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Sherwood House Telephone +353 91 5871 16 Sherwood Avenue Fax +353 91 587110 Taylor’s Hill Email [email protected] CON SU LTI N G E N G I N E E RS Galway Web www.ryan hanley. ie Administration Environmental Licensing Programme Office of Climate, Licensing & Resource Use Environmental Protection Agency Headquarters PO Box 3000 Johnstown Castle Estate CO. WEXFORD Our Reference Your Reference Date 1990/CL 12 November 2008 FAO: Dr Tom McLoughlin/Karen Creed Re: Ballina Waste Water Discharge Licence Application Register Number DO01 6-01 Notice in accordance with Regulation 18(3)(b) of the Waste Water Discharge (Authorisation) Regula ti ons 2007 Dear Dr McLoughlin, Ms Creed, Please find enclosed 2 No. copies of Revision 1 of the Appropriate Assessment for the above, as discussed. Please do not hesitate to contact me if you have any queries. Yours sincerely, CLAIRE LYONS End cc Mr Paddy Mahon, f Services, MCC Ballina DIRECTORS: MICHAEL 1. CANNON. BE. CENG. FIEI.MCIWEM. MlHT, RCONSEI (CHAIRMAN). GERARD F. GIBNEV.BE. CENG. MIEI. RCONSEI (MANAGING) DAMIAN P. HANUY, BE, MSC.(LOND), MEA, CENG, FIEI, MICE, RCONSEI, MICHAEL F. JOVCE, BE, CENG,FIEI, MCIWEM. RCONSEI, ANITA C. IAVDEN, BE,CENG, MICE, MCIWEM. FIEI. RCONSEI, DERMOT W. LYONS, BSc, CENG. FIEI. MCIWEM. AMINsTCES. DAMIAN RINGWOOD, BSC (MGMT) MBS (NON EXECUTIVE) SECRETARY M C CAHILL QUbLITy USUBID w PROPRIETORS RYAN HANLEY LTD REGISTERED IN IRELAND BUSINESS NO 377118 DUBLIN OFFICE Suite D4. The Cubes Offices, Beacon South Quarter, Sandyford, Dublln 18 -Telephone +353 1 2973030 Fax +353 1 2973033 Ernall info@ryanhanleyie For inspection purposes only. Consent of copyright owner required for any other use. EPA Export 26-07-2013:03:13:24

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Sherwood House Telephone +353 91 5871 16 Sherwood Avenue Fax +353 91 5871 10

Taylor’s Hill Email [email protected]

C O N S U L T I N G E N G I N E E R S Galway Web www.ryan hanley. ie

Administration

Environmental Licensing Programme

Office of Climate, Licensing & Resource Use

Environmental Protection Agency Headquarters

P O Box 3000 Johnstown Castle Estate

CO. W E X F O R D

Our Reference

Your Reference

Date

1990/CL

12 November 2008

FAO: Dr Tom McLoughlin/Karen Creed

Re: Ballina Waste Water Discharge Licence

Application Register Number DO01 6-01

Notice in accordance with Regulation 18(3)(b) of the Waste Water Discharge

(Authorisation) Regula ti ons 2007

Dear D r McLoughlin, Ms Creed,

Please find enclosed 2 No. copies of Revision 1 of the Appropriate Assessment for the above, as

discussed.

Please do not hesitate to contact me if you have any queries.

Yours sincerely,

CLAIRE LYONS End

cc M r Paddy Mahon, f Services, MCC Ballina

DIRECTORS: MICHAEL 1. CANNON. BE. CENG. FIEI. MCIWEM. MlHT, RCONSEI (CHAIRMAN). GERARD F. GIBNEV. BE. CENG. MIEI. RCONSEI (MANAGING) DAMIAN P. HANUY, BE, MSC.(LOND), MEA, CENG, FIEI, MICE, RCONSEI, MICHAEL F. JOVCE, BE, CENG, FIEI, MCIWEM. RCONSEI,

ANITA C. IAVDEN, BE,CENG, MICE, MCIWEM. FIEI. RCONSEI, DERMOT W. LYONS, BSc, CENG. FIEI. MCIWEM. AMINsTCES. DAMIAN RINGWOOD, BSC (MGMT) MBS (NON EXECUTIVE) SECRETARY M C CAHILL

