Aras - Environmental Protection Agency · 2013-07-25 · Email: [email protected] Website:...

Aras na Cathrach Luimneach Telefh: 061 .407100 Fax: 061 .415266 Email: [email protected] Website: www.1imerickcity.ie

Environmental Licensing Programme Office of Climate, Licensing anid Resource Use Environmental Protection Agency Headquarters, PO Box 3000 Johnstown Castle Estate GWWexford Your reference

City Hall Limerick Telephone: 061 ,407 100 Fax: 061 .415266 Email: [email protected] Website: www.1imerickcity.ie

- Our reference

Date: 18 June 2008 EPA Ref: 00013-01

RE: LIMERICK MAIN DRAINAGE (CITY & ENVIRONS) Waste Water Discharge Licence Application: Register No. D0013-01

Dear Sirs,

Your letter of 4 April 2008, reference D0013-01, with regard to Article 16 Compliance Requirements pertaining to the Discharge Licence Application for the Limerick City Council Waste Water Treatment Works at Bunlicky, County Limerick, refers.

Herewith are two copies of each of the following:

Drawing LMD-97120-DLA-03 Revision A; A drawing revision list;

The further information requested (as indicated in the shaded areas);

Also herewith is a CD containing the above documents in pdf format.

Please note that the non-technical summary from the original discharge licence application submission has not been amended and so a revised version is not included as part of this submission.

Yours faithfully,

Pat Dromjy, Director f Service (Transportation 8 Infrastructure).

Pdipkar 100% Athchljrsailte Printed on 100% recycled paper

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Response to EPA Letter of 4 April.doc Page 1 of 8

LIMERICK MAIN DRAINAGE

WASTE WATER TREATMENT PLANT DISCHARGE LICENCE APPLICATION

Register No. D0013-01

INFORMATION REQUESTED IN EPA LETTER DATED 4 APRIL 2008

1. 16(1)(d)

Reassess the information submitted in relation to the size of the

agglomeration, in particular the map entitled “Waste water treatment plant

agglomeration boundary – Drawing No. LMD-97120-DLA-03” having regard to

the definition of agglomeration in the regulations. Provide the name of the

agglomeration and submit a revised map as specified in the application form

with a justification for the boundaries of the agglomeration.

1.1 The definition of “agglomeration” is: “an area where the population or

economic activities or both are sufficiently concentrated for a waste water

works to have been put in place” [Waste Water Discharge (Authorisation)

Regulations 2007, SI 684, Part 1, 3-Interpretation]. The red line on Drawing

No. LMD-97120-DLA-03 marks, as required by the Discharge Licence

Application form, the limit of the agglomeration, i.e. the outer extent of the

sewage collection system, served by the Waste Water Treatment Plant at

Bunlicky, Limerick.

1.2 The agglomeration boundary has been named on the plan and added to the

drawing title. The Cloonlara sub-catchment has been named. The Waste

Water Treatment Plant location has been identified. In the drawing legend,

“Brief Catchment Limit” has been changed to “Agglomeration Boundary”.

Provide an estimate of the existing and the maximum proposed Population

Equivalent (p.e.) contribution from (1) domestic, (2) commercial and (3) trade

effluent sources.

1.3 The estimated existing and proposed Population Equivalent contributions,

based on the Preliminary Report data, are given below. The PR was based on

estimated “existing” PEs for 1996 and the figures below are obtained

assuming a linear increase between 1996 and 2021.

Estimated

Existing PE

Estimated Future

PE (2021)

Domestic 83,400 103,000

Commercial 19,200 18,000

Trade 7,500 9,000

Totals 110,100 130,000

Where planning permission has been granted for development(s), but 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 water work works provide the following:

• information on the calculated population equivalent (p.e.) to be

contributed to the waste water work as a result of those planning

permissions granted,

• the percentage of the projected p.e. to be contributed by the non-

domestic activities, and

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LIMERICK MAIN DRAINAGE: WASTE WATER TREATMENT PLANT DISCHARGE LICENCE APPLICATION

NOTES FOR RESPONSE TO EPA LETTER DATED 4 APRIL 2008


• 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.

