: EPA Audit:

A.1 EPA Site Audit 11th

December 2012:

The EPA conducted a site audit on the 11th

December 2012, the following issues were raised from the

Audit.

· There was no continuous flow meter in place at the primary

discharge.

· There was no continuous flow recorder in place.

· There was no 24hr composite sampler available for compliance

monitoring at the primary discharge.

· There was no maintenance programme in place for plant and

equipment.

The geometry of the current outfall does not facilitate the installation of a flow meter / recorder /

sampler or such maintenance of this equipment were it in place.

Currently works have commenced on the construction of a new collection system, the WWTP is due to

commence construction in early 2014. When such infrastructure is commissioned, flow recording and

sampling (similar to Dungarvan and Tramore WWTP) will be in place.

Appendix B: PRTR Data

| PRTR# : D0170 | Facility Name : No treatment plant | Filename : Dunmore East

WWTP 2012.xlsx | Return Year : 2012 |

Guidance to completing the PRTR workbook

Version 1.1.15

REFERENCE YEAR 2012

1. FACILITY IDENTIFICATION

Parent Company Name Waterford County Council

Facility Name No treatment plant

PRTR Identification Number D0170

Licence Number D0170-01

Waste or IPPC Classes of Activity

No. class_name

30.4 General

Address 1 Davitts Quay

Address 2 Dungarvan

Address 3 Co. Waterford

Address 4

Waterford

Country Ireland

Coordinates of Location -6.99974 52.1423

River Basin District IESE

NACE Code 3700

Main Economic Activity Sewerage

AER Returns Contact Name Colum Flynn

AER Returns Contact Email Address [email protected]

AER Returns Contact Position Executive Engineer

AER Returns Contact Telephone Number 058-20807

AER Returns Contact Mobile Phone Number 087-2388044

AER Returns Contact Fax Number 058-20883

Production Volume 0.0

Production Volume Units

Number of Installations 0

Number of Operating Hours in Year 0

Number of Employees 1

User Feedback/Comments

Web Address

2. PRTR CLASS ACTIVITIES

Activity Number Activity Name

5(f) Urban waste-water treatment plants

3. SOLVENTS REGULATIONS (S.I. No. 543 of 2002)

Is it applicable?

Have you been granted an exemption ?

If applicable which activity class applies (as per

Schedule 2 of the regulations) ?

Is the reduction scheme compliance route being

used ?

4. WASTE IMPORTED/ACCEPTED ONTO SITE Guidance on waste imported/accepted onto site

Do you import/accept waste onto your site for on-

site treatment (either recovery or disposal

activities) ?

AER Returns Workbook

4.1 RELEASES TO AIR Link to previous years emissions data | PRTR# : D0170 | Facility Name : No treatment plant | Filename : Dunmore East WWTP 2012.xlsx | Return Year : 2012 | 23/09/2013 16:14

8 14 22 22 30 30 6 6 6

SECTION A : SECTOR SPECIFIC PRTR POLLUTANTS

Please enter all quantities in this section in KGs

QUANTITY

No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year

01 Methane (CH4) E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 24158.0 0.0 24158.0

02 Carbon monoxide (CO) E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

03 Carbon dioxide (CO2) E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 167803.0 0.0 167803.0

05 Nitrous oxide (N2O) E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 1.0 0.0 1.0

07 Non-methane volatile organic compounds (NMVOC) E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

08 Nitrogen oxides (NOx/NO2) E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

11 Sulphur oxides (SOx/SO2) E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

* Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button

SECTION B : REMAINING PRTR POLLUTANTS


QUANTITY


0.0 0.0 0.0 0.0


SECTION C : REMAINING POLLUTANT EMISSIONS (As required in your Licence)


QUANTITY

Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year

0.0 0.0 0.0 0.0


Additional Data Requested from Landfill operators

Landfill: No treatment plant

Please enter summary data on the

quantities of methane flared and / or

utilised

additional_pollutant_no T (Total) kg/Year M/C/E Method Code

Designation or

Description

Facility Total Capacity

m3 per hour

Total estimated methane generation (as per

site model) 0.0 N/A

Methane flared 0.0 0.0 (Total Flaring Capacity)

Methane utilised in engine/s 0.0 0.0 (Total Utilising Capacity)

Net methane emission (as reported in

Section A above) 0.0 N/A

RELEASES TO AIR

METHOD

POLLUTANT METHOD

Method Used

For the purposes of the National Inventory on Greenhouse Gases, landfill operators are requested to provide summary data on

landfill gas (Methane) flared or utilised on their facilities to accompany the figures for total methane generated. Operators should

only report their Net methane (CH4) emission to the environment under T(total) KG/yr for Section A: Sector specific PRTR pollutants

above. Please complete the table below:

Method Used

Method Used

RELEASES TO AIR

POLLUTANT METHOD

Method Used

POLLUTANT

RELEASES TO AIRADD NEW ROW DELETE ROW *

ADD NEW ROW DELETE ROW *


ADD EMISSION POINT

ADD EMISSION POINT

ADD EMISSION POINT

4.2 RELEASES TO WATERS Link to previous years emissions data | PRTR# : D0170 | Facility Name : No treatment plant | Filename : D0170_2012.xls | Return Year : 2012 | 23/09/2013 16:45

8 73 81 81 89 119 6 6 6

SECTION A : SECTOR SPECIFIC PRTR POLLUTANTS Data on ambient monitoring of storm/surface w ater or groundw ater, conducted as part of your licence requirements, should NOT be submitted under AER / PRTR


QUANTITY


34 1,2-dichloroethane (EDC) E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