QUbLITy USUBID w PROPRIETORS RYAN HANLEY LTD REGISTERED IN IRELAND BUSINESS NO 3771 18

DUBLIN OFFICE Suite D4. The Cubes Offices, Beacon South Quarter, Sandyford, Dublln 18 -Telephone +353 1 2973030 Fax +353 1 2973033 Ernall info@ryanhanleyie

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EPA Export 26-07-2013:03:13:24

MAYO COUNTY COUNCIL

Ballina Waste Water Discharge Licence

Appropriate Assessment

November 2008

Sherwood House, Sherwood Avenue,

Taylor’s Hill, Galway

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Report Control Sheet Ryan Hanley consulting engineers

FORM 214 Rev 000 IS0 9001 2000 Quality System

Client

Project No.

Project Title

Mayo County Council

1990

Ballina Waste Water Discharge licence Application

Report Title

Rev.

Appropriate Assessment

0

1

Status

Issue to €PA

Revised

following EPA

comment

Author(s)

Claire Lyons

Claire Lyons

Reviewed By

Claire Lyons

Claire Lyons

Approved By I Issue Date

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EPA Export 26-07-2013:03:13:24

Ballina Waste Water Discharae Licence Application ADaroariate Assessment

Introduction

A Waste Water Discharge Licence Application for the Ballina agglomeration was lodged with

the EPA in December 2007 in accordance with the Waste Water Discharge (Authorisation)

Regulations of 2007. Section F of the Application Guidance Note states that if discharges are

deemed likely to have a significant effect on a European site, an appropriate assessment of

the implications for the site in view of the sites conservation objectives must be carried out.

Following consultation with the National Parks and Wildlife Service, we confirm that

Appropriate Assessment is required for this discharge licence application.

The European Commission publication entitled “Assessment of Plans and Projects significantly

affecting Natura 2000 sites” has generally been followed in the preparation of this

Appropriate Assessment.

Description of Development The Waste Water Discharge Application is for the licensing of 10 No. discharges from the

existing sewerage scheme that serves the Ballina agglomeration. Nine of these discharges are

directly to the River MOY/MOY Estuary and one of the discharges is to the River Brusna,

immediately upstream of its confluence with the River Moy.

These discharges are located as shown on Drawing 31 entitled “Overview of Discharge Points”

which formed part of the Waste Water Discharge Licence Application. It is included again in

Appendix 1 here for convenience. Discharge Point S W 1 is the primary discharge point and is

the treated effluent outfall from the Ballina Wastewater Treatment Plant. Discharge Points

SW2 and 3 are emergency overflows from the two principal pumping stations on the network,

and only come into operation in the event of a power failure. Discharge Points SW4 to S W 1 0

inclusive are the discharge points from combined storm overflows on the collection network.

It is noted that these discharges have been in place since at least the early 1980’s.

location of Development in relation to Designated Sites

The discharges from the Ballina agglomeration take place to the River Moy SAC 002298 and further downstream the Killala Bay/Moy Estuary SAC 000458. SWl is the only discharge to

the Killala Bay/Moy Estuary SAC, the remainder are discharged to the River Moy SAC.

The River Moy SAC comprises almost the entire freshwater element of the Moy and its

tributaries including both Loughs Conn and Cullin. The system drains a catchment area of 805 square kilometres. Most of the site is in County Mayo with some parts located in Counties Sligo

and Roscommon. The underlying geology consists mainly of Carboniferous Limestone, with

some Carboniferous Sandstone in the extreme west of the site and Dalradian Quartzites and

Schists in the southwest. The site contains a wide range of habitats, including five that are

listed on Annex I of the EU Habitats. Directive, of which two are given priority status, i.e.

alluvial wet woodlands and raised bog. The remaining three Annex I habitats are Old oak

Woodlands, Degraded Raised Bog and Rhycosporion. The site supports populations of rare

and threatened mosses, liverworts, stoneworts, ferns and flowering plants including Narrow-

leaved Helleborine (Cephalanfhera longifolia), Intermediate Wintergreen (Pyrola media) and

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Ballina Waste Water Discharae Licence Aodication Amrowiate Assessment

Lesser Twayblade (listera cordata), Heath Cudweed (Omalotheca sylvatica), Great Burnet

(Sanguisorba officinalis) and Irish Lady’s-Tresses (Spiranthes romanzoffiana) and invertebrates

(White-clawed Crayfish, and the rare snail Acanthinula lamellata), fish (Sea Lamprey, Artic

Charr and Atlantic Salmon), birds (Greenland White-fronted Geese) and mammals (Otters).

