Regulatory Impact Analysis of the proposed Surface Water ...€¦ · all waters with the primary...

Regulatory Impact Analysis of the proposed Surface Water Classification Systems including Environmental Quality Standards

Final Report

December 2007 www.erm.com

Delivering sustainable solutions in a more competitive world

Environmental Protection Agency

Regulatory Impact Analysis of the proposed Surface Water Classification Systems including Environmental Quality Standards

December 2007

Prepared by: Thomas McCarthy. Assisted by Sheila Duggan, Joanne McCarthy and Aoife Lambe

For and on behalf of Environmental Resources Management Approved by: Gerard Kelly

Signed: Position: Managing Partner Date: 21/12/2007

This report has been prepared by Environmental Resources Management, the trading name of ERM Environmental Resources Management Ireland Limited, with all reasonable skill, care and diligence within the terms of the Contract with the client, incorporating our General Terms and Conditions of Business and taking account of the resources devoted to it by agreement with the client. We disclaim any responsibility to the client and others in respect of any matters outside the scope of the above. This report is confidential to the client and we accept no responsibility of whatsoever nature to third parties to whom this report, or any part thereof, is made known. Any such party relies on the report at their own risk.

NON – TECHNICAL SUMMARY

INTRODUCTION

In 2000 the European Parliament and Council adopted Directive 2000/60/EC. This Directive established a framework for Community action in relation to water policy. This is commonly known as the Water Framework Directive (WFD). Irish legislation which brought this Directive into existence in Ireland is the European Communities (Water Policy) Regulations 2003 (S.I. No. 722 of 2003). The Directive establishes the legal framework for the protection, improvement and sustainable use of surface waters, transitional waters, coastal waters and groundwater throughout the Member States. The Water Framework Directive requires all Member States to implement the necessary measures to prevent deterioration of the status of all waters (surface, ground, estuarine and coastal) and to protect, enhance and restore all waters with the primary aim of achieving “good status” of all waters by 2015. “Good surface water status” means the status achieved by a surface water-body when both its ecological status and its chemical status are at least “good” as set out in the WFD Surface Water Classification Systems (1). The Environmental Protection Agency (EPA) has responsibility for the establishment of a classification system and environmental quality standards (EQS) for surface waters. The Department of the Environment, Heritage and Local Government has prepared a draft of the proposed Surface Water Classification Regulations including Environmental Quality Standards to satisfy these responsibilities. In accordance with the criteria specified in the Regulatory Impact Analysis (RIA) Guidelines, issued by the Department of the Taoiseach in October 2005, the EPA requires a RIA to be conducted to assess the likely effects of the proposed classification systems. The RIA specifically looks at General Components (physico-chemical), Priority Substances and Specific Relevant Pollutants. The EPA commissioned ERM Environmental Resources Management Ireland Ltd (ERM Ireland) in partnership with Mott MacDonald Pettit, to undertake a full RIA on the proposed Surface Water Classification Regulations including Environmental Quality Standards. The initial screening RIA was completed in July of this year (2007). The completion of this RIA is being overseen by a Steering Group which includes representatives of the EPA and the Department of the Environment, Heritage and Local Government (the Department). The Report is divided into the following sections: Section 2 of the RIA describes the current situation as it exists in Ireland, the national policy in relation to the WFD, the objectives of the proposed Regulations and how the classification system is to work. An overview of the current status of water quality in Ireland is then outlined and a description of the current classification system is outlined to allow a comparison with the proposed system. Existing control (1) http://www.waterframeworkdirective.wdd.moa.gov.cy/docs/GuidanceDocuments/PolicySummary/REFCONDPolicySummary.pdf

mechanisms for both point and diffuse sources are described, including the relevant legislation and the primary organisations involved in their enforcement. Section 3 outlines the options to be considered in the RIA. The Economic, Environmental and Social impacts which are presented in Section 4 are based upon the three scenarios outlined in Section 3. Based upon the RIA Guidelines, three scenarios are assessed within the report:

1. The ‘do nothing’ or ‘no policy change’ option – in this scenario it is assumed that the proposed Regulations are not enacted and the Government relies upon the existing regulations, as set out in Section 2.5.2, to control point and diffuse sources of pollution and ultimately achieve “Good surface water status”;

2. A reliance on voluntary reductions – in this scenario it is assumed that a voluntary scheme will be developed to achieve “Good surface water status”. This will require all stakeholders (industries, state bodies, local authorities etc.) to implement voluntary reductions in the use of, and concentrations of, substances discharged to meet the EQS levels; and

3. Full implementation of proposed Regulations – this scenario assumes that the proposed Regulations are implemented fully. The impact assessment concentrates on this option as it is considered the most likely scenario to be implemented and will require the most significant investment by the stakeholders to achieve the EQS.

Section 4 of the report outlines the, Economic, Environmental and Social Impacts, of the proposed Regulations in the case of each option. Section 5 of the report summaries the consultation process undertaken during the course of the Full RIA. Section 6 and 7 of the report summarises the implications that the proposed Regulations are likely to have on the institutional structures entrusted with their enforcement and the recommended actions to be taken to ensure that the Regulations are effective in their implementation. This RIA is restricted to the General Components (physico-chemical) (No. 8), Priority Substances (No. 33), Other Pollutants (No. 8) and Relevant Specific Pollutants (No. 18). Priority Substances (PS), and Priority Hazardous Substances (PHS) are defined as follows in the WFD: • "Priority substances" means substances identified in accordance with Article

16(2) and listed in Annex X. • Among these substances there are "priority hazardous substances" which means

substances identified in accordance with Article 16(3) and (6) for which measures have to be taken in accordance with Article 16(1) and (8).

• “Hazardous substances" means substances or groups of substances that are toxic, persistent and liable to bio-accumulate, and other substances or groups of substances which give rise to an equivalent level of concern.

South Western River Basin District has issued a document entitled “Significant Water Management Issues, Dangerous Substances Usage (“Bottom up Study”), Background Document”. The document states that the definition of “Dangerous Substances” incorporates all of the following groups and was adopted from the Discussion Document produced by the National Dangerous Substances Expert Group:

• Priority Substances are substances identified in accordance with WFD Article 16(2) and listed in Annex X (33 Substances).

• Among these substances there are ‘priority hazardous substances’ which means substances identified in accordance with WFD Article 16(3) and (6) for which measures have to be taken in accordance with Article 16(1) and (8).

• Relevant Pollutants are specific synthetic and non synthetic substances (not on priority action list) whose presence may lead to a risk of failing the objectives of the WFD.