25 Alachlor E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

26 Aldrin E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

61 Anthracene E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.001 0.001 0.0 0.0

17 Arsenic and compounds (as As) E ESTIMATE

EPA UWWTP Tool

Version 5.0 232.223 232.272 0.0 0.049

27 Atrazine E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.01 0.01 0.0 0.0

62 Benzene E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.007 0.0 0.007

91 Benzo(g,h,i)perylene E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.021 0.021 0.0 0.0

63 Brominated diphenylethers (PBDE) E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

18 Cadmium and compounds (as Cd) E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.048 0.059 0.0 0.011

28 Chlordane E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

29 Chlordecone E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

30 Chlorfenvinphos E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

79 Chlorides (as Cl) E ESTIMATE

EPA UWWTP Tool

Version 5.0 37660.776 40342.783 0.0 2682.007

31 Chloro-alkanes, C10-C13 E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.104 0.113 0.0 0.009

32 Chlorpyrifos E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

19 Chromium and compounds (as Cr) E ESTIMATE

EPA UWWTP Tool

Version 5.0 1.415 1.419 0.0 0.004

20 Copper and compounds (as Cu) E ESTIMATE

EPA UWWTP Tool

Version 5.0 22.623 22.857 0.0 0.234

82 Cyanides (as total CN) E ESTIMATE

EPA UWWTP Tool

Version 5.0 1.339 1.455 0.0 0.116

33 DDT E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

70 Di-(2-ethyl hexyl) phthalate (DEHP) E ESTIMATE

EPA UWWTP Tool

Version 5.0 4.453 4.576 0.0 0.123

35 Dichloromethane (DCM) E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.357 0.362 0.0 0.005

36 Dieldrin E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.001 0.001 0.0 0.0

37 Diuron E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

38 Endosulphan E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

39 Endrin E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

65 Ethyl benzene E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.005 0.0 0.005

88 Fluoranthene E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.004 0.005 0.0 0.001

POLLUTANT

Method Used

RELEASES TO WATERS

ADD EMISSION POINT

83 Fluorides (as total F) E ESTIMATE

EPA UWWTP Tool

Version 5.0 148.999 158.164 0.0 9.165

40 Halogenated organic compounds (as AOX) E ESTIMATE

EPA UWWTP Tool

Version 5.0 1.185 1.284 0.0 0.099

41 Heptachlor E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

90 Hexabromobiphenyl E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

42 Hexachlorobenzene (HCB) E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

43 Hexachlorobutadiene (HCBD) E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

89 Isodrin E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

67 Isoproturon E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.007 0.008 0.0 0.001

23 Lead and compounds (as Pb) E ESTIMATE

EPA UWWTP Tool

Version 5.0 4.197 4.644 0.0 0.447

45 Lindane E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

21 Mercury and compounds (as Hg) E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.05 0.054 0.0 0.004

46 Mirex E ESTIMATE

EPA UWWTP Tool

Version 5.0 7.992 7.992 0.0 0.0

68 Naphthalene E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.017 0.023 0.0 0.006

22 Nickel and compounds (as Ni) E ESTIMATE

EPA UWWTP Tool

Version 5.0 2.939 3.088 0.0 0.149

64 Nonylphenol and Nonylphenol ethoxylates (NP/NPEs) E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.045 0.0 0.045

87 Octylphenols and Octylphenol ethoxylates E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

69 Organotin compounds (as total Sn) E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

48 Pentachlorobenzene E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

49 Pentachlorophenol (PCP) E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

71 Phenols (as total C) E ESTIMATE

EPA UWWTP Tool

Version 5.0 20.164 23.511 0.0 3.347

50 Polychlorinated biphenyls (PCBs) E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

72 Polycyclic aromatic hydrocarbons (PAHs) E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.145 0.154 0.0 0.009

51 Simazine E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.007 0.008 0.0 0.001

52 Tetrachloroethylene (PER) E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.065 0.065 0.0 0.0

53 Tetrachloromethane (TCM) E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

73 Toluene E ESTIMATE

EPA UWWTP Tool

Version 5.0 3.627 4.203 0.0 0.576

12 Total nitrogen E ESTIMATE

EPA UWWTP Tool

Version 5.0 17046.544 18018.358 0.0 971.814

76 Total organic carbon (TOC) (as total C or COD/3) E ESTIMATE

EPA UWWTP Tool

Version 5.0 27116.09 27658.369 0.0 542.279

13 Total phosphorus E ESTIMATE

EPA UWWTP Tool

Version 5.0 2384.529 2562.295 0.0 177.766

59 Toxaphene E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

74 Tributyltin and compounds E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

54 Trichlorobenzenes (TCBs)(all isomers) E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

57 Trichloroethylene E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

77 Trifluralin E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

75 Triphenyltin and compounds E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

60 Vinyl chloride E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

78 Xylenes E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.066 0.0 0.066

24 Zinc and compounds (as Zn) E ESTIMATE

EPA UWWTP Tool

Version 5.0 72.993 78.038 0.0 5.045


SECTION B : REMAINING PRTR POLLUTANTS


QUANTITY


0.0 0.0 0.0 0.0

POLLUTANT

Method Used

RELEASES TO WATERS


ADD EMISSION POINT

SECTION C : REMAINING POLLUTANT EMISSIONS (as required in your Licence)


QUANTITY


370 Selenium E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

205 Antimony (as Sb) E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.068 0.088 0.0 0.02

368 Molybdenum E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.058 0.0 0.058

358 Tin E ESTIMATE

EPA UWWTP Tool

Version 5.0 1.151 1.151 0.0 0.0

373 Barium E ESTIMATE

EPA UWWTP Tool

Version 5.0 22.325 23.817 0.0 1.492

374 Boron E ESTIMATE

EPA UWWTP Tool

Version 5.0 36.256 39.94 0.0 3.684

356 Cobalt E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.013 0.0 0.013

386 Vanadium E ESTIMATE

EPA UWWTP Tool

Version 5.0 1.159 1.374 0.0 0.215

388 Dichlobenil E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.001 0.001 0.0 0.0

383 Linuron E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

385 Mecoprop Total E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.022 0.027 0.0 0.005

380 2,4 Dichlorophenol (2,4 D) E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.012 0.013 0.0 0.001

384 MCPA E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.025 0.025 0.0 0.0

382 Glyphosate E ESTIMATE

EPA UWWTP Tool

Version 5.0 4.955 4.971 0.0 0.016

389 Benzo[a]pyrene E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.001 0.001 0.0 0.0

390 Benzo[b]fluoranthene E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.001 0.001 0.0 0.0

391 Benzo[k]fluoranthene E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.001 0.001 0.0 0.0

392 Indeno[1,2,3-c,d]pyrene E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.015 0.015 0.0 0.0

393 Carbon tetrachloride E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

394 2,6-Dichlorobenzamide E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.03 0.032 0.0 0.002

