TUAM WASTE WATER DISCHARGE LICENCE APPLICATION00-3927 218 218 80% complete 122.1 0-21647 6 6 yes 0.0 0-32107 8 8 yes 0.0 ... Total BOD Load to WWTP 22,440 Design Capacity of WWTP 3

GALWAY COUNTY COUNCIL

TUAM WASTE WATER

DISCHARGE LICENCE APPLICATION

NOTICE RESPONSE REGULATION 18(3)(B)

July 2009

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-07-2013:15:37:46

Report Conlrol Sheet FORM 214 Rev 000 Ryan Hanley conruhing engineers IS0 9001 2000 Quality Sydem

Clieni

Project No.

Projecl Tiile

Issued to Client

I I I I I

Galway Counly Council

1985

Tuom Waste Water Discharge Licence Application - -

Reporl Tiile Notice Response Regulation 18(3)(b)

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-07-2013:15:37:46

Tuam Agglomeration Unsolicited Additional Information

July 2009


TUAM WASTE WATER DISCHARGE LICENCE APPLICATION NOTICE RESPONSE REGULATION 18(3)(B)

TABLE OF CONTENTS

1. INTRODUCTION ........................................................................................................................................................... 1

2. PENDING DEVELOPMENTS AND TREATMENT WORKS CAPACITY .................................................................... 1

3. STATUS REPORT ON WASTE WATER TREATMENT PLANT................................................................................... 3

4. APPROPRIATE ASSESSMENT ...................................................................................................................................... 4

5. ENVIRONMENTAL LIABILITIES DIRECTIVE................................................................................................................. 4

6. PLANNING PERMISSION ............................................................................................................................................ 5

7. SECTION 63 NOTICES................................................................................................................................................. 5

8. DISCHARGE POINTS SW2 TO SW8........................................................................................................................ 5

9. DISPOSAL/RECOVERY OF FINAL SLUDGE.............................................................................................................. 6

10. DRY WEATHER FLOW FOR THE RIVER CLARE........................................................................................................ 6

11. CERTIFICATION OF METHODS USED FOR ANALYSIS ........................................................................................... 6

12. COMPLIANCE WITH MONITORING REQUIREMENTS ........................................................................................... 7

13. SENSITIVE AREAS ......................................................................................................................................................... 7

14. ASSIMILATIVE CAPACITY OF RIVER CLARE ............................................................................................................. 7

15. DANGEROUS SUBSTANCES....................................................................................................................................... 8

16. PROGRAMMES OF IMPROVEMENTS RE: COMPLIANCE WITH DIRECTIVES ..................................................... 8

Appendices

Appendix A: Non-Technical Summary Appendix B: Aeration Capacity Preliminary Report Appendix C: Appropriate Assessment Screening Document Appendix D: Details of Dry Weather Flow (DWF) on the River Clare

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-07-2013:15:37:46


1 July 2009

1. INTRODUCTION

This document relates to outstanding information which was not submitted as part of Galway County Councils Response to the Agency’s Notice Regulation 18 (3)(b) in August 2008. This information which is detailed below includes all the outstanding information required under the Agency’s Notice and will conclude Galway County Councils Response to the Notice. A revised Non-Technical Summary is included in Appendix A

2. PENDING DEVELOPMENTS AND TREATMENT WORKS CAPACITY

Requirement

Where planning permission has been granted for developments, but the said development has not been commenced or completed to date, within the boundary of the agglomeration and this development is being, or is to be, served by the waste water works provide the following; • Information on the calculated population equivalent (p.e.) to be contributed to the waste water

works as a result of those planning permissions granted, • The percentage of the projected p.e. to be contributed by the non-domestic activities, and • The ability of the waste water works to accommodate this extra hydraulic and organic loading

without posing an environmental risk to the receiving water habitat.

Response The population equivalent (P.E.) to be contributed to the waste water works as a result of developments that have not commenced or completed is 3255 P.E. The percentage of the projected P.E. to be contributed by the non-domestic activities is 2.2%. For a more detailed breakdown of the projected P.E. figures, refer to Table 1 below. An assessment of the ability of the waste water works to accommodate the extra hydraulic and organic loading without posing an environmental risk to the receiving water habitat is given in Table 2 below.

Table 1: Calculated P.E. to be contributed to the waste water works and percentage of the projected

P.E. to be contributed by the non-domestic activities

File No. Total Dwelling Apt Ind Ret Other

Constructed &

Connected P.E.