The Killala Bay/Moy Estuary SAC possesses an excellent range of good quality coastal

habitats, including a number listed on Annex I of the EU Habitats Directive. It consists of the

long, narrow estuarine channel of the Moy, a north-facing triangular bay and dune systems.

Much of the inner part of the bay is intertidal with extensive sandflats and mudflats. For the

most part, these flats are unvegetated, but mats of Eelgrass (Zostera spp.), Beaked

Tasselweed (Ruppia maritima) and green algae (Enteromorpha spp.) occur which provide

important feeding material for birds. The dune systems at Bartragh Island, lnishcrone and Ross

are well-developed with a rich and diverse flora. Shifting dunes dominated b y Marram

(Ammophila arenaria) are located at all three sub-sites. Associated with these are embryonic

foredunes. The site still contains a relatively large area of intact fixed dunes, a priority habitat

listed on Annex I of the EU Habitats Directive. Humid dune slacks occur at Ross and Bartragh.

Salt marshes are present in sheltered areas with species typical of Atlantic salt meadows such

a s Sea Plantain (P uccinellia maritima), Thrift (Armeria maritima), Sea Aster (Aster tripolium) and

Red Fescue (Festuca rubra). Lax-flowered Sealavender (limonium humile), Saltmarsh Flat-sedge

(Blysmus rufus) and Sea Rush (luncus maritimus) are also present. O n the lower marshes, and

sheltered parts of the open mud flat:;, pioneering species such as Glasswort (Salicornia spp.)

and Seablite (Suaeda maritima) occur.

Elsewhere along the coastline are sandy beaches, shingle beaches and some bedrock shores

occasionally backed b y clay sea-cliffs. Lough Meelick is significant for the presence of the

Thinlipped Mullet, a fish, which is only occasionally found in the region. A number of rare

plants have been found in the site. The Opposite-leaved Pondweed (Groenlandia densa),

protected under the Flora (Protection) Order, 1999, has been recorded in the Moy Estuary

and Hoary Whitlowgrass (Draba incana), a Red Data Book species has been recorded from

sand dunes along the coast east of Killala town. The rare snail Vertigo angustior occurs in an

area of wet marsh and this site represents one of the few remaining examples of Vertigo

angustior in its marsh “phase”. This species is listed on Annex II of the EU Habitats Directive as it

is considered vulnerable in Europe and has being declining throughout much of its range due to loss of habitat, in particular, drainage of wetlands. The site is very important for wintering

waterfowl, with eight species having populations of national importance. These are a s follows:

Red-breasted Merganser, Ringed Plover, Grey Plover, Knot, Sanderling, Dunlin, Bar-tailed

Godwit and Greenshank. Other notable populations include Golden Plover and Brent Goose.

At times Brent Geese occur in numbers of International Importance. The presence of Golden

Plover and Bar-tailed Godwit is of particular note as these species are listed on Annex I of the

EU Birds Directive.

Screening

Circular L8/08 “Water Services Investment and Rural Water Programmes - Protection of Natural

Heritage and National Monuments” issued by the Department of Environment, Heritage and Local

Government (DEHLG) advises that initial screening be carried out for all water services projects in

order to identify potential ecological constraints. In this regard, a checklist has been drawn up by

the DEHLG. Where initial screening reveals, or cannot exclude with certainty, a likely significant

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Ballina Waste Water Dischorae Licence Amlication ADDroDriate Assessment

ecological impact, an assessment of impacts will need to be undertaken. In the case of a potential

impact on a Natura 2000 or European site (SAC‘S and SPA’S, including any candidate sites),

appropriate assessment (AA) is required under Article 6(3) of the Habitats Directive.

In accordance with the above, the site has been screened in accordance with Appendix I of L8/08 b y addressing the following issues;

I . Is the development in a nature conservation site?

Answer: Yes, the receiving waters for the discharges are part of the River Moy

Special Area of Conservation and the Killala Bay/Moy Estuary Special Area of

Conservation

2. Is the development in the surface water catchment of a nature conservation site (or part

of such a site)?