Under Article 1(c) of the WFD, "specific measures for the progressive reduction of discharges, emissions and losses of priority substances (PS)" are to be implemented. For the priority hazardous substances (PHS), discharges, emissions and losses are to be stopped or phased out within 20 years after the measures cited have been adopted at Community level. SUMMARY OF IMPACT ASSESSMENT

The impact assessment looks at the all three scenarios outlined above. Scenario 1 and 2 outlined above are not considered likely to be implemented and the most significant costs are associated with Scenario 3. Therefore, a summary of the Economic, Environmental and Social findings for Scenario 3 is briefly presented. The proposed EQS will require significant investment from both the public and private sectors. These costs are associated will result from the requirement for capital investment on infrastructure, on-going expenditure on the operation of these facilities and resource allocation for monitoring and enforcement of the EQS. Not all costs associated with the implementation of the Regulations could be estimated, but these areas are still identified. Given the complexity in the design and costing of the infrastructural investment a “worst case” approach was taken in the calculation of the costs. Summary of Economic Costs Sector Cost Due to Amount € Municipal WWTP - Priority Substance Removal

Capital Cost 211,757,489

Operational Cost per annum 13,500,000 Municipal WWTP - Ammonia – All WWTP

Whole life costs – 30yr capital costs plus operational costs

9,000,000

Municipal WWTP - Ammonia – 39% of WWTP


2,300,000

Municipal WWTP -Phosphorous – All WWTP


6,000,000

Municipal WWTP -Phosphorous – 41% WWTP


3,700,000

IPC/IPPC whole life costs per annum (15yrs)

Treatment of discharges directly to waters

40,000 – 4,200,000


Treatment of discharges directly to sewers

90,000 – 4,200,000

Administration - Local authorities – County, City and Borough Councils

Administrative costs first two years

4,485,000 – 13,650,000

On-going annual administrative costs

10,725,000

Sector Cost Due to Amount € Septic Tanks - Local authorities or central government

Septic Tank Remediation 975,310,000 – 3 billion

Septic Tanks - Local authorities or central government

Proprietary systems 158,438,000 -205,716,000

Mines – local authorities or central government

Remediation – capital investment

96,336,000


Remediation – annual operational costs

13,554,000

The following topics are identified as likely to cause potential additional costs but accurate figures could not be calculated due to uncertainties around what work has to be completed in each area:

• Combined Sewer Overflows upgrading; • Impact on agriculture, aquaculture and forestry; • Section 4 and 16 industries – provision of on-site treatment systems; • Sludge management; • Road run-off treatment; • Monitoring costs including laboratory costs; and • Treatment of ammonium releases during peat extraction.

The main environmental and social benefits will include the improvement in water quality and associated positive impacts for all users, including industry, tourism and recreation and the protection and improvement of our aquatic and marine environments. Water treatment plants may also experience improvements in operation and resulting reduction in treatment cost. Improved water supply may also lead to reduced monitoring requirements and additional cost savings for regulatory authorities. Specifically within the ERBD, as it is the most densely populated RBD in Ireland, one of the most significant potential benefits from compliance with the EQS is to improve water status with the reduction of exposure to dangerous substances. For WWTPs and groups involved in sludge management, compliance with the EQS should eventually (and indirectly) result in a reduction in the presence of pollutants in the treatment processes through source control measures. This may lead to more disposal options becoming available in the longer term, as sludge may become less contaminated as Priority Hazardous Substances are eliminated from the waste water stream. Use of the sludge as soil improvers on agricultural land could increase, with concurrent reduction in the accumulation of pollutants in the ground, crops, livestock, etc. Alternatively, if source control is not successful, treatment within WWTPs could result in sludge with higher concentrations of pollutants resulting in higher disposal costs and fewer disposal options. With agriculture and food production being such an important industry in Ireland, the benefits associated with EQS compliance include a reduced accumulation of pollutants in meat and milk through livestock watering, and in crops through irrigation, with subsequent reduction in human exposure to hazardous compounds. For the fisheries industry, the positive benefits should include improved productivity (fewer deaths/healthier animals) in water bodies and increased fish stocks and variety

of stocks with subsequent increased revenues due to improved water quality. There should also be a reduction in the accumulation of pollutants in fish, with a subsequent reduction in human exposure to these pollutants. Areas used for shell-fishing should also experience a reduction in algae blooms, loss of stock and subsequent increase in revenue. RECOMMENDATIONS

The following recommendations are made following consideration of the findings presented within the RIA. Recommendations have been grouped to assist in the identification of where further actions need to be taken. Option Selection 1) The full implementation of the proposed Surface Water Classification Regulations

including Environmental Quality Standards is recommended, as either of the other options would be contrary to Government policy and non-compliant with EU law. Failure to implement the Regulations is likely to result in fines being imposed on Ireland by the EU and the attainment of water quality of good status is unlikely to be achieved.

Local Authority Functions 2) As the local authorities are likely to be the key implementing bodies, there is an

immediate need to establish a consultation process with the County and City Managers Association in regard to the implications for the authorities for resources and systems. Concern has to be noted in regard to the role the authorities will play following completion of the work of the existing River Basin District projects.

3) As implementing bodies the local authorities will need to put in place a more robust management system for Section 4 and 16 licensing than is currently in place. The authorities will need to also apply a more robust operational regime in their management of waste water treatment facilities and municipal waste management facilities. This will require a greater allocation of trained staff and the introduction of comprehensive monitoring systems to ensure the authorities meet their statutory obligations. There is little point in implementing a regulatory framework in the absence of having adequate resources available to the implementing authorities as is evidently the case in regard to the current framework. It is recommended, therefore, that an immediate audit of current capacity of staff and other resources be undertaken to facilitate the completion of a needs analysis arising from the requirements of the proposed Regulations. The needs analysis should set out, on an authority by authority basis, the full staff and financial resources available to the authorities to implement the existing regulatory framework and the expected needs arising from the proposed Regulations. The analysis should also set out the actual requirements for capacity and resoucing to appropriately implement the existing framework, and the expected needs arising from the proposed Regulations. The gap in capacities and resources should then be fully set out in order to determine the real resource needs of the authorities in regard to their current and future statutory role. This identified gap should then be translated into the deficit in financial resources arising for local authorities as a result of the existing regulatory and proposed regulatory framework, and this should be the basis for consideration of the allocation of extra resources, on the part of the Department of the Environment, Heritage and Local Government and the Department of Finance.

4) The implementation of the proposed Regulations will require specific consideration by the corporate planning structures of the local authorities given the potential cross departmental impact of the proposed Regulations including

planning, housing, environmental and infrastructural services and the possible resistance to their implementation by local elected representatives;

5) Planning sections within the local authorities should have to take the treatment of wastewaste into consideration requiring, for example, WWTPs to be built in advance of or in parallel with any future development. This approach needs to be implemented during strategic development planning and carried through to the assessment of individual planning applications.

