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Comhuide Choncue b c h gaRman

Wexford County Council County Hall Wexford

TelO53 9176500

Leonard Poole Executive Engineer Sewage Operations Office

100 Years of Community Service Ckad bliain ag tabhairt seirbhise don phobal

/

Administration , Environmental Licensing Programme, Office of Climate, Licensing & Resource Use, Environmental Protection Agency Headquarters, PO Box 3000, Johnstown Castle Estate, Co. Wexford.

Date 5’’ August 2010 DO161-01

RE: Regulation 20(1) for Kilmuckridge Waste Water Discharge Licence Application.

Dear Mr. Higgins,

In reference to letter of the 27th July 2010 regarding required modification of previously submitted L8/08 screening for the Kilmuckridge Agglomeration license application

The information being submitted requires no revisions to be made to the non-technical summary.

Please find attached as requested in hard copy and on CD, revised copy of L8/08 screening.

Please contact the undersigned if anything further is required.

Yours faithfully,

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EPA Export 26-07-2013:19:52:31

Additional Clarification and Appropriate Asgesslnent for Kiimwlaidge and Environs Agglorneration

Wexford County Council

Additional Clarification for Kilmuckridge WWDL Application

Application Number DO161-01

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Additional Clarification and Approprlate Assessment for Kilmuckrldge and Environs Agglomeration

Table of Contents

I n trod uction ....................................................................................................... 3

Appropriate Assessment Screening. in accordance with DEHLG Circular Letter

L8lO8 ................................................................................................................. 4

Project Description ........................................................................................ 4 Summary of plant results ............................................................................... 9 Add it i on a I corn m en ts/cla rificat ion .................................................................. 9 Assessment of Significance ........................................................................ 10

Compliance with Waste Water Treatment Regulations 2001 .......................... 12

Introduction: ................................................................................................. 12 Article 7 (a) .................................................................................................. 12 Article 8 (1). (2). (3) and (4). ........................................................................ 12 Article 9 ....................................................................................................... 12 Article 10 (1) (a) (b) and (2) ......................................................................... 13 With regard to Fifth Schedule Requires ....................................................... 13 Clarification of precise agglomeration P.E ................................................... 14

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Additional Clarification and Appropriate Assessment for Kilinuckridge and Environs Agglomeration

In fro duc tion

This document is additional clarification for the submitted licence application for

Kilmuckridge and Environs - D0161-01, proving additional clarification as

requested under Regulation 18(3)(b) of the Waste Water Discharge

(Authorisation) Regulations 2007.

This document is prepared in accordance with the EPA guidance notes and

Department of Environment Heritage and Local Government Circular Letter

L8/08 with data from the NPWS web Site and the SERBD, in combination with

Wexford County Council data.

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Additional Clarification and Appropriate Assessment for Kilmuckridge and Environs Agglomeration

Appropriate Assessment Screening, in accordance with DEHLG

Circular Letter L8/08

Project Description

A Description of the Waste Water Works and the Activities Carried Out

Therein

The Kilmuckridge Waste Water Treatment Plant is located east of Kilmuckridge

Village on the south bank of the Kilmuckridge Stream into which it discharges

treated effluent. This plant generally treats all the sewage generated within

Kilmuckridge village and its immediate environs and the Kilmuckridge Waste

Water Treatment Plant is operated directly by Wexford County Council.

The Kilmuckridge Waste Water Treatment Plant was originally constructed in the

late 1970’s, with an initial design capacity of 1000 P.E. The Kilmuckridge Waste

Water Treatment Plant was upgraded in the year 2000, doubling the capacity to

2,000 P.E. (@ 6Og/BOD/PE/D), by the addition of a new, monolithic, aeration

tank and a settlement tank (second treatment stream). The treated effluent from

the Waste Water treatment plant is discharged to the Kilmuckridge Stream. The

Kilmuckridge and Environs collection system consists of a partially combined

network, with one pumping station on the mains network.

The sources of Emissions/Nature of emissions from the Waste Water

Works

The Primary and sole discharge point (SWI) of the treated effluent, from

Kilmuckridge Waste Water Treatment Plant is through the outfall pipe, which is

located on the bank of the Kilmuckridge Stream. The only discharge to the

receiving waters is treated effluent from the Kilmuckridge Waste Water

Treatment Plant, which is treated to meet the required standards.