Answer: Yes, as above.

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

Answer: Yes, some of them are - see site descriptions above.

4. Is the development in the surface or groundwater catchment of other water dependent Annex I1 species, other rare or protected species or salmonid waters?

Answer: Yes, the River Moy is a designated Salmonid river in accordance with SI 293

of 1988. There are also water dependent Annex II species present as noted in site

descriptions above.

5. Answer: No

Is there a WFD sub-basin plan for the site or its protected habitatslspecies?

Conclusion: Assess Impacts

L8/08 states that if the conclusion of the screening process above is to “Assess Impacts” then the

project must be referred to the DEHLG Developments Application Unit. This has been done via the Western Region office of the National Parks and Wildlife Service, where it has been confirmed

that an Appropriate Assessment is required.

Appropriate Assessment

At Appropriate Assessment stage, the impact of the project or plan (either alone or in

combination with other projects or plans) on the integrity of the site is considered with respect

to the conservation objectives of the site and to its structure and function. In this case, the

project or plan is considered to be the existing sewage effluent discharges.

. Description of the plan likely to give rise to significant effects on the site

The description of the plan is given above. The likely significant effects on the site are

deterioration in water quality which could have an impact on the water dependent habitats

and species described above.

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Conservation Objectives of the Sites

There are currently no conservation management plans in place for either the River Moy

SAC or the Killala Bay/Moy Estuary SAC. However, it is expected that any conservation

management plan would aim to maintain the Annex I habitats for which the SAC’S have

been selected at favorable conservation status, such as alluvial wet woodlands and raised

bog, old oak woodlands, degraded raised bog, rhycosporion and intact fixed dunes. It is

also expected that any future conservation management plan would aim to maintain the

Annex II species such as white-clawed crayfish, sea lamprey, Atlantic salmon and otter, at

favourable conservation status. Other conservation objectives are likely to include

maintenance of the extent, species richness and biodiversity of the entire site and to

establish effective liaison and co-operation with landowners, legal users and relevant

authorities.

How plan will affect key species and habitats

An Environmental Impact Statement (EIS) was prepared prior to construction of an industrial

effluent stream at the wastewater treatment works in 1998. As part of the EIS, a water

quality modelling exercise was carried out. In terms of water quality, the EIS concluded that

“the impact on proposed waters can be described as imperceptible” and that “given the

characteristics of the treated water and the dilution capacity of the river, there will be no

significant impact on the aquatic flora and fauna”. It can be concluded that if the water

quality is not affected by the plan, then the key species and habitats will not be affected.

It is noted that analysis of the secondary discharge points (emergency overflows from

pumping stations) and storm overflows are not specifically addressed in this EIS; however

all of these types of discharges are upstream of the primary discharge point which was the

subject of the EIS, and are therefore included in the background or baseline water quality

data.

It is acknowledged that this study was carried out ten years ago and that development has

taken place in the catchment in the meantime. However, while the actual PE of the

agglomeration has increased, the modelling was carried out for the future scenario. Also,

substantial surface water separation works have been carried out in the intervening period,

thereby reducing the volume of effluent in the combined collection network, hence reducing

the volume and frequency of combined storm overflow and volume to be treated at the

wastewater treatment plant.

The figures below are from the EPA website and represent the latest water quality data

available. The nearest station on the River Moy has a Q value of 4 representing

unpolluted waters. It is noted that this station is just upstream of the discharges, apart from

SWl 0. The EPA Estuarine and Coastal data shows the Moy Estuary to be “unpolluted” as

represented by the blue shading below. The status of both of these water bodies remains

unchanged over the past number of decades. As noted in the description of the works, the

discharges have been taking place since at least the early 1980’s.

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EPA Export 26-07-2013:03:13:24

Ballina Waste Water Discharae Licence Auulication Auurouriate Assessment

Figures 1 & 2 Extracts from EPA Mapviewer for River and Estuarine Water Quality Data. The Blue

shading represents “Unpolluted” status

7 November 2008

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Ballina Waste Water Discharae Licence Amlication ADDroDriate Assessment

More detailed testing results for the relevant stretch of the River Moy and Moy Estuary have

also been obtained from the EPA. The! relevant sampling points are located as follows;

I EPA Location I Location

River Moy \ I

1100 I River Moy

River Moy

Moy Estuary

1 Moy Estuary

Moy Estuary

Location relative to ,Discharge Points I r 1

/ I - Upstream of Ballina agglomeration and all discharge

points. Closest discharge point is 1400m downstream of

sampling point.