PE

(n.dom) Comment

yes/no

0-64699 25 25 0 no 70.0

0-73475 35 35 no 98.0

0-51157 6 6 no 16.8

0-62871 5 5 yes 0.0

0-72169 16 8 8 yes 0.0

0-62876 12 12 no 33.6

0-65766 120 99 20 1 no 317.2 0.5 retail

0-7669 11 5 6 no 26.0

0-45061 178 154 24 yes 0.0

0-51630 6 6 no 16.8

0-72272 5 5 no 14.0

0-71167 16 16 no 44.8

0-42389 108 108 yes 0.0

0-43249 7 7 no 14.0

054095 4 4 no 2

01728 2 1 1 yes 10

041024 4 4 no 2

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-07-2013:15:37:46


2 July 2009

File No. Total Dwelling Apt Ind Ret Other

Constructed &

Connected P.E.

PE

(n.dom) Comment

yes/no

065042 5 5 no 2.5

045312 139 136 2 yes 0.0

022421 8 3 1 4 yes 0.0

024003 13 9 4 yes 0.0

035466 16 12 4 yes 0.0

044818 2 2 yes 0.0

053756 1 yes 0.0

0-73767 168 112 55 1 yes 0.0 0 supermarket

001217 10 1 yes 0.0

01635 17 1 yes 0.0

042120 1 1 no 5 Medical centre

04-2275 22 14 4 4 no 28.0 4

014592 5 5 yes 0.0

033530 1 yes 0.0

062385 1 1 no 5 Day centre

074112 5 2 3 no 4.0 1.5 Commercial

054462 1 1 no 5 Childcare

0-81464 15 15 no 42.0

0-81734 10 10 no 5 Warehouses

0-8564 13 13 no 6.5 Warehouses

0-74064 13 13 no 36.4

0-81629 372 277 92 2 1 no 1038.2 1 retail

00-3927 218 218 80% complete 122.1

0-21647 6 6 yes 0.0

0-32107 8 8 yes 0.0

0-35579 10 10 no 28.0

0-73590 30 30 no 60.0

0-74996 9 9 no 4.5 industrial

0-11279 5 5 no 14.0

0-36978 88 88 no 246.4

0-81656 108 108 no 302.4

00-3474 201 201 yes 0.0

0-11650 9 9 yes 0.0

0-11715 24 24 no 48.0

0-35434 1 yes 0.0

0-44818 1 yes 0.0

0-54986 9 9 no 25.2

0-63296 17 13 4 no 36.4 2

0-65424 6 6 no 16.8

0-65783 7 5 2 no 14.0 1 Commercial

0-1488 69 65 yes 0.0

0-33487 22 22 yes 0.0

0-5841 24 24 50% complete 33.6

0-880 15 15 no 30.0

0-74067 64 64 no 179.2

0-75288 26 26 no 72.8

0-81989 9 4 4 1 no 11.2 7 supermarket

00-1203 15 15 no 42.0

00-1799 9 9 yes 0.0

00-3276 12 12 no 24.0

00-4277 32 32 yes 0.0

0-13009 6 6 no 16.8

0-42603 93 93 yes 0.0

0-61409 69 69 yes 0.0

0-6695 22 22 yes 0.0

0-62261 38 38 yes 0.0

0-63287 34 30 4 yes 0.0

0-63537 13 2 6 2 3 no 17.6 2.5 retail units

0-81965 30 22 8 no 44.0 4 retail units

0-52806 13 13 yes 0.0

0-72947 24 24 yes 0.0

3184.3 71

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-07-2013:15:37:46


3 July 2009

Projected P.E

Total Contribution of developments to be constructed and connected to WWTW 3,255.3 100.0%

Domestic contribution of developments constructed and connected to WWTW 3,184.3 97.8%

Non domestic contribution of developments constructed and connected to WWTW 71.0 2.2%

Basis P.E.

retail shop 0.5

house 2.8

apartment 2

office 0.5

industrial unit 0.5

restaurant 5.0

The current loadings to Tuam Wastewater Treatment Plant are set out in Table 2, with a more detailed account given in the Aeration Capacity Preliminary Report, a copy of which is included with this response in Appendix B. Leachate from the Connaught Regional Residual Landfill and Imported sludge are discharged by tankers to pumping stations within the Tuam Town collection network.