395 Dicofol E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

396 Hexabromocyclodecane (HBCD) E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

397 PFOS E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

238 Ammonia (as N) E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

303 BOD E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

306 COD E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

362 Kjeldahl Nitrogen E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

327 Nitrate (as N) E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

372 Nitrite (as N) E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

332 Ortho-phosphate (as PO4) E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

240 Suspended Solids E ESTIMATE

EPA UWWTP Tool

Version 5.0 0.0 0.0 0.0 0.0

Method Used

POLLUTANT

RELEASES TO WATERS

ADD EMISSION POINT

4.3 RELEASES TO WASTEWATER OR SEWER Link to previous years emissions data | PRTR# : D0170 | Facility Name : No treatment plant | Filename : D0170_2012.xls | Return Year : 2012 | 23/09/2013 16:45

8 8 16 16 6 6 6 6

SECTION A : PRTR POLLUTANTS


QUANTITY


0.0 0.0 0.0 0.0


SECTION B : REMAINING POLLUTANT EMISSIONS (as required in your Licence)


QUANTITY


0.0 0.0 0.0 0.0

OFFSITE TRANSFER OF POLLUTANTS DESTINED FOR WASTE-WATER TREATMENT OR SEWER

OFFSITE TRANSFER OF POLLUTANTS DESTINED FOR WASTE-WATER TREATMENT OR SEWER

Method Used

Method Used

POLLUTANT METHOD

POLLUTANT METHOD


ADD EMISSION POINT

ADD EMISSION POINT

4.4 RELEASES TO LAND Link to previous years emissions data | PRTR# : D0170 | Facility Name : No treatment plant | Filename : D0170_2012.xls | Return Year : 2012 | 23/09/2013 16:45

8 8 16 16 6 6 6 6

SECTION A : PRTR POLLUTANTS


QUANTITY

No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year

0.0 0.0 0.0


SECTION B : REMAINING POLLUTANT EMISSIONS (as required in your Licence)


QUANTITY

Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year

0.0 0.0 0.0

POLLUTANT METHOD

Method Used

RELEASES TO LAND

RELEASES TO LAND

POLLUTANT METHOD

Method Used


ADD EMISSION POINT

ADD EMISSION POINT

5. ONSITE TREATMENT & OFFSITE TRANSFERS OF WASTE | PRTR# : D0170 | Facility Name : No treatment plant | Filename : D0170_2012.xls | Return Year : 2012 | 23/09/2013 16:45

5 5 Please enter all quantities on this sheet in Tonnes 3

Quantity

(Tonnes per

Year)

Haz Waste : Name and

Licence/Permit No of Next

Destination Facility

Non Haz Waste: Name and

Licence/Permit No of

Recover/Disposer

Haz Waste : Address of Next

Destination Facility

Non Haz Waste: Address of

Recover/Disposer

Name and License / Permit No.

and Address of Final Recoverer /

Disposer (HAZARDOUS WASTE

ONLY)

Actual Address of Final

Destination i.e. Final Recovery /

Disposal Site (HAZARDOUS

WASTE ONLY)

Transfer Destination

European Waste

Code Hazardous Q u a n tity T /Y e a r Description of Waste

Waste

Treatment

Operation M/C/E Method Used

Location of

Treatment N a m e a n d L ic e n c e / P e rm it N o . o f R e c o v e re r / D isp o se r / B ro k e r A d d re ss o f R e c o v e re r / D isp o se r / B ro k e r N a me a n d A d d re ss o f F in a l D e stin a tio n i.e . F in a l R e c o v e ry / D isp o sa l S ite (H A Z A R D O U S W A S T E O N L Y ) L ic e n c e / P e rmit N o . o f F in a l D e stin a tio n i.e . F in a l R e c o v e ry / D isp o sa l S ite (H A Z A R D O U S W A S T E O N L Y )

Method Used

Appendix C: WCC Bathing Water Quality Results: Dunmore East Strand (with assessment)

Beach Name: DUNMORE STRAND Contact: Waterford County Council Phone: 058 22000DESIGNATED BEACH

Date 23/05/2012 06/06/2012 19/06/2012 04/07/2012 16/07/2012 30/07/2012 14/08/2012 28/08/2012 12/09/2012

Time 12.45 14.25 14.25 11.40 14.15 11.50 11.30 14.45 10.00

E coli count per 100 mls 44 10 200 47 27 0 33 138 15

Water Quality Category ☺☺☺☺ ☺☺☺☺ � � � � ☺☺☺☺ ☺☺☺☺ ☺☺☺☺ ☺☺☺☺ � � � � ☺☺☺☺

Intestinal Enterococci count per 100 mls 24 5 2 18 1 8 25 6 0

Water Quality Category ☺☺☺☺ ☺☺☺☺ ☺☺☺☺ ☺☺☺☺ ☺☺☺☺ ☺☺☺☺ ☺☺☺☺ ☺☺☺☺ ☺☺☺☺

Bathing water quality What do the results mean?

E coli Intestinal enterococci Latest Water Quality Classification ☺☺☺☺ ☺☺☺☺ Based on 2012 season's results

Below 100 Below 100Good Bathing Water

GOOD ☺☺☺☺� � � � � � � �

Below 2000 Above 100Sufficient quality

��Above 2000

Poor quality

Is allowed a few times during the season

The bathing water is monitored for the

different for the different

types of bacteria shown in the tables.

In the table you can see when the water has

been analysed and how many bacteria were

found. A small number of bacteria tell you

that the water is very clean - a high number

of bacteria tell you that the water may be

polluted and could contain bacteria from

sewage.

42

Appendix D: Responses to the Agency’s Assessment of the 2011 AER.

D.1 Ambient Monitoring Data Summary:

“NOT REPORTED – Faecal Coliforms, E-Coli, Enterococci, Visual Inspection”

The following is extracted from the 2011 AER, as presented in the report there are Health and Safety

issues with the prescribed ambient monitoring points in the licence, and due to these Health and

Safety issues it was not possible to sample / compare the samples to the relevant standard.

“Bathing water quality is in compliance with National and European requirements and also meets the

requirements for Blue Flag status.