200m downstream of S W 1 2 and upstream of all other

discharge points

400m downstream of 1 100, and downstream of all

discharge points apart from SWl, SW2, S W 1 1

900m downstream of 1200 and downstream of all

discharge points apart from S W 1

-

-

540m downstream of 10, at SWl , the primary discharge point (WWTP treated effluent outfall)

440m downstream of 15 and downstream of all discharge

points

T ble 1: EPA Sampling Points

All of the discharge point referred to are shown on Drawing 31 in Appendix 1.

A summary of the average measurements for these sampling points from 2005 to 2008 for the

River Moy and for 2007 to 2008 for the Moy Estuary for the measured parameters is given

below;

Table 2: Average Results of EPA Testing on River Moy and Moy Estuary in vicinity of Ballina Agglomeration

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EPA Export 26-07-2013:03:13:24

Ballina Waste Water Discharae Licence Aadication ARRrORriate Assessment

The above results are presented graphically from upstream to downstream sampling points on

the graphs below;

1 BOD +Ammonia +Ortho Phosphate +Total Oxidised Nitrogen

Chart 1 Average Testing Results for Sampling Points in vicinity of Ballina Agglomeration

BOD, Ammonia, Ortho-Phosphate, Total Oxidised Nitrogen

99.00 98.50

v) 98.00 97.50

E 97.00 Q E 96.50 r~ 96.00

95.50 95.00

+ Dissolved Oxygen

Chart 2 Average Testing Results for Sampling Points in vicinity of Ballina Agglomeration

Dissolved Oxygen

The location of the sampling points range from 1400m upstream of all discharge points (EPA Location Code 1000) to 420m downstream of all discharge points (EPA Location Code 20) and at regular intervals between these points. The graphs above illustrate that there is very

little change in the water quality parameters upstream and downstream of the agglomeration.

It is noted that there is a small spike at sampling point 20 which corresponds to the primary

discharge point location. This is to be expected in the immediate vicinity of the discharge

point. However, by sampling point 20, the water quality parameters have returned to similar

values to the parameters recorded at sampling points upstream of point 15. While there is a

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EPA Export 26-07-2013:03:13:24

Ballina Waste Water Discharae Licence Adication Amrowiate Assessment

small increase in the average BOO levels recorded upstream and downstream of the

discharge points, in the order of 0.26rng/l, it should be noted that there is actually an increase

in Dissolved Oxygen levels over the same stretch of water, Ortho-phosphate levels remain the

same and Total Oxidised Nitrogen levels decrease.

As noted in the screening process, the River Moy is a Salmonid water as per SI 293 of 1988.

All parameters for which testing has been carried out, namely pH, suspended solids, BOD and

total zinc are in compliance with the water quality standards for salmonid waters.

Ongoing testing is also carried out as Ross Strand and Enniscrone Beach, both designated

bathing water downstream of all of the discharges. These designated bathing waters are

meeting the standards set down in the Bathing Water Directive continuously. Both have Blue

Flag status. Details of the testing results for these bathing waters were contained in the Waste

Water Discharge Licence Application and are also included in Appendix 2 of this report.

It is concluded from all of the above evidence that the impact of the discharges on the water

quality is imperceptible, and that there is therefore no significant impact on the key habitats

and species for which the site has been selected.

Attachment F of the Waste Water Discharge Licence Application is included in Appendix 2 as

it contains information of the receiving environment and impact of the discharges.

. The integrity of the site is unlikely to be affected by the plan considering the conclusion above

that neither the Annex I habitats or the Annex II species are likely to be impacted by the plan.

The discharges will not impact on the potential future conservation objectives of the site, in

particular the objective to maintain favourable conservation status in regards to the Annex I and Annex II habitats and species.