Table 2 Current Loads to Tuam WWTP (Population Equivalents)

Tuam Town 11,000

Leachate1 7,500

Imported Sludges2 3,940

Total BOD Load to WWTP 22,440

Design Capacity of WWTP3 25,000

Available Capacity at WWTP 2,560

1. Maximum daily load estimate, see discussion in Aeration Capacity Preliminary Report 2. Domestic equivalent load estimate; see discussion in Aeration Capacity Preliminary Report

3. Capacity assuming that aeration system is upgraded

The total population that would arise from the developments listed in Table 1 above is estimated to be 3,255 P.E. The available capacity (2,560 P.E.) will be taken up over time by population growth as housing and commercial developments already approved by Galway County Council are completed and occupied. Between the 2002 Census and 2006 Census, the Tuam urban and rural population grew by 938, an average rate of 4% p.a. At an average growth rate of 4% p.a. and assuming that the current Tuam catchment population is 9,000 (Ryan Hanley, August 2008) then the available capacity will be fully utilised in 7 years time.

3. STATUS REPORT ON WASTE WATER TREATMENT PLANT

Requirement Information on the Status Report which Galway County Council intended to commission on the existing wastewater treatment plant in order to determine its adequacy etc. (Page 12 of 77, Non Technical Summary refers). Submit a copy of any such report on the matter as has been produced to date.

The Status Report should also include the following:

• An update on the figure for the P.E. load currently being treated at the plant. It is noted that the design P.E. figure supplied in the application was determined in 1988. The updated figure supplied in the application was determined in 1988. The updated figure should be

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-07-2013:15:37:46


4 July 2009

generated using the most up-to-date data from the Central Statistics Office (CSO). • An assessment of the information relating to planning permission as required above.

Response The following report is included in Appendix B of this response and addresses the issue raised above.

‘Aeration Capacity Preliminary Report’, Ryan Hanley, March 2008.

A Current Population Equivalent of 22,440 has been calculated based on a targeted influent survey to allow a baseline assessment of the exiting domestic load. Imported loads from the sludge and leachate have been calculated separately. This is a more accurate way of determining the existing P.E. loading to the plant than using CSO figures. An assessment of planning permissions granted by Galway County Council is addressed above and elsewhere in the Aeration Capacity Preliminary Report in Appendix B. Please note that the upgrade works proposed for the Tuam Wastewater Treatment Works, is dependant on funding being provided jointly by the Connaught Regional Residual Landfill and the Department of Environment, Heritage & Local Government as set out in the Aeration Capacity Preliminary Report.

4. APPROPRIATE ASSESSMENT

Requirement The final report on the Appropriate Assessment of the WWTP discharges as requested by the NPWS in November 2007, to include and ecological assessment under the Birds Directive. In this regards, your attention is drawn to the Agency’s recent guidance document on appropriate assessment of waste water works projects. Response An Appropriate Assessment Screening Document, prepared by McCarthy Keville O’Sullivan, is included in Appendix C.

5. ENVIRONMENTAL LIABILITIES DIRECTIVE

Requirement A statement as to how Galway County Council will satisfy the requirements of Article 3 and Annex III of the Environmental Liabilities Directive as required by Section G.1 of the application form. Response The Environmental Liabilities Directive sets out to prevent or where appropriate remedy environmental damage caused by human developments and activities. This environmental damage is in respect of protected species and natural habitats, water damage and land damage.

Discharge Point SW1 is located in the River Clare, which is within the Lough Corrib Special Area of Conservation. Although the river is not designated a salmonoid river under S.I No. 293-1988 the river does contain significant populations of salmon and trout with extensive spawning grounds. Also Lough Corrib, into which the Clare flows is designated as salmonoid water and thus the standards for salmonoid water were adopted when considering final effluent standards for the treatment works. The treatment process incorporates Phosphorus Removal which is achieved

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-07-2013:15:37:46


5 July 2009

by dosing Ferric Sulphate directly downstream of the aeration tanks. 6. PLANNING PERMISSION

Requirement The reasons as to why planning permission is not required for the wastewater treatment works. See Section B.6 of the Application Form.

Response The Waste Water Treatment Works was constructed in 1993, prior to the introduction of a requirement for Part X Planning for Wastewater Treatment Facilities by Local Authorities, which was brought about by the Local Government (Planning & Development) Regulations 1994. Tuam Waste Water Treatment Works was therefore exempt from a requirement for planning permission at the time it was designed and constructed. Part 8 Planning has been sought and acquired for the proposed works to be carried out under the Tuam Town Water and Main Drainage Scheme in accordance with the Local Government (Planning and Development) Act 2000 & the Local Government (Planning and Development) Regulations 2001. The same will apply to any future upgrades of the Waste Water Treatment Works.

7. SECTION 63 NOTICES

Requirement A statement as to whether or not any Section 63 notices have been issued by this Agency in relation to the waste water works. Complete Attachment B.11, where appropriate. Response No section 63 notices have been issued to date.