The other four ambient monitoring point are at aSW1u (E268926, N099516), aSW1d (E269208,

N099914, SR 620 (E270776, N100264) and SR650 (E269663, N098392) and the Licence requires 1

sample to be taken annually at each location.

The first pair of ambient monitoring points are just offshore at the Main Harbour and under Red

Head. However, safe access to these points is not readily attained and the Council’s Health & Safety

Advisor has serious concerns over the risks associated with our staff taking samples at these points. A

full Risk Assessment is required for the task which will define the mitigation measures required in

order to enable the Council’s staff to take samples at these locations. For the above reason, ambient

monitoring at these locations was not possible in 2011. It is hoped that once the risk assessment is

completed and mitigation measures agreed, the Council will be in a position to undertake the

sampling in 2012.

The other pair of ambient monitoring points are further out into Waterford Harbour and have

extremely high risks to health and safety associated with sampling at these points. A full Risk

Assessment is also being prepared for these and the Council will endeavour to put mitigations in

place to allow such sampling to be done. The Council may have to outsource the sampling at these

monitoring points.

Once the Risk Assessments are complete, the Council may request a review/technical amendment to

the ambient monitoring required in the licence.

Since it was not possible to carry out the ambient monitoring at the designated locations in Dunmore

East, it is not possible to fully comment on the impact of the discharges on the receiving water in

terms of the relevant EQS standards. The impact is largely unchanged from previous years as there

have been no recent significant changes to the discharges from the agglomeration. However, in order

to minimise the impacts on the receiving waters, a new Collection System and WWTP are required to

be constructed. These works will be provided under the relevant contracts in the Waterford Grouped

Towns & Villages Sewerage Scheme.”

43

D.2 Complaints Summary:

“Number of Complaints - Not Sumarised”

“Section 2.4 Complaints summary” of 2011 AER adequately details and summarises the complaints

for the reporting year.

D.3 Treatment Capacity Report:

“What is the remaining Hydraulic capacity – Not Reported”

“What is the remaining Organic capacity – Not Reported”

There is no hydraulic or organic capacity remaining in the system.

D.4 Improvement Programme Progress:

“If no, what is the scheduled completion date? – End 2012”

These timelines have been extended, work is currently onsite on the collection system. Waterford

County Council may need to apply for a Technical Amendment.

D.5 License Specific Reports - Priority Substances Investigation:

“No Interpretation of results reported on”

Refer to Appendix E of this report

D.6 Assessment of Licence:

“IP dates being surpassed”

These timelines have been extended, work is currently onsite on the collection system. Waterford

County Council may need to apply for a Technical Amendment.

44

Appendix E: Priority Substances Screening Report

Dunmore East

Agglomeration

PRIORITY SUBSTANCES SCREENING

REPORT

Licence Register No. D0170-01

45

Introduction:

As part of the WWDA Licence for the Dunmore East Agglomeration, Schedule B.1 of the Licence

requires that screening for Priority Substances in the discharges from the agglomeration be

undertaken. This screening is initially carried out using a desktop study in accordance with the

Agency’s guidance documents ‘Guidance on the Screening for Priority Substances for Waste Water

Discharge Licences’. A risk-based Screening Report was carried out on the agglomeration. It is largely

based on a Desktop Study of the discharges to the agglomeration from potential sources of Priority

Substances. It also includes the results of monitoring for Priority Substances that was carried out in

2011.

The Dunmore East Agglomeration is relatively small (4,348 p.e.) with very little

industrial/commercial activity discharging to the sewer network. There are two Section 16 Licences

are in place but only one of these premises is currently operational. The operational premises has a

licence to discharge 5m³/day with limits of 600mg/l of BOD and 600mg/l of Suspended Solids, this

effluent is almost entirely wash water from fish processing.

The future proposals for the improvement of the Dunmore East Agglomeration’s environmental

performance is the upgrade of the Collection System to separate foul and storm flows as far as

possible, and the construction of a new Wastewater Treatment Plant at Coxtown East with an

associated new marine outfall at Red Head, just south of the Main Harbour. These works are being

advanced as part of the Waterford Grouped Towns & Villages Sewerage Scheme.

The following flowchart describes the process undertaken in preparing the Screening Report.

As noted previously, since the agglomeration size is small (<5,000 p.e.), and considerin

of any sizable commercial activities, it was deemed more appropriate to carry out a desktop study

to ascertain the risk of Priority Substances entering the network and being discharged from the

Primary Discharge Point.

The Desktop Study is outlined in the following pages.

As noted previously, since the agglomeration size is small (<5,000 p.e.), and considerin



outlined in the following pages.

As noted previously, since the agglomeration size is small (<5,000 p.e.), and considering the absence



Step A: Review of All Industrial Inputs

There are no Industrial inputs of any significance to the agglomeration’s network.

Step B: Are Discharges part of a Screening/Monitoring Programme?

None of the discharges in Dunmore East, are part of a screening or monitoring programme for

Priority Substances under the Dangerous Substances Screening Programme.

As part of the application process for the WWDA Licence for Dunmore East, Dangerous Substance

Monitoring was carried out but there was no indication that further monitoring was required based

on the results of that monitoring.

In December 2011, Waterford County Council also carried out monitoring for Dangerous and Priority

Substances as required by Condition 4.10 of the Licence;

A copy of the monitoring results is included at the end of this report.

All substances on the Appendix 1 list of the aforesaid Agency guidance document were monitored

for with the exception of the following substances:

• Benzene

• Carbon tetrachloride

• 1,2-Dichloroethane

• Tetrachloroethylene

• Trichloroethylene

• Trichlorobenzenes

• Trichloromethane

• Ethyl Benzene

• Naphthlene

• Fluoranthene

• Benzo[k]fluoranthene

• Benzo[ghi]perylene

• Indeno[1,2,3-c,d]pyrene

• Benzo[b]fluoranthene

• Benzo[a]pyrene

• Di(2-ethylhexyl)phthalate (DEHP)

• Isodrin

• Dieldrin

• Diuron

• Isoproturon

48

• Glyphosate

• Mecoprop

• 2,4-D

• MCPA

• Linuron

• Pesticides

• Dichlobenil

• 2,6-Dichlorobenzamide

• PCBs

• Antimony

• Molybdenum

• Cobalt

• Vanadium

• Chloride

• TOC

There is a very low risk of any of these substances appearing in the discharges from the Dunmore

East agglomeration based on the fact that there are no known potential sources for these

substances in catchment. If the Agency requires these parameters to be monitored for, it can be

carried out in future years.