6) Future planning for waste water collection and treatment may have to consider the collection and treatment of CSO discharges.

7) Costs incurred in the construction and refit of WWTPs, should be passed back, where possible, onto the industries and sectors that discharge to the sewers. This could be achieved through the existing mechanism of the Water Services Pricing Policy.

8) The control of the Section 4 and 16 emissions requires more stringent monitoring and a more detailed consistent application across the State. Local authorities should undertake an audit of their Section 4 and 16 licences to ensure that all emissions to sewer and surface water are being appropriately licensed and policed.

Septic Tanks 9) Maintenance of proprietary treatment systems is vital for their continuing

effective running of one off housing effluent treatment systems. A comprehensive state wide audit of the up-take of maintenance agreements for such systems should be completed to determine the extent of non maintenance and their location. This information should be used to assess the need for and focus any scheme considered to be necessary to up-grade existing on site wastewater treatment systems.

10) A succinct guidance document drawing together the principle features of waste water related regulation should be prepared and local authority staff trained in regard to its application.

11) The current reference document for the installation of septic tanks in one off developments is SR6: Septic Tank Systems: Recommendations for Domestic Effluent Treatment and Disposal from a Single Dwelling House. This is to be replaced by EN 12566 - Small wastewater treatment systems for up to 50 PT. Prefabricated septic tanks. The Department of Environment, Heritage and Local Government must ensure that clear instruction is provided to the local authorities in the use of EN 12566 and the status of the EPA draft “Code of Practice: Waste Water Treatment Systems for Single Houses”. Specific guidelines in regard to the local authority as a planning authority may also be required having regard to the provisions of the existing Departmental guidance on rural housing.

Environmental Protection Agency 12) Once the Regulations have been finalised the EPA should assess the Regulations

to determine the implications on the ELVs of IPPC installations and Waste licensed facilities, to ensure that they can and will meet the new EQS.

13) The RIA process had identified that the level of enforcement of Section 4 and 16 licences, and the level of knowledge of sources of emissions and their characteristics, varies significantly between local authorities. The level of resources available and the licensing and enforcement systems within the local authorities may not have the capacity to implement the level of control required to achieve the EQS. This gap in understanding the current position must, as a matter of urgency, be addressed by completion of a comprehensive audit of such licences in each local authority.

14) The EPA should continually review the costs and assumptions applied within this RIA, to ensure that the economic impacts identified on the various

stakeholders, public and private, from the implementation of the proposed Regulations are kept up to date. This review will allow for the effective management of investment and planning by central and local government.

15) EQS relating to metals may also require background levels to be established for all water bodies to be monitored. This function is likely to sit best within the monitoring programme currently being operated by the EPA.

Research, Studies and Guidance Advice 16) Detailed characterization studies of Irish municipal WWTP should be a

requirement of the incoming licensing regime for such treatment facilities. 17) The renewal and updating of existing Section 16 licences (and those of Section 4)

and enforcement of licence conditions, is inconsistent around the country. Having regard for Section 63 of the Water Services Act 2006 a set of guidelines to underpin a nationwide system of consistent enforcement should be considered by the Department.

18) Guidance for Sectors, including agriculture, water industry and industrial facilities, discharging to receiving waters as a consequence of diffuse run-off, will be required to enable such sectors to take action to reduce discharges.

19) Municipal WWTPs should be required to monitor Priority Substances or Specific Relevant Pollutants and that data is made available to determine the loads of these substances discharging from the plants into the receiving water. This information while collected by the water services section needs to be provided to and taken into consideration by, the planning sections of local authorities.

20) The levels or sources of dangerous substances being discharged to local authority collection systems should be studied to determine their impact on the treatment regimes managed by local authorities.

21) Additional work is also required in relation to the development of a pilot plant (and further assessment is recommended) with regard to the treatment of metals as set out in Section 4 (pg 28) of this RIA.

22) In regard to landfill sites the treatment process and relevant costs will need to be identified for each landfill individually. The impact of treating landfill leachate at source would need to be assessed and compared to continuing of treatment at a WWTP. Due to the lack of adequate information and potential variability of leachate it is not possible to provide meaningful costs associated with this source. This gap in information needs to be addressed.

23) It should be determined if the EPA ERTDI programme is an appropriate vehicle to advance the research recommended in this RIA to close out the gaps in information required to fully consider the impact of these Regulations.

Other Issues 24) Additional maintenance of the road run off systems once installed would need to

be carried out. This is not currently being done, mainly due to lack of resources. Moving forward this may require additional resources to be allocated by the local authorities and NRA.

25) There is a need to ensure that there is sufficient capacity in monitoring laboratories through out the State to ensure a robust system can be put in place. The volume of monitoring likely to be required due to the implementation of these Regulations and other recent Regulations is likely to place significant pressure on laboratory resources across Europe.

26) Clarification needs to be sought in relation to the issue of naturally occurring background levels for metals which exceed the EQS. The monitoring to be carried out for recommendation 15 should feed into this process. Further clarification is also required around the issue of percentile flow in rivers and EQS, and mixing zones around fin-fish farming.

CONTENTS

1 INTRODUCTION 1

1.1 BACKGROUND 1 1.2 RIA OBJECTIVES 2 1.3 METHODOLOGY 2 1.4 ACKNOWLEDGEMENTS 4

2 STATEMENT OF POLICY, CONTEXT, OBJECTIVES AND CASE 5

2.1 INTRODUCTION 5 2.2 DESCRIPTION OF POLICY CONTEXT 5 2.3 DESCRIPTION OF OBJECTIVES 7 2.4 PROPOSED CLASSIFICATION REGULATIONS 7 2.5 AN OVERVIEW OF IRELAND’S SURFACE WATER RESOURCES 9

3 OPTIONS 18

3.1 INTRODUCTION 18

4 IMPACT ANALYSIS 22

4.1 INTRODUCTION 22 4.2 NATIONAL DANGEROUS SUBSTANCES SCREENING PROGRAM 22 4.3 SECTORS AND GROUPS AFFECTED 24 4.4 ECONOMIC IMPACT 25 4.5 ENVIRONMENTAL IMPACT 52 4.6 SOCIAL IMPACT 54 4.7 SUMMARY OF IMPACTS 56