8. DISCHARGE POINTS SW2 TO SW8

Requirement A clear statement as to the current nature of the discharge points SW2 to SW8, i.e., whether or not they act as surface water overflows and/or emergency overflows. There are conflicting statements in your licence application documentation. A clear statement as to the eventual use of discharge points SW2 to SW8 post Stage 2 upgrading works, i.e. which of these is to be retained or fully eliminated? There are conflicting statements in your licence application documentation. By way of example, it is stated on Page 21 of your application (under Section B.10) that ‘it is Galway County Council’s intention to remove six storm overflows completely from the network (i.e. storm water references SW3 to SW8 exclusive)’, while on page 28 (under Section C2) it is stated that the Stage 2 works will result in ‘significantly decreased operation of the remaining overflows’. Response

Discharge points SW2 & SW8 relate to overflows from the Weir Road and Galway Road pumping stations respectively, while discharge points SW3, SW4, SW5, SW6 & SW7 relate to existing Combined Storm Overflows (CSOs) within the sewerage network. Following completion of surface water separation within the existing sewerage network carried

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-07-2013:15:37:46


6 July 2009

out as part of Tuam Town Water and Main Drainage Stage 2 Contract, the 5 No. CSOs will cease to discharge raw sewage at discharge points SW3 to SW7. Construction of a storm water holding tank at the Weir Road pumping station site will reduce occurrences of overflow at SW2 to a much lower frequency (one spill per annum on average) than that stipulated by the Urban Wastewater Treatment Directive (UWWTD 91/271/EEC) for bathing waters and contact/recreational areas (respectively; three and seven spills per annum on average). SW8 is an emergency overflow from the Galway Road pumping station. This pumping station collects foul effluent only and there is no storm water contribution to this pumping station. This wet well/dry well pumping station is equipped with two dry mounted pumps which work on a duty/standby basis. A 150mm diameter emergency overflow is provided at 33.20 mOD from this pumping station and it was provided to allow foul effluent escape from the system should the duty pump and standby pump fail to start due to ESB power outage or pump failure. This overflow was not provided for the purpose of relieving the system of excess flows that arise as a result of rainwater or melting snow. This emergency overflow would not expect to be used in the normal operation of this pumping station and would only be used in the event of power or mechanical failure.

9. DISPOSAL/RECOVERY OF FINAL SLUDGE

Requirement An outline description of the eventual disposal/recovery of the final sludge produced at the plant Response

Tuam MDS Wastewater Treatment Plant manages the spreading of sludge produced in the WWTP by way of land spreading to a land bank once the sludge has undergone lime treatment. Records of land spreading are forwarded to the EPA and are kept in a sludge register. Sludge Spreading is not permitted during the period of 15th October to 15th January and surplus sludge produced by the plant is exported from the site by a Sludge Management Company, Ormonde Organics, who in turn manage the sludge through a combination of composting, sludge storage and land spreading. The lands on which sludge produced at the Wastewater Treatment Works is spread are subject to nutrient management plans.

10. DRY WEATHER FLOW FOR THE RIVER CLARE

Requirement A value for Dry Weather Flow (DWF) on the River Clare at the Discharge Point SW1. Complete table D(1)(i)(a) of the application form. Response A copy of Table D(1)(i)(a), Revision A is included in Appendix D.

11. CERTIFICATION OF METHODS USED FOR ANALYSIS

Requirement Details of any accreditation or certification of the methods used for analysis of discharge or ambient samples. Complete Attachment E.2.

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-07-2013:15:37:46


7 July 2009

Response It has been previously stated in the Technical Summary of the WWD Application Form that the Plant Manager participates on the EPA’s inter-calibration programme and the laboratory in the Tuam waste water treatment works is listed on the EPA’s “Register of Quality Approved Laboratories Submitting Data to EPA (2006 Data)”.

12. COMPLIANCE WITH MONITORING REQUIREMENTS

Requirement Details of compliance with any applicable monitoring requirements and/or treatment standards as required by Regulation 16(1)(1) of the Wastewater Discharge (Authorisation) Regulations 2007. Complete Attachment E.4. Response The water quality monitoring programme complies with the applicable monitoring requirements and/or treatment standards as required by Regulation 16(1)(1) of the Wastewater Discharge (Authorisation) Regulations 2007. Copies of water quality data with results for all of the relevant parameters listed under the regulations were forwarded to the agency in August 2008.