1.4 The calculated PE of the developments within the agglomeration for which

planning permission has been granted by Limerick City Council that have not

been commenced or completed to date is 3,700 PE. None of this total is contributed by non-domestic activities.


planning permission has been granted by Limerick County Council that have

not been commenced or completed to date is 10,200 PE of which 29 % is

estimated to be contributed by non-domestic activities.


planning permission has been granted by Clare County Council that have not

been commenced or completed to date is 700 PE of which 8 % is estimated to

be contributed by non-domestic activities.

1.7 The total calculated PE of the developments within the agglomeration for

which planning permission has been granted that have not been commenced

or completed to date is 14,600 PE. The estimated current plant loading is

110,100 PE and the design capacity is 130,000 PE. The Waste Water

Treatment Works, therefore, can accommodate this extra hydraulic and

organic loading without posing an environmental risk to the receiving water

habitat.

Provide further details of the transfer and storage arrangements for

sludge/leachate, the location in the WWTP where the leachate and/or sludge

residues are introduced and the quantity (volume and p.e.), frequency and

rate of addition to the WWTP.

1.8 The location of the sludge plant is shown on Drawings Nos. LMD-97120-DLA-

02, LMD-97120-DLA-05 and LMD-97120-DLA-12.

1.9 The sludge volume imported to the Bunlicky Waste Water Treatment Plant in

2007 was 6,719 m3. This comprised:

• 1,990 m3 liquid at 3 % dry solids

• 4,729 m3 liquid at 11 % dry solids

The total tonnage of dry solids imported and processed was, therefore, 579.7

tonnes

1.10 Liquid and cake sludge are delivered to the plant five days per week with no

deliveries at the weekend. Typical monthly volumes are (for April 2008):

• 647 tonnes cake sludge at 10-12 % dry solids

• 175 tonnes liquid sludge at 3-4 % dry solids

1.11 Septic tank and chemical toilet contents and occasionally leachate are imported to the

Waste Water Treatment Plant on weekdays only. The total volume imported in April 2008 was around 200 m3.

1.12 The design loading of imported sludge is 759 TDS/year, a Population

Equivalent of 26,000. The volume of sludge treated, therefore, represents a

population equivalent of 19,900 PE.

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2 16(1)(e)

Clarify if the data provided in Attachment D1 relates to operation at maximum

design loading or current operation. Provide a comparison of the modelled

discharge parameters (including discharge rate) and the maximum actual

levels being discharged and also those proposed at design/agglomeration

capacity.”

2.1 The data provided relate to current operation and testing of discharges.

2.2 The water quality parameters considered as part of the discharge modelling

exercise at a continuous discharge rate of 0.338 m3/sec (i.e. the modelled dry

weather flow) were:

• Faecal coliform 1x106 No./100 ml

• BOD 25 mg/litre

• Ammonia 20 mg/litre

• Nitrogen 32 mg/litre

2.3 The recorded water quality parameters at the current normal daily discharge

rate of 0.341 m3/sec are:

• Faecal coliform Not tested

• BOD 23 mg/litre (maximum daily average)

• Ammonia 0.11 mg/litre (maximum daily average)

• Nitrogen 12.7 mg/litre (maximum daily average)

3 16(1)(k)

Provide an assessment of the effects (using actual monitoring data) of the

actual discharge on the water quality of the receiving water and outline how it

relates to the predicted discharge and the predicted impact outlines in the EIS.

3.1 The effluent quality parameters modelled for the EIS were:

Faecal coliform - 1x106 No./100 ml

BOD - 25 mg/litre

Ammonia - 20 mg/litre

The discharge rate was specified as 0.338 m3/sec, discharging continuously.

3.2 The water quality standards determined for the project were those set down in

the Shannon Estuary Water quality Management Plan, which complied with all

the relevant European and Irish legislation:

Faecal coliform - 1000 No./100 ml

BOD - 4 mg/litre

Ammonia* - 1 mg/litre N

* This standard (based on the EU freshwater fish directive) applies only to

the freshwater area at the head of the estuary where the assimilation

capacity at certain stages is determined mainly by river flows. There is

not a standard set for the estuary.