5 CONSULTATION 60

5.1 INTRODUCTION 60

6 INSTITUTIONAL REQUIREMENTS, ENFORCEMENT AND COMPLIANCE63

6.1 INTRODUCTION 63 6.2 INSTITUTIONAL APPLICATIONS 63 6.3 ENFORCEMENT 64 6.4 COMPLIANCE 65 6.5 SUMMARY 66

7 RECOMMENDATIONS 67

8 GLOSSARY OF TERMS 70

1 INTRODUCTION

1.1 BACKGROUND

The Water Framework Directive (WFD), (Directive 2000/60/EC establishing a framework for Community action in the field of water policy), was formally adopted by the European Parliament and Council in October 2000. The Directive establishes the legal framework for the protection, improvement and sustainable use of surface waters, transitional waters, coastal waters and groundwater throughout the Member States. The Directive was transposed into Irish legislation through the European Communities (Water Policy) Regulations 2003 (S.I. No. 722 of 2003). The Water Framework Directive requires all Member States to implement the necessary measures to prevent deterioration of the status of all waters (surface, ground, estuarine and coastal) and to protect, enhance and restore all waters with the primary aim of achieving “good status” of all waters by 2015. “Good surface water status” means the status achieved by a surface water-body when both its ecological status and its chemical status are at least “good” as set out in the WFD Surface Water Classification Systems (1). Under Article 9 of the Water Policy Regulations, the Environmental Protection Agency (EPA) has responsibility for the establishment of a classification system and environmental quality standards (EQS) for surface waters. The Department of the Environment, Heritage and Local Government (DEHLG) has prepared a draft of the proposed Surface Water Classification Regulations including Environmental Quality Standards. In accordance with the criteria specified in the Regulatory Impact Analysis (RIA) Guidelines, issued by the Department of the Taoiseach in October 2005, the EPA requires a RIA to be conducted to assess the likely effects of the proposed classification systems, specifically looking at General Components (physico-chemical), Priority Substances and Specific Relevant Pollutants. The EPA commissioned ERM Environmental Resources Management Ireland Ltd (ERM Ireland) in partnership with Mott MacDonald Pettit, to undertake a full RIA on the proposed Surface Water Classification Systems including Environmental Quality Standards. The initial screening RIA was completed in July of this year (2007). The completion of this RIA is being overseen by a Steering Group which includes representatives of the EPA and the Department of the Environment, Heritage and Local Government (the Department). The RIA focuses on the proposed Regulations and EQS as presented by the EPA. Discussions as to the technical appropriateness of the standards on a scientific basis, while noted within the consultation process, were not the focus of the RIA. A separate technical committee, including representatives from the Department and the EPA, is reviewing the technical merits of the proposed EQS. Any comments of a technical

(1) http://www.waterframeworkdirective.wdd.moa.gov.cy/docs/GuidanceDocuments/PolicySummary/REFCONDPolicySummary.pdf

ERM ENVIRONMENTAL RESOURCES MANAGEMENT FINAL REPORT 2007 FULL RIA FOR SURFACE WATER

1

nature that were received in the course of the drafting of the RIA were communicated to that committee.

1.2 RIA OBJECTIVES

The main objectives in commissioning this full RIA were as follows: • To undertake a full RIA of the effects of implementation of the proposed Surface

Water Classification Systems and proposed Environmental Quality Standards in Ireland, specifically looking at General Components (physico-chemical), Priority Substances and Specific Relevant Pollutants;

• Once completed, to expand on the outcomes from the Screening RIA providing more extensive and detailed evaluation of the proposed identified key points for consideration; and

• To summarise the findings of the consultation process on the classification system. This was carried out by the EPA between September and October 2007.

1.3 METHODOLOGY

The Full RIA was carried out over a 13 week period between 1st August 2007 and 26th October 2007. A Screening RIA was prepared prior to this over a four week period between 5th June and 29th June 2007. Based on the outcome of the Screening Report, the EPA determined that the conduct of a Full RIA was appropriate. The completion date for the Full RIA was set by the EPA to coincide with the completion of the public consultation on the classification system, at the end of October 2007, and prior to their submitting recommendations to the Minister for the Environment, Heritage and Local Government on the making of Regulations in early 2008. Submissions from the consultation process were reviewed and the resulting findings incorporated into this Full RIA. The Full RIA Report is in effect a review and refinement of the findings of the Screening Report. The structure and approach of both assessment programmes is similar, and the format of the Full RIA closely mirrors that of the Screening Report. The approach to the RIA included: • A description of the nature of the surface water classification system and EQS,

and development of an understanding of their significance within the Irish context (refer to Section 2.1);

• Review of the formal consultation process, undertaken by the EPA, with Government and regulatory agency stakeholders, NGO’s and the public (refer to Section 5);

• Structured presentation and consideration of reasonable options (refer to Section 3);

• Identification and where possible, quantification of impacts (refer to Section 4);

• Consideration of enforcement and compliance issues (refer to Section 6); and

• The determination of appropriate recommendations (refer to Section 7). This RIA was conducted in accordance with The RIA Guidelines – How to Conduct a Regulatory Impact Analysis, issued by the Department of the Taoiseach in October 2005. The RIA also incorporates recommendations, made by the consultants, (Section 7),


2

which were discussed by the Steering Group during the course of the completion of the RIA.

1.3.1 General Approach Taken

The RIA addresses the proposed Regulations on Surface Water Classification including Environmental Quality Standards to be applied to assess water quality in Ireland. It is based on data derived from the predefined river basin districts (RBDs), and the body of work completed to date in the recognition and implementation of the WFD requirements. The National Characterisation Report (NCR) was submitted to the EU Commission in March 2005 as part of the implementation of the WFD, and represents the main body of technical information reviewed as part of the RIA. The NCR describes the RBDs within Ireland and provides an analysis of the characteristics of the RBDs, a review of the impact of human activity on the status of the water bodies and an economic analysis of existing water use. There are seven basin districts in total, four national and three international (which are shared with Northern Ireland). Risk assessments were utilised in the preparation of the NCR, to determine baseline data regarding human pressures and impact(s) on the water bodies. The Assessments can be broadly divided into four categories as follows; • Point source impacts - these result from discharges that can be traced back to a

specific point e.g. an outlet from a Waste Water Treatment Plant (WWTP), or a licensed discharge point;

• Diffuse source impacts - these result from discharges over a broad area and may be associated with specific activities e.g. the application of fertiliser or pesticides, run-off from roads etc;

• Hydrological impacts - activities that impact on the hydrological characteristics of the water body e.g. abstraction; and

• Morphological impacts - associated with the physical changing of the water body e.g. the construction of flood defences, dams, locks etc.