13. SENSITIVE AREAS

Requirement An indication as to whether or not there are sensitive areas or areas of special interest within 2km of discharge point SW1. Response Discharge Point SW1 is located in a Special Area of Conservation, namely;

Lough Corrib SAC; Site Code 000297

The drawing showing the extent of the Lough Corrib SAC in the vicinity of Tuam, a Site Synopsis and an Assessment of Significant Impacts are provided in the Appropriate Assessment Screening Document contained in Appendix C.

14. ASSIMILATIVE CAPACITY OF RIVER CLARE

Requirement An updated assessment of assimilative capacity of the River Clare. It is noted that such a study was last carried out in 1988. Any updated study should address, where appropriate, the requirements and details as set out in Section F of the WWDL Application Guidance Notes, which are available on the Agency Website. Response The following Report is included in Appendix II of the Appropriate Assessment Screening Document, which is included in Appendix C of this response;

“Assessment of the Cumulative Impact on the Clare River, Co. Galway, of Wastewater Discharges from Wastewater Treatment Plants in Milltown, Tuam & Claregalway”, Hydro-G, November 2008.

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-07-2013:15:37:46


8 July 2009

15. DANGEROUS SUBSTANCES

Requirement

A statement, as per Section F of the Licence Application Form, as to whether or not emissions of the main polluting substances (as defined in the Dangerous Substances Regulations SI No. 12 of 2001) to water are likely to impair the environment. The submission of the relevant emissions data in Table D(1)(c) in your reply of 20/08/08 is noted. This data should now be examined with a view to assessing any impact. Response Emissions of the main polluting substances (as defined in the Dangerous Substances Regulations SI No. 12 of 2001) to water are not likely to impair the environment as the levels present in discharges from Tuam WWTP are negligible in comparison to the maximum permissible levels stipulated in the Dangerous Substances Regulations, based on sampling data which was forwarded to the Agency in August 2008.

16. PROGRAMMES OF IMPROVEMENTS RE: COMPLIANCE WITH DIRECTIVES

Requirement Details of any current programmes of improvements, as required by Section G.1 of the Licence Application form, where not already witnessed in your application documentation, to ensure compliance with the various Directives, as set out in Section G.1, in particular:

(a) The Dangerous Substances Directive. The submission of the relevant emissions data in Table D(1)(c) in your reply of 20/08/08 is noted,

(b) The Groundwater Directive. This should examine whether or not there are any emissions to ground or groundwater by way of system leaks, etc. that are currently the subject of a programme of improvements,

(c) The Drinking Water Directive. You should provide clarification as to whether or not the discharge at SW1 was included in the risk assessment for the Terryland Drinking Water Treatment Plant. If so, provide an outline of the outcome of the risk assessment where it relates tot e SW1 discharge at Tuam.

Response

(a) Emissions of the main polluting substances (as defined in the Dangerous Substances Regulations SI No. 12 of 2001) from Tuam WWTP have been shown to be negligible in comparison to the maximum permissible levels stipulated in the Dangerous Substances Regulations, based on sampling data available. A programme for improvements is therefore not required.

(b) A CCTV survey was carried out on the entire Tuam Town Wastewater Collection Network and no emissions to groundwater by way of system leaks were detected.

(c) Galway County Council is not aware whether Galway City Council has prepared a Risk Assessment for the Terryland Water Treatment Plant, however we are aware that Galway City Council operates a conventional coagulation/filtration water treatment plant with UV disinfection and that this type of treatment provides a 6.5 log reduction/inactivation of cryptosporidium.

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-07-2013:15:37:46


TUAM WASTE WATER DISCHARGE LICENCE APPLICATION

Notice Response Regulation 18(3)(b)

Appendix A:

Non-Technical Summary

July 2009

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-07-2013:15:37:46



Notice Response Regulation 18(3)(b)

Appendix B:

Aeration Capacity Preliminary Report

July 2009

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-07-2013:15:37:46



Tuam Waste Water Treatment Plant Process Audit Report

Appendix C:

Appropriate Assessment Screening Document

July 2009

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-07-2013:15:37:46



Tuam Waste Water Treatment Plant Process Audit Report

Appendix D:

Dry Weather Flow (DWF) on the River Clare Table D(1)(i)(a)

July 2009

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 26-07-2013:15:37:46

Documents

TUAM WASTE WATER DISCHARGE LICENCE APPLICATION00-3927 218 218 80% complete 122.1 0-21647 6 6 yes 0.0 0-32107 8 8 yes 0.0 ... Total BOD Load to WWTP 22,440 Design Capacity of WWTP 3