3.3 The effect of the discharge was discussed in Section 4.4.3 of the EIS:

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“4.4.3(ii) Chemical effects: Impacts on water quality are more difficult

to predict. The effect of the scheme will be to remove from the

estuary untreated raw sewage discharges from Limerick City and

to concentrate the treated effluent at a single discharge point in

the river, downstream of Bunlicky. The present inputs of

organic matter to the estuary as a whole cannot be shown to

have any appreciable impact on the benthic fauna. All the available evidence suggests that the present inputs have little

effect on the nutrient regime in the estuary. The effluent from

the proposed treatment plant will be treated to secondary level

and will achieve the standards set down in the Water Quality

Management Plan for the Shannon Estuary. A general

improvement in water quality can be expected particularly at

Limerick City and there is no reason to suggest that the

concentration of the (treated) discharges at Bunlicky will have

any significant effect on local water quality in the estuary and,

by implication, on flora and fauna, fisheries and other beneficial

uses.”

3.4 With regard to faecal coliforms, the EIS recorded:

“4.6.11(d)(i) It must firstly be noted that there are no designated bathing

areas along this section of the estuary and therefore the

relevant bacteriological standards set in the Water Quality

Management Plan are not applicable.”

3.5 The overall conclusions of the mathematical modelling of the discharges, as

recorded in the EIS, were:

“4.6.12 The modelling predictions demonstrate that, as a result of the

treated effluent discharge from the proposed Limerick City

Waste Water Treatment Plant at Bunlicky and the elimination of

existing raw sewage discharges, water quality in the Shannon Estuary will comply with the standards set down in the Water

Quality Management Plan which have been adopted for the

Limerick Main Drainage Project.

4.6.13 These predictions are based on conservative effluent

concentrations, decay rates and environmental conditions and

have examined the occurrence of a coincidence of events, Le.

spring tides simultaneously occurring with adverse winds and

99.5% river flows.

4.6.14 With regard to nutrients, the proposed waste water treatment

plant will reduce both nitrogen and phosphorus inputs from the

current population by small amounts, thus reducing the potential

for nutrient enrichment. However, with increased loading on the

treatment plant up to its design capacity, additional amounts of

nitrogen and phosphorus will be discharged. Ongoing monitoring

of this treated effluent and its impact on nutrient levels in the

estuary will be required.

4.6.15 Although there are no bacteriological standards applicable to this

section of the estuary, there will be a significant improvement in

bacteriological water quality thus allowing greater opportunity

for water based recreational activity.”

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3.6 Six observation sites were considered in the modelling exercise:

• The WWTW outfall

• Limerick Docks

• Sarsfield Bridge

• Coonagh Point

• Meelick Rocks

• Scarlet Reach

3.7 Test results from the six sites show that the coliform and ammonia levels are

within the prescribed limits. (The anomalous ammonia reading from the

Abbey River is remote from the discharge point and must be attributable to

another, unknown source.) The BOD results, while being higher than the

model results, are well below the prescribed limit. Their consistency indicates

that background levels are being measured and that the discharge, in line with

the model results, is not having a significant effect on the receiving waters.

The mathematical model data and the latest test results from the sites are:

Low Tide

<2.00

<2.00

<2.00

<2.00

<2.00

<2.00

<2.00

<2.00

9.55

Ammonia (mg/litre)

High Tide

<2.00

Mean Tide 0.16 m

g/l

<2.00

Mean Tide 0.13

<2.00

Mean Tide 0.15

<2.00

Mean Tide 0.99

<2.00

<2.00

Mean Tide 0.18

Mean Tide 0.00

<2.00

<2.00

<2.00

Low Tide

86

21

172

1,666

52

1,439

30

42,991

1,986

26

1,987

41

766

27

133

Coliform

(No./100 m

l)