The risk assessment data provided critical information, (as presented in Section 4) in identifying the primary sources of human impact within each RBD. Of most relevance for the purpose of the RIA, are the waters assessed as being ‘at risk’ (i.e. they may not comply with the criteria to meet ‘good status’ by 2015, unless measures are taken in the meantime) or, ‘probably at risk’ (1). Preparation of the NCR involved extensive collaboration with relevant parties, public authorities and other various stakeholders, in the collation of existing datasets and in the generation of new datasets through commissioned work and research programmes. The majority of the information presented in Section 4 is abstracted from the NCR background information and EPA datasets. Background information and additional data generated by the competent authority for each RBD was also reviewed. For the most part, the RBD information reflected the National Characterisation Report information.

(1) Water bodies at significant risk, identifies water bodies for which consideration of appropriate measures to improve status can start as soon as practical. Water bodies probably at significant risk but for which further information will be needed to confirm that this view is correct. A more detailed characterisation of these waters would allow a better risk assessment to be completed, to determine whether or not the water bodies in this category are at significant risk.


3

As part of the implementation of the WFD in Ireland, a National Dangerous Substances Expert Group was established to design an appropriate screening programme and assist in the development of the EQS for surface waters. As part of that screening programme, an 18 month monitoring programme was conducted on selected water bodies, to assess the relevance of all the candidate parameters in the Irish context and compile data for establishing the EQS. In general, the water bodies were selected to represent potentially worst case surface water bodies. Such bodies typically display a number of characteristics associated with human impact (e.g. from major towns, licensed discharge points, mining, forestry, agricultural activities etc.). The monitoring results were reviewed as part of this process, and are also detailed in Section 4, for the relevant RBD. This monitoring data was also utilised in the preparation of cost estimates.

1.3.2 Considerations in Cost Impact Analysis

The activities that will be most affected by the proposed Regulations pertaining to the classification system for surface waters are listed in Section 4.2. Not all of these activities will be affected to the same degree from an economic perspective. Some activities will secure benefits, while some will incur costs. The most significant costs, will be borne by those who will be required to implement measures to cease or reduce the discharge of specific pollutants to achieve or maintain the relevant environmental quality standards (EQS). Such activities may include discharges from waste water treatment plants operated by either the public or private sectors. It is extremely difficult to accurately predict the economic impact on the various stakeholders resulting from the Regulations. There are many variables which need to be determined for each activity in order to estimate the costs. In most cases, this information is not available and hence it is only possible to provide indicative costs based on broad assumptions. In Section 4.3 the basis for cost estimates is discussed including how the order of magnitude costs were derived. The costs identified may or may not occur in certain circumstances, and may occur to greater or lesser degrees. The costs highlight areas of potential economic impacts, the magnitude of which will depend on more detailed information becoming available.

1.4 ACKNOWLEDGEMENTS

The cooperation of all stakeholders involved in providing input to the preparation of this RIA is acknowledged. The analysis could not have been completed without their contributions and capacity to prioritise the information requests arising from the analysis. A full list of stakeholders is provided in Section 5.


4

2 STATEMENT OF POLICY, CONTEXT, OBJECTIVES AND CASE

2.1 INTRODUCTION

In recent years, considerable progress has been made in Ireland in developing the legal and institutional arrangements to address the broad objectives of the Water Framework Directive (2000/60/EC). This is expected to enable the Country to meet its obligations with regard to the comprehensive management of the State’s water resources. The policy framework is in addition to the implementation of the Directive through the European Communities (Water Policy) Regulations 2003, (S.I. No. 722 of 2003).

2.2 DESCRIPTION OF POLICY CONTEXT

In broad terms the WFD seeks to: • Prevent further deterioration and protect and enhance the status of aquatic

ecosystems, and terrestrial ecosystems and wetlands directly depending on aquatic ecosystems;

• Promote the sustainable use of water based on the long term protection of water resources;

• Provide enhanced protection and improvement of the aquatic environment by having in place measures to progressively reduce or cease emissions, discharges and losses of priority substances;

• Ensure the progressive reduction of the pollution of groundwater and prevention of its further pollution;

• Mitigate flooding and droughts and thus contribute to the provision of a sufficient, sustainable water resource.

Generally, the Directive is seeking a significant reduction in the pollution levels of Europe’s water resources for both fresh and marine waters. This will result in the improvement of our aquatic environment, but more importantly will increase protection of human health. Article 16 of the WFD sets out a strategy against the pollution of water and outlines the steps to be taken to achieve this. The first step of the strategy required the establishment, by the EU Commission, of a list of priority substances to become Annex X of the WFD. ‘Priority substances’ are chemical pollutants identified as being of major concern in surface waters throughout the EU, as a result of their widespread use and high concentrations in rivers, lakes and coastal waters. Furthermore, there is a subset of ‘priority hazardous substances’ requiring more stringent environmental objectives due to their high persistence, bioaccumulation and toxicity. These will be subject to stricter control measures e.g. cessation or phasing out of discharges, emissions and losses, within an appropriate timetable not to exceed 20 years. In addition to the priority substances, Member States are required to identify other chemical pollutants which impede the aims of the WFD. These are referred to as ‘Specific Relevant Pollutants’. In July 2006, the European Commission adopted a proposal amending the WFD, for a new Directive, COM (2006) 398 (1), on environmental quality standards. This Directive seeks to protect surface waters from pollution and will set limits on the concentration in surface waters of 41 dangerous chemical substances (including 33 priority

(1) Proposal for a Directive of the European Parliament and of the Council on environmental quality standards in the field of water policy and amending Directive 2000/60/EC


5

substances and 8 other pollutants) that pose a particular risk to animal and/or plant life in the aquatic environment, or to human health. Following an extensive national dangerous substances screening and monitoring programme, Ireland has currently identified 18 (1) Specific Relevant Pollutants to be assigned an EQS at national level, comprising 4 Metals, 8 Pesticides and 6 other substances. It is important to note that in order for a water body to achieve and maintain “good status”, as required under the WFD, all parameters must comply with the proposed EQS. Therefore, the failure of a single parameter will result in the failure of achieving “good status” for the entire water body.

Annex A lists the General Components and the 59 substances that are covered under the Full RIA and the associated EQS. It is noted that substances listed in Annex A differ from those listed in the Screening RIA. This reflects the dynamic and evolving nature of the process involved in the selection of Ireland’s Relevant Specific Pollutants. The EPA commissioned this RIA, as it considered that there could be considerable financial and administrative cost associated with the implementation of the WFD, and in particular the European Communities (Water Policy) Regulations 2003 (S.I. No. 722 of 2003). The assessment focussed on establishing the potential positive and negative benefits of implementing Article 9 of the Regulations. Article 9 provides for the putting in place of classification systems which;

• estimate the values of the biological quality elements specified for each surface

water category, heavily modified water body and artificial water body; • classify and present the ecological status and chemical status of surface waters;

and • classify and present the chemical status and quantitative status of groundwater. This RIA addresses only the current EPA proposal for the establishment of environmental quality standards for General Components (physico-chemical), Priority and Priority Hazardous Substances and Specific Relevant Pollutants for surface waters. Surface waters include rivers, lakes, canals, impoundments, estuarine and coastal waters.