Step C: Is there a Downstream Monitoring Programme?

The discharge is to a coastal water body, there is no monitoring programme in place. Giving

consideration to the monitoring undertaken in 2011, and noting that the there is a new collection

and WWTP being constructed, there is currently no indicators to suggest that additional monitoring

is required.

Step D: Assessment of PRTR Data

The PRTR report for Dunmore East is based on estimated results for Priority Substances since there

was no monitoring of these parameters in the discharge from the agglomeration in 2011. These

estimates are from the Agency’s own calculation tool for the PRTR report. Following assessment of

the estimates in the PRTR calculation tool, there are no Priority Substances identified that require

further monitoring.

Review of Desktop Study:

From the foregoing, it appears that there is a very low risk of Priority Substances being discharged

from the Dunmore East Agglomeration to the receiving waters. While the characterisation of the

discharges may be considered to be only Partial, based on the criteria set out in the aforesaid

Agency guidance document, the potential risk is very low and Waterford County Council do not

believe that ongoing monitoring is required. However, should the Agency require it, sampling and

analysis of the discharge for Dangerous Substances can be carried out in 2013 or subsequent years.

Appendix F: Environmental Liability Risk Assessment


Environmental Liability Risk Assessment

Licence Register Number: D0170-0 1

Waterford County Council, Civic Offiices,

Davitts Quay,

Dungarvan,

Co. Waterford.

D0170-01 iiELRA

Chapter Title Page

1. Introduction 1

1.1 General 1

1.2 Background 1

2. Environmental Sensitivity 3

2.1 Environmental Sensitivity of Receiving Water 3

2.2 Groundwater Protection 3

2.3 Protected Ecological Sites and Species 3

2.4 Human Health 4

3. Risk Assessment 6

4. Risk Prevention/ Mitigation 10

5. Statement of Measures 11

6. Financial Provisions 14

6.1 Estimation of Remediation Costs 14

6.2 Details of Financial Provision/ Insurance 17

Content

1

General

This Environmental Liability Risk Assessment relates to the agglomeration of Dunmore East. This report

has been prepared in compliance with Condition 7.2.2 of Licence No. D0170-01 which requires:

“The licensee shall arrange for the completion, by an independent and appropriately qualified consultant, of

a comprehensive and fully costed Environmental Liabilities Risk Assessment (ELRA) to address the

liabilities from present or planned discharges. A report on this assessment shall be submitted to the Agency

for agreement as part of the second AER (required under Condition 6.10). The ELRA shall be reviewed as

necessary to reflect any significant change to the volume or character of effluent discharged, and in any

case every three years following initial agreement (the results of the review shall be notified as part of the

AER).”

This report was prepared in accordance with the Environmental Protection Agency Guidance on the

Preparation & Submission of the Environmental Liability Risk Assessment (ELRA) for The Annual

Environmental Report (AER) for Waste Water Discharge Licences.

Background

This Environmental Liabilities Risk Assessment relates to the Dunmore East Agglomeration.

Dunmore East’s sewerage network was constructed in the early sixties as a combined system. Sewage

from the combined sewers flowed by gravity towards the coast and passed through a disused comminutor

chamber before being discharged, untreated, to Dunmore Bay, part of Waterford Harbour, via a 225mm

diameter marine outfall fitted with a flap valve, located just outside the outer wall of Dunmore East harbour

at Blackknob(SW1). These are designated Coastal Waters.

A secondary wastewater treatment plant, upgraded collected system and new marine outfall are proposed

for Dunmore East under the Waterford Grouped Towns and Villages Sewerage Scheme. The collection

system is due to commence construction in early 2013 with upgraded sewers to replace existing systems

and new separate foul and storm sewers to cater for future developments. The proposed WWTP is to be

provided as part of a design, build, operate contract. The proposed WWTP has a design loading of 8,991

p.e. and will be located at a new site in Coxtown West, c.900m south-west of Dunmore East Harbour. It is

proposed to install a treated effluent outfall to discharge treated effluent via a 300 mm diameter marine

outfall which will extend some 130m beyond the High Water Mark at Red Head. The Licence for the

Dunmore East Agglomeration requires that the Dunmore East Waste Water Treatment Plant, ancillary

works and outfall are to be completed by 31st December 2013.

The upgraded collection system will provide one new pumping station sump at the Main Harbour and

upgrades to the existing pumping stations at the Strand and the Dock. It will also provide a new stormwater

outfall (SW9) which will cater for the stormwater overflows from the Strand Pump Station and the Ard na

Coille Combined Sewer Overflow and discharge them approximately 250m below the High Water Mark. A

new stormwater outfall (SW8) will also be provided at the Harbour to cater for the stormwater overflows

from the new Harbour Pumping Station. All secondary discharges to the existing Horsequarter and Killea

Streams will also be discontinued when the Collection System contract is completed.

Introduction

2

The current flows and loads in the catchment are estimated as follows:

PE Flow (m3/d)

Current (Winter) 3,754 751

Current (Summer) 6,111 1,222

Note: PE estimate from 2010 PE Review Report (MPI) for Waterford Grouped Villages Sewerage Scheme, flow estimated at

0.2m3/pe/d

The wastewater from the agglomeration is currently discharged untreated to a proposed National Heritage

Area. There are two designated Bathing Water Areas in Dunmore East that are located approximately

850m north of the main discharge point (SW1). These Bathing Water Areas are also adjacent to the

existing stormwater overflow from the Strand Pump Station (SW3). The southern boundary of the

Waterford Harbour designated Shellfish Waters is located approximately 1.9km north of SW1. There have

been no observable impacts on these shellfish waters to date.

The EPA Report Urban Waste Water Discharges in Ireland for Population Equivalents Greater than 500

Persons (A Report for the Year 2006 – 2007), and the Focus on Urban Waste Water Discharges in Ireland

Report (2012) reported that the Dunmore East Agglomeration is currently without secondary treatment.