High Tide

298

582

275

1,972

222

1,512

231

46,102

456

235

1,953

228

1,986

143

387

Low Tide

2

0.04

2

0.26

2

0.14

2

1.31

4

2

0.39

<2

0.67

2

4

BOD (mg/litre)

High Tide

6

0.13

6

0.15

6

0.10

7

1.31

6

6

0.38

6

0.58

6

5

Test 09/04/08

Math. Model

Test 09/04/08

Math. Model

Test 09/04/08

Math. Model

Test 09/04/08

Math. Model

Test 09/04/08

Test 09/04/08

Math. Model

Test 09/04/08

Math. Model

Test 09/04/08

Math. Model

Test 09/04/08

Test 09/04/08

Location

Scarlet Reach

Meelick Rocks

Coonagh Point

WWTW Outfall

Ballinacurra

Creek

Limerick Docks

Sarsfield Bridge

(Low Tide)

Sarsfield Bridge

(High Tide)

Thomond

Bridge

Abbey River

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4 16(1)(l)

Review Section G of the application form to address compliance with Council

Directives and other statutory regulations (including Bathing Water

requirements) and submit additional information as necessary. Provide details

of any correspondence engaged in with the National Parks and Wildlife service

in relation to the likelihood of discharges from the wastewater works having a significant effect on a European site. If any of the discharges are deemed

likely to have a significant effect, an appropriate assessment of the

implications for the designated site in view of the sites conservation objectives

must be carried out and submitted to the Agency.

4.1 No improvements are planned or scheduled at present.

4.2 Section G.1: Dangerous Substances Directive, 2006/11/EC

4.2.1 Analyses of the effluent discharged to the River Shannon are given in

Attachment D.1.

4.2.2 With regard to the permitted limits for List I substances, under Article 4,

Paragraph (b) of Directive 2006/11/EC: “the authorisation shall lay down

emission standards …”.

4.2.3 With regard to the permitted limits for List II substances, under Article 6,

Paragraph 2 of Directive 2006/11/EC: “All discharges … shall require prior

authorisation by the competent authority …”.

4.2.4 In the absence of notification of such limits, the requirement for improvements

cannot be determined.

4.3 Section G.1: Water Framework Directive, 2000/60/EC

4.3.1 Article 10, paragraph 2 of the Directive requires the standard of waste water

discharge to be in accordance with Annex 1B of Council Directive 91/271/EEC.

4.3.2 The required and measured discharge parameters are:

Parameter Appendix 1B

Measured

(Max. Daily

Average)

BOD5 25 mg/l 23 mg/l

COD 125 mg/l 102 mg/l

Suspended solids 35 mg/l 33 mg/l

4.4 Section G.1: Birds Directive, 79/409/EEC

4.4.1 The Environmental Impact Statement recorded two species (common tern and

arctic tern) in the Shannon/Fergus Estuary protected under Annex 1 of the

Birds Directive and no birds that reached the qualifying level for national

importance in the Inner Estuary (i.e. between Corbally (Limerick City) and

Bunlicky).

4.4.2 The evaluation with regard to estuarine birds in the Environmental Impact

Statement (Paragraph 3.4.8) was:

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“The estuary as a whole is of international importance for birds both in winter

and summer. The inner sector of the estuary, between Limerick City and

Bunlicky, is relatively unimportant for birds, largely due to the limited area of

suitable habitat. There is no evidence that the present discharges in Limerick

city have any detrimental effect on the birds of the estuary.”

4.4.3 Since all of the discharges from Limerick City were untreated at the time the assessment was made, it can be concluded that the treated discharges from

the Bunlicky Waste Water Treatment Plant, which treats all of the sewage

produced by the Limerick agglomeration, also will have no detrimental effect

on the birds of the estuary.

4.5 Section G.1: Groundwater Directives, 80/68/EEC and 2006/118/EC

4.5.1 The treated effluent is discharged directly to the River Shannon. There are no

discharges from the plant that could result in contamination of groundwater.

4.5.2 There is no groundwater abstraction in the vicinity of the Waste Water

Treatment Plant.