2.2.1 Exemptions

Within the WFD there is the possibility to extend the timeline for compliance with the requirement to achieve “good status” for all surface waters by 12 years from 2015 to 2027. The extension can be sought based upon three possible reasons: • Adverse natural condition; • Insurmountable technical difficulties; and/or • Disproportionate costs. However, the reasons and justifications for the use of extensions must be incorporated into the River Basin Management Plans for each RBD. This will require public

(1) The list of Specific Relevant Pollutants as provided in the EPA Discussion Document for Public Consultation on the Proposed Quality Standards for Surface Water Classification, July 2007.


6

consultation and agreement must be reached to request an extension on the compliance deadline. This is set out in Article 4(4) of the WFD. Additionally, under Article 4(5) of the WFD, if a water body is “so affected by human activity….that the achievement of the objectives would be unfeasible or disproportionately expensive” that water body can be excluded from the requirements to meet the objectives. Again, this would require significant consultation to be carried out on this exclusion and it does not exempt the water body from meeting the objective of progressively reducing pollution by priority substances or priority hazardous substances.

2.3 DESCRIPTION OF OBJECTIVES

The fundamental objective of the Water Policy Regulations is to achieve the objectives of the WFD, which are in brief: • Achieve good ecological status and chemical status in surface waters; • Achieve good chemical status and quantitative status in groundwaters; • Achieve good ecological potential and chemical status in artificial and heavily

modified waters; • Prevent deterioration in the status of surface and groundwaters; • Reverse pollution trends; • Achieve objectives and targets for protected areas; and • Cease the discharge of priority hazardous substances.

Ultimately the objective is to achieve good status in all surface waters by 2015 through the successful attainment of the above objectives. All objectives established in accordance with the WFD and Regulations must fulfil the SMART (Specific, Measurable, Accepted, Realistic and Time-Dependant) criteria. The intermediate SMART objectives should therefore include: • Implementation of a water framework monitoring programme for all surface

waters; • All surface waters to meet the proposed ecological and chemical EQS; • Where surface waters fail to meet proposed EQS, develop action plans within

specified timeframes to improve water quality and meet EQS; • Continue monitoring of good status waters to detect any deterioration in status; • Where deterioration is detected, implement action plans to reverse deterioration

and revert surface water to good status; • Establish EQS reporting programmes; • Identify priority hazardous substances discharges and implement programmes

for their reduction and eventual cessation.

2.4 PROPOSED CLASSIFICATION REGULATIONS

The purpose of the proposed Surface Water Classification System Regulations is to establish specific criteria to classify surface waters in Ireland. This will facilitate the comparison of surface waters and monitor changes in status over time. It also allows for the identification and focus of improvement works on priority surface water bodies, the setting of improvement plans for surface water, with specific improvement targets, and the demonstration of improvements and environmental benefits. The


7

classification system will also facilitate the national requirement to protect water quality and monitor improvements to achieve the WFD target of ‘good status’ by 2015. The status of each surface water body will be assessed using the criteria set out in the new Regulations, which includes an ecological classification and chemical classification system. In order to achieve the overall aim of ‘good status’, the surface water body must demonstrate good status results for both types of classification. The ecological classification includes the following elements:

• Biology;

• The General Components (physico-chemical) supporting biology;

• Water quality standards for specific relevant pollutants; and

• Hydromorphological conditions supporting biology.

While the chemical classification is based on:

• EU wide standards for priority substances listed in Annex X of the WFD; and

• Standards already established under other relevant EU Directives as listed in Annex IX of the WFD.

This RIA is restricted to the General Components (physico-chemical) (No. 8), Priority Substances (No. 33), Other Pollutants (No. 8) and Relevant Specific Pollutants (No. 18). Since the completion of the Screening RIA, the Specific Relevant Pollutants and associated EQS have been updated, and refer to 18 substances which are included in this RIA. Standards will be brought forward for other substances at a later stage, if deemed necessary, based on the findings of the national monitoring programme.

A list of the General Components (8 physico-chemical parameters) and Priority Substances, Other Pollutants and Specific Relevant Pollutants (59 substances) and proposed EQS is presented in Annex A (67 EQS in total). Annex A also includes a comparison of the current emission limit values and environmental quality standards used by Local Authorities and the EPA, with the proposed EQS. As can be seen, there is a significant change in the proposed concentration limits for some of the parameters, which ultimately is expected to improve the quality of water. However, meeting them may also present a significant challenge for some water bodies in Ireland. An overview of the new EQS is presented in Table 2.1. It should also be noted that background concentrations, in particular natural background levels for some metals, are currently not taken into consideration when assessing compliance. Agreement has to be reached on how to take background concentrations into consideration and this issue is yet to be resolved at EU level. One key difference between some of the existing standards and the new EQS, is that some of the existing standards only apply in designated waters e.g. waters designated under existing national legislation for the protection of freshwater fish. However, the EQS proposed under the new classification system will apply to all surface waters in the State, up to the outer boundary of each river basin district, except in the case of standards proposed for Priority Substances, which will also apply in territorial waters.


8

Table 2.1 Overview of proposed EQS

Summary of Impacts of proposed EQS No. No. of new EQS introduced 21 No. of EQS with lower limits, or changes to existing EQS with minor/significant impact

19

No. of EQS with no change 19

2.5 AN OVERVIEW OF IRELAND’S SURFACE WATER RESOURCES

2.5.1 Surface Water Status in Ireland

The EPA’s Water Quality Reports note that the primary challenge that Ireland faces over the next decade is to achieve ‘good water status’ for all waters by 2015, as required by the WFD. Not all waters in Ireland currently meet this objective, with the main threat being excessive nutrient loading leading to eutrophication. The nutrients of concern are primarily phosphorus and nitrogen, which typically arise in runoff from agricultural manures and fertilisers, sewage and detergents.

Table 2.2 Classification System

Status Quality Element Within Scope of RIA

Proposed Standards

Relevant Proposed Documentation

Ecological Biological Elements No N/A N/A General Components

(physico-chemical) supporting biology

Yes Annex VIII of WFD

Proposed EQS for General Components (physico-chemical) in Surface Waters in Ireland, Report by South Eastern River Basin District.

Water quality standards for Specific Relevant Pollutants

Yes Annex VIII of Proposed EQS for Specific relevant Pollutants in Surface Waters in Ireland.