Description of how the integrity of the site is likely to be affected by the plan

n . Description of Mitigation Measuues to avoid, reduce or remedy adverse effects on the

integrity of the site

As stated above, the integrity of the site is unlikely to be affected by the plan. The mitigation

measures that are already included in the plan to ensure this are as follows;

Provision of physical, biological and chemical treatment at the primary discharge

point including nutrient reduction

Availability of adequate capacity at the wastewater treatment works ensuring all

effluent from the treatment plant is fully treated to comply with Urban

Wastewater Regulations prior to discharge from plant

sophisticated SCADA system in the event of pump failure

Reduction of volumes and frequency of overflow of the combined storm overflows

as a result of substantial surface water separation works recently undertaken as

part of the main drainage scheme

Provision of screens at the most significant combined storm overflows (to be

completed by 2009)

0

Provision of standby pumps at the pumping stations and text alarms via a

0

0

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Ballina Waste Water Discharae Licence Amlication ADwrowiate Assessment

0 Provision of diffused outfall pipeline at primary discharge point to aid dispersion

and assimilation

Removal of existing septic tank serving Crocketstown area (> 1,000PE) which

historically has overflowed regularly to the River Moy

0

The above mitigation measures have all been undertaken as part of the Ballina Main

Drainage Scheme, Stage 2 which will be completed by the end of 2008 with the exception of

the combined storm overflow screens.

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Ballina Waste Water Discharge Application

APPENDIX 1

LOCATION OF DISCHARGE POINTS

F. 1/12

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Ballina Waste Water Discharge Application

APPENDIX 2 EXTRACT FROM ATTACHMENT F OF DISCHARGE LICENCE APPLICATION

F. 1/13

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Ballina Waste Water Discharge Application

n F.1. Assessment of Impact on Receiving Surface or Ground Water

n

0 Give summary details and an assessment of the impacts of any

existing or proposed emissions on the environment, including

environmental media other than those into which the emissions are to

be made.

The existing water environment is discussed in detail in Chapter Three

of the attached EIS. This EIS was prepared for the extension of the

wastewater treatment plant to provide an industrial effluent treatment

stream on site. The design values used in modelling exercises etc are

for the industrial effluent stream, with the municipal treatment stream

being included by reference to the background river data in the

vicinity. Section 3.4 discusses the existing aquatic environment and

Appendix no. 6 of the EIS contains a report prepared by Aquafact

International Services Ltd which is also relevant to this portion of the

application.

Tables F. 1 (i)(a) & (6) should be completed for the primary discharge

point. Surface water monitoring locations upstream and downstream

of the discharge point shall be screened for those substances listed in

Tables F.I(i)(a) & (b). Monitoring of surface water shall be carried out

at not less than two points, one upstream from the discharge location

and one downstream.

Resu Its pending .

0 For discharges from secondary discharge points Tables F. 1 (ii)(a) & (6)

should be completed. Furthermore, provide summary details and an

assessment of the impacts of any existing or proposed emissions on

the surface water or ground (aquifers, soils, sub-soils and rock

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Ballina Waste Water Discharge Application

environment), including any impact on environmental media other

than those into which the emissions are to be made.

Resu Its pending .

Provide details of the extent and type of ground emissions at the

works. For larger discharges to groundwaters, e.g., from Integrated

Constructed Wetlands, large scale percolation areas, etc., a

comprehensive report must be completed which should include, inter

alia, topography, meteorological data, water quality, geology,

hydrology, and hydrogeology. The latter must in particular present

the aquifer classification and vulnerability. The Geological Survey of

Ireland Groundwater Protection Scheme Dept of the Environment and

Local Government, Geological Survey of Ireland, EPA (1 999)

methodology should be used for any such classification. This report

should also identify all surface water bodies and water wells that may

be at risk as a result of the ground discharge.

Not applicable

0 Describe the existing environment in terms of water quality with

particular reference to environmental quality standards or other

legislative standards. Give details of any designation under any Council

Directive or Regulations that apply in relation to the receiving water.

The existing water environment is discussed in detail in Chapter Three

of the attached EIS. This EIS was prepared for the extension of the

wastewater treatment plant to provide an industrial effluent treatment

stream on site. The design values used in modelling exercises etc are

for the industrial effluent stream, with the municipal treatment stream

being included by reference to the background river data in the

vicinity. Section 3.4 discusses the exist aquatic environment and

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Ballina Waste Water Discharge Application

Appendix no. 6 of the EIS contains a report prepared by Aquafact

International Services Ltd which is also relevant to this portion of the

application.