4.6 Section G.1: Drinking Water Directive, 80/778/EEC

4.6.1 Water is not abstracted for drinking purposes, as defined in Article 2 of the

Directive, either from the Shannon Estuary or from boreholes in the Limerick

area.

4.7 Section G.1: Urban Waste Water Treatment Directive, 91/271/EEC

4.7.1 The discharge from the Waste Water Treatment Plant is subject to secondary

treatment as required by Article 4 of the Directive.

4.7.2 The requirements of Annex 1B and the measured values of the parameters

noted therein are:

Parameter Appendix 1B

Measured

(Max. Daily

Average)

BOD5 25 mg/l 23 mg/l

COD 125 mg/l 102 mg/l

Suspended solids 35 mg/l 33 mg/l

4.7.3 The treated discharge, therefore, is within the prescribed limits.

4.8 Section G.1: Habitats Directive, 92/43/EEC

4.8.1 The Limerick Special Protection Area, which formerly covered the area along

the River Shannon between Ballinacurra Creek and Kilrush, was extended in

2007 to include the area upstream of Ballinacurra Creek as far as Sarsfield Bridge in Limerick City.

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4.9 Section G.1: Bathing Water Quality Directive, 76,160/EEC

4.9.1 There are no designated bathing areas along this section of the estuary and

therefore the relevant bacteriological standards set in the Water Quality

Management Plan are not applicable.

4.10 National Parks and Wildlife Service

4.10.1 A conclusion of the Environmental Impact Statement, at Paragraph 4.4.3(ii),

was: “… The effluent from the proposed treatment plant will be treated to

secondary level and will achieve the standards set down in the Water Quality

Management Plan for the Shannon Estuary. A general improvement in water

quality can be expected particularly at Limerick City and there is no reason to

suggest that the concentration of the (treated) discharges at Bunlicky will

have any significant effect on local water quality in the estuary and, by

implication, on flora and fauna, fisheries and other beneficial uses.”

4.10.2 Discussions were held with the National Parks and Wildlife Service during the

design phase of the Works and a licence was obtained, and renewed each year

until construction was complete, in respect of possible disturbance to

Triangular Club Rush (Scirpus Triqueter).

4.10.3 In view of the conclusion of the Environmental Impact Statement and the

water quality monitoring data, no further correspondence has been entered

into with the National Parks and Wildlife Service.

5 16(1)(n)

Provide further details (if relevant) in relation to any specific works, schedules

and timeframes to provide outstanding connections to the wastewater works

for the agglomeration.

6.1 There are no connections to the Waste Water Treatment Plant for the

agglomeration outstanding.

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Tel:

Fax:

Email:

HC/ HC/

I I

DLH DLH

KMcI KMcI

6175

2371

Day 11 18

Month 12 06

Year 07 08

97120 - DLA - 01 A

97120 - DLA - 02 A

97120 - DLA - 03 A B

97120 - DLA - 04 A

97120 - DLA - 05 A

97120 - DLA - 06 A

97120 - DLA - 07 A

97120 - DLA - 08 A

97120 - DLA - 09 A

97120 - DLA - 10 A

97120 - DLA - 11 A

97120 - DLA - 12 A

97120 - DLA - 13 A

97120 - DLA - 14 A

97120 - DLA - 15 A

97120 - DLA - 16

- -

- -

- -

- -

- -

- -

- -

- -

- -

- -

- -

- -

- -

- -

- -

- -

-

-

-

-

-

TED and Storm Overflow Locations

Possible Future Connections

Works Process Diagrams

Site Plan

Site Location Plan

Site Plan

Agglomeration Boundary

Outfall Discharge Point Details

ING Location of WWTP and Outfall Discharge

WWTP Monitoring Points

Outfall Discharge Point Details

TED and Storm Overflow Locations

Public Notice Display

Discharge Sampling Point

C:Construction I:Information A:Approval

ISSUED BY:

CHECKED BY:

CORRESPONDENCE NUMBER:

- - -

- - -

-

- - -

- -

Main Contractor: - -

Other: - -

-

Architect: -

Quantity Surveyor: - -

CLIENT:

PROJECT NO.: 97120

LIMERICK CITY COUNCIL FILE REF: 97120/32

J. B. Barry & Partners Ltd

CIVIL DRAWING TRANSMITTAL RECORD

32 Dartry Road +353 (1) 497 5886 PROJECT TITLE: LMD WWTW DISCHARGE LICENCE

-

Consulting Engineers

Tramway House +353 (1) 497 5716

[email protected] 6

-

M&E Consultant: -

ISSUED TO: Company Contact

LIMERICK CITY COUNCIL Seamus RyanClient:

-

-

-

-

-

-

-

-

WWTP Monitoring and Sampling Points

-

-

Sampling Points

NUMBER OF COPIES

DATE OF ISSUE:

DWG NUMBER DRAWING TITLE DRAWING REVISION

E:Email HC:Hard Copy CD:CD E'net:Extranet TRANS FORMAT:

P:Planning T:Tender Pr:Progress TRANS PURPOSE:

P:\97 Projects\97120 - LMD Project Man\Civil-Eng\Discharge Licence Application\Drawings\97120 Outgoing Drawings Register.xls

Sheet 1 of 1

Printed on 18/06/2008

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This drawing and any design hereon is the copyright of the

All drawings remain the property of the Consultants.

Copyrightc

Consulting Engineers:

THE EUROPEAN COMMUNITIESFROM THE COHESION FUND OF

Project:

Revisions:

Client:

By:

80% FINANCIAL ASSISTANCE

THIS PROJECT IS RECEIVING

Date: Rev.:

Scales: Date:

Project Office:

Drawing. No.:

Revision:

Stage:

Title:

Drawn By:

Approved By:

Checked By:

Consultants and must not be reproduced without their written consent

LIMERICK CITY COUNCIL


(City & Environs)

Tel: 353-61-484580

Fax: 353-61-484581

E-Mail: [email protected]

5

kilometres

2.50

LMD-97120-DLA-03

WASTE WATER TREATMENT PLANT


AGGLOMERATION BOUNDARY

F.N.

K.McI

SEPT.20071:25,000@A1 1:50,000@A3

N

LEGEND:

TRUNK SEWERS

COLLECTOR SEWERS

AGGLOMERATION BOUNDARY

COUNTY BOUNDARY

SUB-CATCHMENTS BOUNDARY

INTERCEPTOR SEWER

BOROUGH BOUNDARY

ZONED RESIDENTIALBUT NOT DEVELOPED

ZONED INDUSTRIAL.

ZONED COMMERCIAL.

ZONED INSTITUTIONAL.

ZONED OPEN SPACE BUTPOSSIBLE FUTURE RESIDENTIAL

ZONED GENERAL PURPOSE BUTPOSSIBLE FUTURE RESIDENTIAL

NORTHERN INTERCEPTOR SEWER

SUB-CATCHMENT

INNER-SOUTHERN INTERCEPTOR SEWER

SUB-CATCHMENT

SOUTHERN INTERCEPTOR SEWER

SUB-CATCHMENT

COUNTY CLARE

COUNTY LIMERICK

COUNTY LIMERICK

Limerick Main Drainage Project Office,

Limerick Business Centre

Raheen Business Park

Raheen, Limerick

Pat DromeyDirector of Transportation & InfrastructureLimerick City CouncilCity HallLimerick.

Ordnance Survey of Ireland Licence No.EN 0003008© Government of Ireland

All Maps are Referenced to Irish National Grid (I.N.G.)

All Levels are in Metres and Relate to O.S. Datum Malin

P:\97 Projects\97120 - LMD Project Man\Civil-Eng\Discharge Licence Application\Drawings

16/05/2008

.

DISCHARGE LICENCE APPLICATION

D.L.H.

A

DISCHARGE LICENCE APPLICATION F.N. SEPT. '07 A

WASTE WATER

TREATMENT PLANT

BOUNDARY OF


AGGLOMERATION

CLOONLARA

SUB-CATCHMENT

B

LABEL & TITLE REVISION F.N. BMay'08

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