Hydromorphological conditions supporting biology

No N/A N/A

Chemical Priority Substances Yes Annex IX, X of WFD

Proposal for a Directive of the European Parliament and of the Council on environmental quality standards in the field of water policy and amending Directive 2000/60/EC.

A brief summary of the reported existing water quality status in Ireland, relevant to this RIA, is provided in Table 2.3 below. This, and similar datasets developed by the EPA, GSI and the various RBD projects, were used to help establish the baseline for this RIA.


9

Table 2.3 Baseline Water Quality in Ireland 2006

Water Body Classification Rivers Overall Irish rivers (71.4%) have a satisfactory water quality status and the

level of serious pollution continues to be low (0.6%). Based on the most recent evaluation, 71.4% of river channel length is believed to be, on the basis of existing evaluation methods, likely to achieve ‘good status’. Significant efforts will be required to improve the remaining 28.6%.

Lakes

Some 383 (85.3%) of the 449 lakes assessed were of satisfactory water quality, i.e. oligotrophic or mesotrophic in status. Measures need to be put in place to improve the water quality of the remaining 66 lakes (14.7%) that, on the basis of existing evaluation methods, are not deemed satisfactory.

Estuaries & coastal waters

Of the 69 water bodies assessed from 21 estuarine and coastal areas, 25 (36.2%) are classified as unpolluted on the basis of existing evaluation methods. Significant efforts will be needed for the remaining estuarine and coastal water bodies to achieve the WFD good status target.

Urban Waste Water Treatment

The proportion of waste water receiving secondary waste water treatment has increased from 21% in 2000-2001, to 82% in 2004-2005.

River Basin Management

The percentage of water bodies at risk of failing to meet the WFD good water targets by 2015 were identified to include: rivers (64%), lakes (38%), estuarine waters (53%), coastal waters (27%) and groundwaters (62%).

Source: EPA Website http://www.epa.ie/environment/water/ It is noted that 71.4% of rivers and 85.3% of lakes, were described as having “satisfactory” water quality in 2006. However, the various RBD characterisation reports indicate that 64% of rivers and 38% of lakes are described as water bodies “at risk”. Taking a point between these two figures (29% and 64% for rivers and 15% and 38% for lakes), it could be approximated that water quality in some 47% of our rivers and 27% of our lakes, are either unsatisfactory or at risk, and therefore are likely to fail to meet the environmental objectives to be established for the WFD, without the implementation of further pollution reduction measures.

Records of biological monitoring and classification of rivers are available on the EPA website and have, up until 22 December 2006, been based upon the previous biotic index (Q values), which have subsequently been revised. This monitoring system assigned “Q-Values” to rivers using biological assessment of the water quality. Based upon these results, a rating of satisfactory or unsatisfactory was assigned. Physico-Chemical sampling is also carried out which identifies organic pollution, assessing the more commonly measured parameters, such as dissolved oxygen (DO), biological oxygen demand (BOD), ammonia, oxidised nitrogen (nitrites plus nitrates) and phosphates. In the presence of pollution, characteristic and well-documented changes are induced in the aquatic flora and fauna. The changes brought about by organic pollution in the invertebrate community, (which form the basis for the Q system), are due to the varying sensitivities of the different components of the community to the stresses caused by pollution. The Q system is summarized in Table 2.4.

Table 2.4 Summary of biological water quality assessment

Q Value Community Diversity Water Quality Condition* Q5 High Good Satisfactory Q4 Reduced Fair Satisfactory Q3 Much Reduced Doubtful Unsatisfactory Q2 Low Poor Unsatisfactory Q1 Very Low Bad Unsatisfactory * 'Condition' refers to the likelihood of interference with beneficial or potential beneficial uses.


10

In June 2007, each River Basin District Project issued, a “Water Matters” report (1) which summarised the existing controls in place and provided an assessment of their adequacy. The reports highlight some deficiencies in the existing controls and sets out proposed actions, along with the parties responsible for taking those actions and the users who would be affected.

2.5.2 Current Relevant Legislation, Schemes Guidelines and Enforcement Organisations

Assessing the potential impacts of the proposed EQS for the General Components (physico-chemical), Priority Substances, Other Pollutants and Specific Relevant Pollutants, requires consideration of the existing impacts on our surface waters, the controls that are currently in place to protect water quality from the different sources and the types of pollution.

The first section concentrates on potential diffuse sources of pollution, the second on point sources of pollution and the third on specific potentially polluting substances. Thereafter we analyse the role of the current Regulations and regulators, as the new Regulations will have a cross compliance aspect in its enforcement as it draws upon several current Regulations. It is likely that enforcement will fall to a number of the existing enforcement bodies, including the various Local Authorities, the Environmental Protection Agency and other Departmental Inspectorates.

It is noted that under the WFD, the deadline for the delivery of a Programme of measures to achieve water quality of good status by 2015, must be in place by the 22nd December 2012. This will require that all licences will have to have been assessed for their compliance with the requirements of the Regulations and reviewed where necessary. Control of Diffuse Pollution Sources

Phosphates, nitrates and organic pollution are the main water pollutants associated with discharges or run-off from agricultural activities. As stated in Section 2.5.1, one of the main sources of diffuse nutrient pollution to rivers in Ireland is from agricultural activities. As agriculture is also one of the primary users of pesticides, it is also a potential source of diffuse pesticide pollution. Unsewered properties, which typically rely on on-site treatment systems e.g. septic tanks, can also be significant contributors of diffuse pollution in surface water bodies. It is noted that in conjunction with the increase in housing development in recent years, there has been a corresponding increase in development in unsewered areas (2). These may include single dwellings, holiday homes, housing clusters of up to 100 houses (which are serviced by shared systems), commercial premises and light industrial units. The most recent Central Statistics Office and RBD documentation report that approximately 450,000 properties (31% of the national total) are currently without public sewerage facilities and rely on septic tanks, propriety treatment systems or in some cases, no sewerage facilities. The counties with the highest percentage of properties without public sewerage facilities are Counties Cork, Kerry and Galway. Given the range of premises that discharge to these treatment systems, they are potential sources of diffuse pollution of the range substances being assessed in the RIA.

(1) Water Matters - "Have your say!", issued by each of the RBD, 2007.(2) Pleanáil: Journal of the Irish Planning Institute. “Some Hidden Costs of Rural Housing”, Diarmuid Ó Gráda. Issue 17, Spring 2007.