The Update Report on Date Presented in the Focus on Urban Waste Water Discharges in Ireland Report

(2012) was issued in January 2013 with 2010 data taken into account. The status of the Dunmore East

Agglomeration remains unchanged from the original report.

3

The main considerations in relation to the receiving waters for the discharge were identified. Each

environmental attribute is described in detail below, which is the basis of the designated score assigned to

each attribute in Table 1.

Environmental Sensitivity of Receiving Water

Waterford Harbour is not designated as a sensitive area with respect to the Urban Waste Water Treatment

Regulations (S.I. 254 of 2001).

Water quality in Waterford Harbour was unpolluted in terms of Trophic Status in the period 2002-2006 and

was deemed unpolluted also in Water Quality in Ireland 2007- 2009 Report (EPA, 2010).

Waterford Harbour was also deemed to have “Good” status for the Water Framework Directive (River Basin

Management Plan 2009-2015).

Groundwater Protection

Red conglomerates, sandstone and siltstone underlie the area. The groundwater mapping section of

www.gsi.ie was consulted to determine the type and vulnerability of the aquifer.

The draft aquifer maps indicate that the Dunmore East Catchment overlies a Locally Important Aquifer –

bedrock which is moderately productive only in local zones. This aquifer has a high vulnerability

classification.

There were no wells identified in the vicinity of the site (source – www.gsi.ie).

There are no direct discharges to groundwater.

Protected Ecological Sites and Species

Protected Areas in the vicinity of the discharge include:

� Dunmore East Cliffs pNHA Site Code

� Hook Head cSAC Site Code 000764

� River Nore/Barrow cSAC Site Code 002162

The primary discharge point is located just east of the Main Harbour. The discharge is located within the

Dunmore East Cliffs pNHA, c.3.7km west of the Hook Head cSAC and 5km south of the Nore/Barrow

cSAC.

The Dunmore East Cliffs pNHA relate to the Sandstone cliffs surrounding Dunmore East harbour which rise

to 20-30m in places. There are cliffs including an offshore stack at the Black Knob below the Port Authority

building, another shorter section about the waterside road in the harbour and a further series below the

Park and Kelly's Rocks. These cliffs are listed because they are the nesting colony of a large population of

Kittiwake. The colony is very accessible and the birds are accustomed to people and boats in close

proximity.

Environmental Sensitivity

4

Hook Head cSAC is situated on the southern tip of the Hook Pensinsula, on the west Wexford coastline,

stretching from Loftushall in the west round Hook Head and east as far as Fethard Bay. The majority of the

SAC is in the Eastern Celtic Sea. There are three Annex I habitats associated with the SAC. These are (i)

large shallow inlets and bays, (ii) reefs and (iii) vegetated sea cliffs. The rocky coastline is also a breeding

area for two Annex I bird species, namely Chough and Peregrine.

The River Nore/Barrow cSAC is situated to the north of Creadun Head and separates from the Lower River

Suir SAC at Cheekpoint before heading north along both river valleys. The site is a candidate SAC

because of two priority Annex I habitats, alluvial wet woodlands and prettifying springs. There are also a

number of other Annex I habitats within the cSAC, as well as a number of Annex II species.

Human Health

The existing discharge is located approximately 850m to the two designated bathing waters at Dunmore

East, namely Counsellor’s Strand and Main (Lawlor’s) Strand. The bathing waters at Counsellor’s Strand

were reported as ‘Sufficient’ water quality in 2006-2009 but have improved to ‘Good’ in 2010-202. The

bathing waters at the Main Strand varied between ‘Poor’ and ‘Sufficient’ water quality from 2005-2009 but

have improved to ‘Good’ water quality since 2010. While it should be noted that EPA reported in The

Quality of Bathing Water in Ireland, An Overview for the Year 2010 that “The improvement in overall water

quality in 2010 could be at least partly attributed to the drier and sunnier weather during the season, with

rainfall totals near normal and sunshine totals above normal everywhere.”, the bathing water quality for

2005 – 2012 (Table 2.4.1 below), shows that in recent years an improvement in the bathing water quality at

both Dunmore East Beaches.

The legislation governing the quality of bathing waters for the 2012 season is set out in the Quality of

Bathing Waters Regulations, 2008 (S.I. 79 of 2008) and amendments, which transposed the EU Directive

2006/7/EC concerning the quality of bathing water. The two microbiological parameters considered for

compliance purposes are:

� E coli

� Intestinal Enterococci

Table 2.4.1 Bathing Water Quality

Year E coli

Counsellor’s Strand

Enterococci Counsellor’s

Strand

STATUS Counsellor’s

Strand

E coli

Main Strand

Enterococci

Main Strand

STATUS

Main Strand

2012 Good Good Good Good Good Good



2009 Sufficient Sufficient Sufficient Poor Sufficient Poor

2008 Sufficient Good Sufficient Sufficient Good Sufficient

2007 Sufficient Good Sufficient Poor Sufficient Poor

2006 Good Sufficient Sufficient Poor Sufficient Poor

2005 Good Good Good Good Sufficient Sufficient

.

5

Waterford Harbour is a designated Shellfish Water and the southern boundary of the designated area is

approximately 1.9km north of SW1. There have been no observable impacts on these shellfish waters to

date.

There are no water abstractions downstream of the discharge.

Table 1: Environmental Sensitivity Assessment

Environmental Attribute Attribute Score Designated Score Comment

Sensitivity of Receiving Water

Class A (Q5, Q4-5, Q4) 3

Class B (Q3-Q4) 2

Class C (Q3, Q2-3) 1

Class D (Q2, Q1-2, Q1) 0

Designated Coastal & Estuarine Waters 2

Potentially Eutrophic Coastal & Estuarine 1 1 See Section 2.1

Groundwater Protection

Regionally Important Aquifer 2

Locally Important Aquifer 1

Poor Aquifer 0 1 See Section 2.2

Vulnerability Rating - Extreme 3

Vulnerability Rating - High 2

Vulnerability Rating - Moderate 1

Vulnerability Rating - Low 0 2 See Section 2.2

Protected Ecological Sites and Species (Shortest distance from any discharge)

Discharge within or directly bordering a

designated site 2

<1km 1

>1km 0 2 See Section 2.3

Human Health

Discharge within or directly bordering a

designated shellfish area

0 - 5 km 1

>5 km 0 1 See Section 2.4

Designated Bathing Water

WITHIN 0-5 km 1

>5 km 0 1 See Section 2.4

Drinking Water Source

Within 0-10 km 1

>10km 0 0 See Section 2.4

Environmental Sensitivity Score 8

6

The risk identification process involved:

� The identification of potential environmental receptors at the site

� The identification of treatment processes that posed potential hazards to the environmental receptors

� The identification of risks associated with the processes

The potential environmental receptors and site sensitivity were discussed in Section 2.