The receiving water is a designated Special Area of Conservation,

known as the River M0.y Site Code 002298 and further downstream

Killala Bay/Moy Estuary Site Code 000458. The site synopsis sheets

are included at the end of this attachment. Contact has been made

with the National Parks and Wildlife Service (NPWS) regarding this

application. See attached correspondence. The NPWS has indicated

that it will not be in a position to comment on this application by the

deadline of 14 December 2007. It is intended that a copy of the

relevant sections of this application form will be copied to the NPWS on

completion and any further comment that they may have will be

forwarded to the EPA as an addendum to this application form as soon

as possible.

0 Provide a statement as to whether or not emissions of main polluting

substances (as defined in the Dangerous Substances Regulations S. I. No. 12 of 2001) to water are likely to impair the environment.

No dangerous substances likely to be present in discharges.

0 In circumstances where water abstraction points exist downstream of

any discharge describe measures to be undertaken to ensure that

discharges from the waste water works will not have a significant effect

on faecal coliform, salmonella and protozoan pathogen numbers, e.g.,

Cryptosporidium and Giardia, in the receiving water environment.

No water abstraction points downstream of discharges.

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Ballina Waste Water Discharge Application

0 Indicate whether or not emissions from the agglomeration or any plant,

methods, processes, operating procedures or other factors which affect

such emissions are likely to have a significant effect on -

a site (until the adoption, in respect of the site, of a decision by

the European Commission under Article 21 of Council Directive

92/43/EEC for the purposes of the third paragraph of Article

4(2) of that Direciive) -

(0

(ii)

(iii)

notified for the purposes of Regulation 4 of the Natural

Habitats Regulations, subject to any amendments made

to it by virtue of Regulation 5 of those Regulations,

details of which have been transmitted to the Commission

in accordance with Regulation 5(4) of the Natural Habitats

Regulations6, or

added by virtue of Regulation 6 of the Natural Habitats

Regulations to the list transmitted to the Commission in

accordance with Regulation 5(4) of those Regulations,

a site adopted by the European Commission as a site of

Community impoi-tance for the purposes of Article 4(2) of

Council Directive SJ2/43/EEC1 in accordance with the procedures

laid down in Article 21 of that Directive,

a special area of conservation within the meaning of the Natural

Habitats Regulations, or

an area classified pursuant to Article 4(1) or 4(2) of Council

Directive 79/409/€EC2;

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w Ballina Waste Water Discharge Application

n

‘Council Directive 92/43/EEC of 21 May 1992 on the conservation of

natural habitats and of wild fauna and flora (OJ No. L 206,

22.07.1992)

2Council Directive 79/409/EEC of 2 April 1979 on the conservation of

wild birds (OJ No. L 103, 25.4.1979)

The receiving waters to which all the discharges take place is a Special

Area of Conservation as described above and a designated salmonid

water.

The EIS concluded that “the impact of the proposed development on

waters can therefore be described as imperceptible”. And “The

predictions of the mathematical models relating to the dissipation of

effluent parameters along the estuary would indicate that the proposed

project would have no irnpact on the Blue flag beach at Enniscrone or

on licensed shell fishing areas in Killala Bay”. It is noted that analysis

of the secondary discharge points (emergency overflows from pumping

stations) and storm overflows was not specifically addressed in the

EIS. However, it is noted that both of these types of discharge are all

upstream of the discharge being assessed in the EIS and hence are

included in the background water quality data.

Describe, where appropriate, measures for minimising pollution over

long distances or in the territory of other states.

Biological and chemical treatment is provided at the wastewater

treatment works, to reduce the number of faecal coliform, salmonella

and protozoan pathogen numbers in the effluent. No treatment is

carried out at the storrri overflow points or the secondary discharge

points (pumping station emergency overflows), but the volume of flow

in the River Moy is such that adequate dilution is available for the

intermittent discharges. The inclusion of phosphorous and nitrogen

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Ballina Waste Water Discharge Application

n

n

removal will mitigate ariy adverse impact which the discharge of an

additional volume of treated effluent might have on the ecology of the

estuary .