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There are no reports of unusual or abnormal noise and/or odour emissions from

the plant, either from operational personnel, other agencies or the general public.

Quantities of discharge

Details of the quantities of emissions are not available due to technical difficulties

with the flow meter.

Effect of emissions

The average plant results for the past 2 years show that the plant performance is

not within the plant design specification standards of 25mg/l Biochemical Oxygen

Demand (BOD), 125mg/l Chemical Oxygen Demand (COD), 35mg/l Total

Suspended Solids (TSS). The average discharge from the plant is 61mg/l BOD,

1065mg/l COD, and 846mg/l TSS.

The EPA “River Water Quality in County Wexford” reports for 2006 and 2007 do

not show any monitoring details on the Kilmuckridge Stream. The immediate

receiving water for discharges from the Kilmuckridge Waste Water Treatment

Plant is the Kilmuckridge Stream which eventually flows into St. George’s

Channel.

Technologies

The primary discharge is not compliant with design standards and may be having

an effect on the receiving water. As the only emission from the plant is the

primary discharge, from which there are no complaints, there are no current

proposed upgrades. There are no plans to reduce or mitigate discharges from

the plant.

Additionally, there are no complaints or incidents in relation to other discharges

to the general environment.

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Tech n i q ues

Not Applicable

Prevention of Pollution

The operation of the Kilmuckridge Waste Water Treatment Plant produces a

treated effluent which is not compliant with the plant design standards prior to its

discharge to the Kilmuckridge Stream. Adequate supervision and control of this

site should be carried out by the caretaking staff to monitor the Kilmuckridge

Waste Water Treatment Plant to ensure the effluent quality meets the design

standards set down.

Toxic Substances

Analysis of the samples taken from the receiving waters upstream and

downstream of the discharge point, and of the effluent from the Kilmuckridge

Waste Water Treatment Plant shows levels of dangerous substances that are

below the limits specified in the Dangerous Substances Regulations. The

agglomeration discharges are therefore compliant with the requirements.

Measures planned to monitor emissions into the environment

Wexford County Council will monitor the final effluent, in accordance with our

monitoring regime. This work is undertaken on behalf of Wexford County Council

by an independent ILAB accredited laboratory.

Process description

Plant Process

The overall Kilmuckridge Waste Water Treatment Plant has a design capacity of

2000 P.E. The daily Biological design load is 120Kg of BOD (60g/person/day). The

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plant maximum hydraulic design capacity is unknown, however, it is assumed to be

6 Dry Weather Flow for 2000 P.E. at 225 I/day.

Inlet works

The influent enters the Kilmuckridge Waste Water Treatment Plant through the

inlet channel. It passes over a stone trap and is directed by a disc screen to a

macerator. After passing through the macerator, the flow is split between the two

aeration ditches.

Aeration Ditches

The plant consists of two parallel treatment streams. The original Aeration Ditch,

which is equipped with two number cage rotors and a manually adjustable outlet

weir. The cage rotors operate in a cycle using a timer, and given that the outlet

weir and aerators have no automation besides cycle times, any adjustment to the

aeration process must be done manually. The Dissolved Oxygen (D.O.) meter

fitted is for monitoring purposes only.

The new aeration tank is the outer section of the new circular tank located beside

the inlet channel. The inner section is the settling tank associated with this

aeration tank. The aeration tank is fitted with a single cage rotor. The tank is also

equipped with a single flow booster.

The outlet weir of this aeration tank is fully automated and adjusts its level

depending on the reading from the Dissolved Oxygen (D.O.) meter fitted to the

tank.

Settling tanks

The purpose of the 2 settling tanks is the physical separation of liquid (treated

effluent) and solids (biomass). The 2 settling tanks operate in parallel.

The old aeration ditch discharges into the old settling tank located just upstream

of the outlet channel. Influent from the old aeration ditch enters the settlement

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tank via a centre diffuser drum and is directed downwards, encouraging the

settlement of solids and an even displacement of treated effluent over the saw

tooth weir, located around the perimeter, on the surface of the tank.

This tank is equipped with a Scraper Bridge which directs settled sludge into a

hopper located in the centre of the tank, where it is returned to the Aeration ditch

via the old sludge return sump. In addition, the tank is also fitted with a scum

collection box, discharging sludge which has risen to the surface to the scum

sump and is pumped back to the old aeration tank.