The Risk Assessment form (Table 2) identifies all risks which are associated with the process. Risk

rankings were applied to each risk for severity and occurrence in accordance with the risk classification

tables (Table 5 and 6). The overall risk score was calculated for each risk i.e. the risk score is a product of

the risk severity and risk occurrence rating.

Risk Assessment

7

Table 2: Risk Assessment Form

Risk

ID

Process Potential Hazards Environmental effect Severity

Rating

Basis of Severity Occurrence

Rating

Basis of

Occurrence

Risk Score

1 Discharge of Sewage Untreated Sewage

Discharge from Harbour

Outfall

Untreated wastewater

discharge to surface

waters in vicinity of

bathing waters,

shellfish waters,

pNHA and cSACs.

3 The impact of the current

discharge from the

Harbour Outfall has not

been shown to have a

major impact on the

environment.

5 Occurs daily as

there are no

wastewater

treatment facilities in

Dunmore East

15

2 Strand Pump Station –

Operation & Maintenance

Breakdown

High Flows to Sump




bathing waters,

shellfish waters,

pNHA and cSACs.

3 Risk of untreated sewage

overflowing from sump to

storm outfall. Volumes

would be low as it only

serves one third of

agglomeration.

5 Level sensors and

alarms. Facility to

bypass the chamber

and overflow to the

outfall. Combined

Sewer System with

history of overflows.

15

3 Strand Pump Station -

Flooding

Flooding Untreated wastewater



bathing waters,

shellfish waters,

pNHA and cSACs.

2 Untreated sewage would

be heavily diluted by flood

waters.

2 Has only rarely

occurred in past.

6

4 Dock Pump Station –


Breakdown

High Flows to Sump




bathing waters,

shellfish waters,

pNHA and cSACs.

2 Risk of untreated sewage

overflowing from sump to

storm outfall. Volumes

would be very low as it

only serves a small part

of the agglomeration.

5 Level sensors and

alarms. Facility to

bypass the chamber

and overflow to the

outfall. Combined

Sewer System with

history of overflows.

10

8

Risk

ID

Process Potential Hazards Environmental effect Severity

Rating

Basis of Severity Occurrence

Rating

Basis of

Occurrence

Risk Score

5 Network Failure - Structural Pipe Failure Groundwater pollution

- subsequent impact

on watercourses/

coastal waters

3 Contamination could be

ongoing for a long period

of time if leak not

detected. Possible need

to pump and treat

groundwater and soil.

2 Regular inspection

and maintenance.

No history of

significant leaks in

network.

9

6 Network Failure –


Flooding Untreated wastewater



bathing waters,

shellfish waters,

pNHA and cSACs.

2 Untreated sewage would

be heavily diluted by flood

waters.

3 Has occurred in the

past.

6

7 General – Pump

Sumps/Storage Tank

Failure

Tank failure Groundwater pollution 2 Risk of untreated

sewage, could be

ongoing a long-time

before being detected.

2 No history of

sump/tank failures in

agglomeration.

4

8 General - oil spill Spill onsite Groundwater pollution

- subsequent impact

on watercourses

1 Very small quantities

utilised onsite.

1 Skilled operatives

onsite.

1

9 General - power failure Power Failure at Pump

Stations




bathing waters,

shellfish waters,

pNHA and cSACs.

3 Outage would likely be

short.

1 No reported problem

with ESB supply.

3

9

Table 0: Risk Matrix

V. High 5

Oc

cu

rre

nc

e High 4

Medium 3

Low 2

3 1

V. Low 1

4 2, 5 6

Trivial Minor Moderate Major Massive

1 2 3 4 5

Severity

These are considered to be high-level risks requiring priority attention. These risks have the potential to be

catastrophic and as such should be addressed quickly.

These are medium-level risks requiring action, but are not as critical as a red coded risk.

Green (light and dark green) – These are lowest-level risks and indicate a need for continuing awareness

and monitoring on a regular basis. Whilst they are currently low or minor risks, some have the potential to

increase to medium or even high-level risks and must therefore be regularly monitored and if cost effective

mitigation can be carried out to reduce the risk even further this should be pursued.

10

The risk matrix indicates that there are no risks in the red zone requiring immediate attention. There are

two risks in the yellow zone which requires priority attention. These are the risks associated with an

untreated discharge from the SW1 and with a breakdown or high flows to the Strand Pump Station. The

construction of the new WWTP is the prevention/mitigation measure for the untreated discharge. This is

due to commence construction in early 2014 with a construction period of 18-24 months. The prevention/

mitigation measure proposed for the Strand Pump Station is for the upgrade of the pump station and to

construct a storm detention tank on the site for storage during storm events. The storm overflow will then

meet the requirements of the DoEHLG’s ‘Procedures and Criteria in relation to Storm Water Overflows,

1995’. The upgrade of the pump station will include the installation of anti-ragging systems which will

minimise the number of blockages/breakdowns in the pumps. A new storm outfall will also discharge any

overflows further out into the harbour and have a reduced impact on the bathing waters. The current status

of these works is that tenders have been sought for the Dunmore East Collection System Contract (which

includes) and Waterford County Council are awaiting approval by the Department to award the contract.

Once awarded, it is expected that the contract will take 18 months to complete.

All other risks are located in the green zone indicating a need for continuing awareness and monitoring on

a regular basis. However, assessment of the green zone risks during the process has indicated that some

of these risks can be reduced through the implementation of mitigation measures. These measures should

be adopted where considered cost-effective to further reduce the risks. As these risks may have the

potential to increase to yellow or red zone risks, risk management measures should be put in place to

manage them at their current levels, or preferably to reduce them further.