Information from 18 no. tests carried out in the Ross Strand bathing

water quality station, which is downstream of all discharge points was

obtained from the EPA, see Table F1 below. These tests show that the

total number of coliforrns per 100ml was less than ten on seven

occasions and the total number of coliforms only exceeded 100 on three

occasions. This beach also enjoys blue flag status which is an indication

that the water quality is; very good. This beach is downstream of all

discharge points being discussed in the application.

This section should also contain full details of any modelling of

discharges from the agglomeration.

See attached EIS.

e Measures to be undertaken to ensure discharges from the waste water

works will not have a significant effect on faecal coliform, salmonella

and protozoan pathogen numbers, e.g., Cryptosporidium and Giardia,

in the receiving water environment. Particular focus exist downstream

of the waste water discharge points.

Biological and chemical treatment is provided at the wastewater

treatment works, to reduce the number of faecal coliform, salmonella

and protozoan pathogen numbers in the effluent. No treatment is

carried out at the storm overflow points or the secondary discharge

points (pumping station emergency overflows), but the volume of flow

in the River Moy is such that adequate dilution is available for the

intermittent discharges. The inclusion of phosphorous and nitrogen

removal will mitigate any adverse impact which the discharge of an

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Ballina Waste Water Discharge Application

n

additional volume of treated effluent might have on the ecology of the

estuary.

Information from 18 no. tests carried out in the Ross Strand bathing

water quality station, which is downstream of all discharge points was

obtained from the EPA, see Table F l below. These tests show that the

total number of coliforms per lOOml was less than ten on seven

occasions and the total number of coliforms only exceeded 100 on three

occassions. This beach also enjoys blue flag status which is an indication

that the water quality i!; very good. This beach is downstream of all

discharge points being discussed in the application.

0 The presence of any areas designated for the protection of economically

significant aquatic species (fish, shellfish).

None.

0 The presence of any areas designated as recreational and bathing

waters.

Two such areas are present in the Moy estuary. The closest blue flag

beach is 9 km north of ,the outfall point and is located at Enniscrone.

There is a second blue flag beach at the western side of the estuary at

Ross Strand.

0 The presence of any areas designated as nutrient sensitive areas.

There are no designated nutrient sensitive areas downstream of the

discharge points. However, nitrogen and phosphorous reduction of the

effluent takes place before discharge to the River Moy.

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B

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Ballina Waste Water Discharge Application

0 The presence of any biological species sensitive to any substance in

the emission.

No known species.

0 Sensitive areas of special interest within 2 kilometers of the emission

point which could be affected by the emission.

Discharges are directly to the River Moy SAC and Killala Bay/Moy

Estuary as described above.

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.. . .. . . . . . . . . .

Ballina Waste Water Discharge Application ' I

0 Flow Data - upstream of discharge points

Summary Statistics Data 0 Daily Mean Flow Data Daily Mean Level Data Annual Maxima Data

Mean Annual Flow (m3/s): 55.37

(Data derived for the period 1969 to 2004.)

Note 1 : Data extracted from the Environmental Protection Agency publication 'Hydrological Data', July

1997

r excee

(Data derived for the period 1969 to 2004)

Dry weather flow, as quoted by the EPA is 3m3/s.

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P

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Ballina Waste Water Discharge Application

0

Since the installation of the new outfall point which extends 40m from the

river bank streaming has been prevented down the western side of the

river. Mixing of the effluent with the river water is much more efficient now.

Models of this have been prepared and can be found in Appendix no. 5 of

the EIS.

Mixing Zone or transitional areas of exceedance.

See Section 3 of EIS.

Levels of dilution available within the receiving waterbody.

0 Receiving water and sediment quality, physical, chemical and biological.

See Section 3 of EIS.

Existing or proposed uses and/or designations of receiving waters and

compliance with any applications standards (e.g. salmonoid standards,

bathing water standards, standards specified in Water Quality

(Dangerous Substances) Regulations 2001.

The receiving water is classified as a salmonoid river.

0 Nature of final emission to receiving waters, along with the estimated

volumetric contribution by the site emissions to the Dry Weather Flow to

the receiving waters, expressed as a percentage [YoDWF].

Dry weather flow as quoted by the EPA at the Rahans station as being

10,800m3/hour. The average volume discharge from the treatment works is

125m3/hour. This equates to 1.15 O/O of the DWF of the River Moy.

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