The new settling tank is the inner section of the new aeration tank and operates

on exactly the same principle as the old settling tank.

Sludge Return

Each settlement tank is equipped with a sludge return sump. Sludge from the

settlement tank is drawn off to the sludge sump by gravity. Each sump is equipped

with 2 No. submersible pumps, which operate in dutyktandby mode and return the

contents of the sump either to its dedicated Aeration ditch or to the sludge press

room.

Outlet Channel

The outlet channel is equipped with ultrasonic flow measurement, which is installed

upstream of a Venturi weir. Additionally, the outlet channel is equipped with a flow

proportional refrigerated sampler. The sample point is located just upstream of the

flume.

Welfare Facilities

There is a small control building on site housing welfare facilities, a small

laboratory and the electrical control equipment. There is no generator at the

treatment works to provide standby power in the event of a power failure.

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Additional Clarification and Appropriate Assessment for Kilmuchridge and Environs Agglomeration

Upstream

Downstream

Sludge Press Room

Excess sludge in the Kilmuckridge Waste Water Treatment Plant is pumped from

the sludge return sump to the sludge press room. The sludge is dewatered to

approximately 11% Dry Matter (D.M.) by means of a single belt sludge press and

removed from site for treatment at the sludge treatment centre.

I I I I

07-Aug-08 45 12 2.3 11 1.78 5 0.169

08-Aug-08 52 20 5.1 9 1.32 8 0.215

Summary of plant results

The table below outlines the median values for discharge parameters over 34

sampling events since January 2007.

The table below outlines submitted results for the receiving waters

Additional comments/clarification

This application is being made under the Waste Water Discharge (Authorisation)

Regulations 2007 and is solely for the pre-existing Primary Discharge Point

(SWI), which discharges Secondary treated effluent to the Kilmuckridge Stream,

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some 2.5Km upstream of an area designated as the Tinnaberna Sandhills

Special Area Conservation (SAC), site code 001 746, additionally, the Tinnaberna

Sandhills are also a designated National Heritage Area (NHA), site code 001746.

This application does not propose nor seek approval for any additional civil works

(excavation, construction, intrusion works etc) nor modification of the treatment

process or site activities, nor expansion of the discharge beyond its current

capacity and committed loading.

Therefore, the only potential source of any possible impact on the Nature

Conservation Sites is solely from the discharge to the aquatic environment.

Additionally, the discharge, as outlined above, is pre-existing, with the current

discharge installed in the late 1970s. Therefore, it would be fair to infer that, as

the discharge preceded the site designation, the requirements for knowledge of

the existence of the development by, and consultation with, all interested parties,

have been met.

Assessment of Significance

The primary discharge point and the receiving waters and agglomeration are not

located within a Designated Special Area of Conservation (SAC) or a Special

Protected Area (SPA).

Furthermore the primary discharge point is not within a National Heritage Area

(NHA).

Assessment as per Circular Letter L8/08 Appendix 1

1. Is the development in a nature conservation site? No.

2a. Is the development in the surface catchments of a nature conservation site

(or part of such site)? Yes.

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Discharge is to the Kilmuckridge stream, which is some 2.5 Km

downstream of the discharge point, and is designated as the Tinnaberna

Sandhills SAC and NHA, site code 001741.

Designation is due to the presence of 2 habitats listed on Annex 1 of the

Habitats Directive, namely Marram Dunes and Fixed Grey Dunes.

2b.k the development in the groundwater catchment or within 5Km of a

nature conservation site? N/A.

3. Are the qualifying habitats and species of the site water dependant?

No.

The qualifying Interests for the Site are Marram Dunes and Fixed Dunes,

both of which are Terrestrial Habitats and thus are not dependant on the

surface waters of site.

4. Is the development in the surface or groundwater catchment of other

water dependant Annex 11 Species or salmonid waters ? No

Additionally there is a WFD sub-basin plan for the sites and their

dependant habitats and species in place namely . South Eastern River Basin District Sub-basin Plan Tinnaberna, Trib of

Castle

South Eastern River Basin District Coastal Plan Southwestern Irish Sea

Conclusion

Given the following points:

The Distance from the discharge point to the area of designation is in

excess of 2Km;

The Qualifying interests in terms of habitats and their supported species

are all solely terrestrial, thus they are not receiving water quality

dependant;

There are SERBD plans in place for the designated areas.