Risk Prevention/ Mitigation

11

The measures to be undertaken by Waterford County Council are outlined in Table 4.

Measures proposed within the Dunmore East Agglomeration will result in improved compliance with the

licence conditions and a reduced impact on the protected areas within the Harbour. The other measures

already in place within the Agglomeration are adequate to maintain the discharge at a quality that complies

with the licence conditions and does not significantly impact on the conservation objectives of the protected

areas within the Harbour.

Statement of Measures

12

Table 4: Statement of Measures

Risk

I.D.

Risk

Score Mitigation measure to be taken Outcome Action

Date for

completion

Owner/Contact

Person

1 15

Provision of Secondary Wastewater

Treatment for Dunmore East

Agglomeration.

Reduced impact on

receiving waters and

protected areas.

Progress WGTVSS Contract No. 8 –

WWTP DBO Contract to

construction.

December

2015

Waterford

County Council

2 15

Upgrade of Strand Pump Station and

provision of new outfall.

Reduced risk of blockage

and overspill. Reduced

impact of overflows on

the bathing waters.


Dunmore East Collection System

Contract to construction.

December

2014

Waterford

County Council

3 4 n/a n/a n/a n/a n/a

4 10

Upgrade of Dock Pump Station. Reduced risk of blockage

and overspill. Reduced

impact of overflows on

pNHA.




December

2014

Waterford

County Council

5 6

Upgrade of Collection System and

provision of new outfalls. Continue regular

maintenance and inspection.

Reduced risk of pipe

failure. Reduced impact

on ground and surface

waters.



Contract to construction. Continue

regular maintenance and

inspection.

December

2014 and

ongoing.

Waterford

County Council

6 6


provision of improved storm storage and

new outfalls.

Reduced impact of

overflows on the bathing

waters and pNHA.




December

2014.

Waterford

County Council

7 4


provision of improved storm storage

Continue regular maintenance and

inspection.

Reduced risk of spillages

to receiving waters from

new infrastructure



Contract to construction. Continue

regular maintenance and

inspection.

December

2014 and

ongoing.

Waterford

County Council

13

Risk

I.D.

Risk

Score Mitigation measure to be taken Outcome Action

Date for

completion

Owner/Contact

Person

8 1


inspection. Ensure staff training is up to

date and SOPs are followed.

Reduced risk of spill/leak

onsite


inspection. Ensure staff training is

up to date and SOPs are followed.

ongoing Waterford

County Council

9 3

Put in place emergency procedures for

prolonged power outage. Ensure staff

training is up to date.

Reduced risk from power

outage onsite.

Put in place emergency procedures

for prolonged power outage.

Ensure staff training is up to date.

ongoing Waterford

County Council

14

Estimation of Remediation Costs

The “unknown” environmental liabilities are associated with environmental risks and may or may not occur.

The best case scenario is that none of the environmental risks occur and hence at the end of the

assessment period of 30 years, the additional costs incurred by the County Council are zero. Alternatively,

should a significant number of risks materialise, significant additional costs could be incurred.

The “unknown” environmental liabilities are estimated through the use of a financial model.

Each risk has two characteristics that are derived from the Risk Classification Tables (Tables 5 and 6) that

are used in the financial model:

� The range in cost implications (€A-B) if the risk occurs (Table 5)

� The range in probability (X-Y%) of the risk occurring (Table 6)

Table 5: Risk Classification Table - Severity

Rating

Severity

Category

Description

Cost of Remediation

1 Trivial No damage or negligible change to the

environment. <1,000

2 Minor Minor impact/localised or nuisance 1,000 - 10,000

3 Moderate Moderate damage to environment 10,000 -50,000

4 Major Severe damage to local environment 50,000-100,000

5 Massive Massive damage to a large area, irreversible

in medium term 100,000-500,000

Financial Provisions

15

Table 6: Risk Classification Table - Occurrence

Rating

Occurrence

Category

Description

Likelihood of

Occurrence (%)

1 Very Low Very low chance (0-5%) of hazard occurring

in 30 yr period * 0 – 5%

2 Low Low chance (5-10%) of hazard occurring

in 30 yr period 5 - 10%

3 Medium Medium chance (10-20%) of hazard occurring


4 High High chance (20-50%) of hazard occurring


5 Very High Greater than 50% chance of hazard occurring

in 30 yr period >50%

In order to identify an indicative level of environmental liability associated with the environmental risks for

the purposes of the ELRA, a cost model has been used to generate the expected cumulative cost of the

risks as outlined in Section 4 of this report. The modelling has been undertaken using the median

probability and severity of occurrence of each risk (Table 7).

16

Table 7: Financial Scenario based on Median Probability and Median Severity for each

Risk

Risk

ID

Severity

Rating

Cost Range

(€)

Occurrence

Rating

Likelihood

of

Occurrence

Rating (%)

Median

Probability

(%)

Median

Severity

(€)

Most

Likely

Cost

Scenario

(€)

1 3 10,000 - 50,000 5 >50 75 30,000 22,500.00

2 3 10,000 - 50,000 5 >50 75 30,000 22,500.00

3 2 1,000 - 10,000 2 5 - 10 7.5 5,500 412.50

4 2 1,000 - 10,000 5 >50 75 5,500 412.50

5 3 10,000 - 50,000 2 5 - 10 7.5 30,000 2,250.00

6 2 1,000 - 10,000 3 10 - 20 15 5,500 825.00

7 2 1,000 - 10,000 2 5 - 10 7.5 5,500 412.50

8 1 <1,000 1 0 – 5 2.5 500 12.50

9 3 10,000 -50,000 1 0 – 5 2.5 30,000 750.00

TOTAL 50,075.00

17

Details of Financial Provision/ Insurance

Waterford County Council Water Services is currently reviewing their Environmental Liability Pollution

Insurance cover in the Dunmore East Agglomeration in light of this Environmental Liabilities Risk

Assessment report. It is considered that our current Public Liability Insurance would cover the risk as

any major environmental incident would be of a one-off nature rather than chronic.

dunmore east agglomeration · 2014. 12. 16. · dunmore east agglomeration annual environmental...

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