Therefore in accordance with Circular L8/08, no further assessment is required at

this stage.

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Compliance with Waste Water Treatment Regulations 2001

Introduction:

The Kilmuckridge Waste Water Treatment is designed to cater for a design P.E

of 2,000 P.E. at 60g per P.E (120kg BOD/ Day) with an final effluent standard

effluent, of 25 mg/l BOD, The current calculated loading on the W P is 1686

P.E. (max loading taking into account seasonal variations), with a predicted

future committed total loading of 1921 P.E.

Article 7 (a)

Given the plant was in place prior to 31st December 2005: and is in compliance

with requirements under Second Schedule Part 1 of Urban Waste Water

Treatment Regulations, 2001 (S.I. No 254 of 2001). Additionally the receiving

water is not designated as sensitive under the Third Schedule Part 1 I Part 2 of

S.I. 254 of 2001 , Plant and final effluent is compliant with Article 7(a)

Article 8 (I), (2), (3) and (4),

As the Kilmuckridge W P plant is designed, constructed, operated and

maintained in accordance with the requirements of Article 8, with exception of

extraordinary circumstances, plant I final effluent is compliant with Article 8

Article 9

As the plant solely treats domestic waste water: with no licensed discharges to

collection system, plant / final effluent are compliant with Article 9

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Article 10 (I) (a) (b) and (2)

In that for this current 12 month period 12 samples of final effluent have been

taken, and results of previous years have been returned to the agency as

required. Plant / final effluent are compliant with Article 10

With regard to Fifth Schedule Requirements

The plant is compliant with point 1

Monitoring is currently in place with compliance regarding sample frequency and

laboratory requirements.

The plant is compliant with point 2,

In that the requirement for flow proportional sampling is required for plants with

design / loading of greater than 2,000 p.e. ( current loading is less than 2000 p.e.

and plant design is 2,0000) and as no formal request has been issued to

Wexford County Council, requiring installation of same.

The plant has been made compliant with point 3,

By increased monitoring frequency for 2009 forward and by important

compliance monitoring and installation of a new LlMS

Fifth Schedule,

It is believed that the plant will be in compliance with point 4 for 2009, however it

is currently not possible to confirm compliance as results of monitoring for

December 2009 is as yet not available. However for the 12 preceding months

(Dec 08 to Nov 09), of 12 samples taken 2 samples exceeded parameters as set-

out under applicable regulation ( Part 1 of the Second Schedule), with one of

these samples taken as extreme values (point 5 Fifth Schedule). Results are

attached.

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Clarification on Functionality of flow meter / Sampler

Flow:

The currently installed flow meter is functional, however does not currently have

a totalising / recording - logging functionality. Thus it is not possible to actually

measured discharge rates.

Sampler

The currently installed automatic sampler is neither functional nor fit for purpose.

Mitigation measures

The fusible of installation of flow monitoring and auto sampler is currently

underway. It is proposed to have remedial works completed by end 1" quarter

2010, pending feasible report and funding.

Clarification of precise agglomeration P.E.

The current plant loading is 1686 p.e: method of calculation and breakdown of

loading is outlined in Section B.9(i) of the application as previously submitted.

The predicted future (current plus committed) loading for Kilmuckridge

agglomeration is 1982 p.e.. The predicted future is based on best estimate of

outstanding planning commitments and predicted probability of actual

construction.

Clarification of coordinates for relevant points

(a) Centre of Site :

Correct coordinates are 316690 E/ 141244N as indicated in submitted

attachment B.3 (a), The coordinates indicted in submitted attachment B.2 (a) are

incorrect.

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(b) Primary Discharge Point SW1

Correct coordinates are 316761 E / 141244 as indicated in Submitted attachment

B.3 (a)

(c) Upstream sampling point aSWl U

Correct coordinates are 316562 E / 141533 (sample taken from downstream of

Kilmuckridge Br mid Stream.)

(c) Down steam sampling point aSWld

Correct coordinates are 317187 E / 141090 N ( Sample taken at nearest access

point of stream downstream of discharge - requires access across private lands)

Correct coordinates are 317187 E / 141533, supplied coordinates had an slight

error on Northern coordinates

All coordinates have been corrected in web link tools

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