11

Discharge from these septic tank systems is estimated to be in the range of 250 – 300 million litres per day to the countryside. Of significant concern is the finding that only 5% of septic tanks inspected in Leinster were installed in areas where ground conditions were suitable(1). Proprietary systems are commonly advocated as the solution to the lack of public treatment systems. However, the treatment plant firms suggest that this is not always the case (2). Maintenance of proprietary systems is vital for its continuing effective running and it has been shown that while the first year maintenance is typically included in the initial cost, the up-take of maintenance agreements past this point drops off significantly and at best only 25% have them in place 3 – 5 years after installation. A pilot study (2002) undertaken by Cavan County Council found that over one third (36%) of on-site systems within their functional area were defective (3). The study found that 7.6% had serious defects and 29% had significant defects. Many tanks are poorly maintained (e.g. are not desludged), or are poorly designed. Cavan County Council introduced Bye-laws in 2004 in relation to onsite treatment systems for single houses which require homeowners to provide and maintain an approved and properly functioning treatment system for their property. The Bye-laws also require that a certified inspection of the septic tank be undertaken at a minimum of every 7 years, with evidence of inspection provided to the Local Authority. While is appears that this system may work in relation to enforcement of maintenance of septic tanks, inconsistencies may arise between local authorities, national legislation, therefore, would provide clarity and consistency across local authorities and for the public. Forestry can be a diffuse source of impact on water quality through activities such as such as acidification of soils, nutrient enrichment, erosion/sedimentation and pesticide run-off. Ireland’s national policy is to increase the percentage of land under forestry from the current level of 10%, to 17% over the next 30 years. Coniferous trees currently dominate the forestry stock accounting for approximately 75% of all trees planted. The majority of forests are state owned and are managed by Coillte. In an effort to ensure that Ireland’s timber resources are managed in a sustainable manner, the Department of Agriculture, Fisheries and Food, through the Irish Forest Service, are implementing Sustainable Forest Management practices (SFM) in relation to development and evaluation of forestry. A Code of Best Forest Practice has been developed for the industry and the process of tree felling is controlled through the licences issued under the Forestry Act. In addition, a significant volume of Irish and European legislation has been enacted in Ireland, along with a comprehensive policy framework, to control and limit agricultural and forestry activities as diffuse sources of pollution. Listed below is a summary of the main pieces of legislation and guidance documents applicable. More information can be obtained on the relevant departmental web sites: • Forestry Act 1946, 1956 and 1988; • Forestry 1946 (Part IV) Regulations 1949; • Council Directive of 4 May 1976 on pollution caused by certain dangerous substances

discharged into the aquatic environment of the Community (76/464/EEC);

(1) Pleanáil: Journal of the Irish Planning Institute. “Some Hidden Costs of Rural Housing”, Diarmuid Ó Gráda. Issue 17, Spring 2007.(2) Pleanáil: Journal of the Irish Planning Institute. "Waste Water Treatment for Single Rural Housing", Gordan Daly. Issue 17, Spring 2007.(3) Peter Cork (Senior Engineer, Cavan County Council) at the River Basin District Advisory Councils National Conference for Members dated 28th September 2007 gave information on the pilot study conducted by Cavan County Council in 2002


12

• Local Government (Water Pollution) Act, 1977 (Water Quality Standards for Phosphorus) Regulations, 1998 (S.I. No. 258 of 1998);

• Council Directive of 12 December 1991 concerning the protection of waters against pollution caused by nitrates from agricultural sources (91/676/EEC)

• Water Quality (Dangerous Substances) Regulations, 2001 (S.I. No. 12 of 2001); • European Communities (Authorization, Placing on the Market, Use and Control of Plant

Protection Products) Regulations (S.I. No. 83 of 2003); • European Communities (Aerial Fertilisation) (Forestry) Regulations 2006 (S.I. No. 592

of 2006); • European Communities (Good Agricultural Practice for the Protection of Waters)

Regulations 2006 & 2007 (S.I. No. 378 of 2006 and S.I. No. 526 of 2007) enacting Council Directive 91/676/EEC (Nitrates Directive);

• Rural Environmental Protection Schemes (REPS); • Cross Compliance Guide for the Single Payment Scheme; • SR6: Septic Tank Systems: Recommendations for Domestic Effluent Treatment

and Disposal from a Single Dwelling House; • Appendix 16 - Principles of Good plant protection Practice, this applies to all areas

where pesticides are used; and • Forestry and Water Quality Guidelines.

Control of Point Pollution Sources

In Ireland, point source pollution arises primarily from municipal and industrial waste water treatment plants. However, it may also rise from other point sources such as landfills, quarries, mines, contaminated lands and road run-off. Ireland reportedly has 540 sewerage schemes, servicing populations of between 500 and 1.7 million, 408 modern municipal treatment facilities and 132 smaller plants providing minimal treatment. Since 2000 to 2006, almost €3 billion has been invested to upgrade 210 waste water treatment plants, with local authorities building over 90% of the infrastructure required to comply with the Urban Waste Water Treatment Directive. More recently in September 2007, the Water Services Investment programme 2007-2012 was launched by the Minister for the Environment, Heritage and Local Government. In total, the proposed programme comprises 955 projects that have an overall capital value of €5.8 billion. However, approximately €2.9 billion of this overall value relates to provision and upgrade of sewerage and waste water treatment services from 2007 - 2009. Currently, the EPA manages 482 operational licences under the IPPC licensing regime, of which 103 discharge to waters and approximately 298 discharge to sewers, with local authorities facilitating the licensing of a further 1,090 small scale commercial and industrial discharges to sewer and 1,120 direct discharges to water. The EPA also manages 176 waste licences, which range from waste transfer stations to landfill sites. Discharges from these sites are typically only clean surface water run-off and leachate from landfills are discharged through existing local authority WWTP. Information regarding point source impacts from landfills, quarries, mines and contaminated lands is not comprehensive, particularly regarding historical activities in Ireland. However at present, the EPA lists 86 contaminated sites (including 25 illegal landfills); 500 quarries and 100 mines (active and non-active). These sites are variously captured under the waste licensing regime, IPPC licensing regime and planning and development requirements.


13

National roads are constructed with the collection and treatment of road run-off as an integrated feature of the design process. The National Roads Authority (NRA) has commissioned studies to assess the impact of run-off from roads. This has identified that the level of pollution is low and that the treatment processes that have been implemented are effective. However, the NRA are improving the guidance available in relation to the design of collection and treatment systems for national roads, with new guidance expected in 2008. Additionally, the Environmental Impact Assessment process associated with the development of the national road network takes into consideration the environmental setting of the roads and identifies where and what level of mitigation is required to ensure the road has the least possible impact on the environment. The following items of legislation have been enacted to control emissions from point sources and general controls to prevent water pollution, including: • Local Government (Water Pollution) Act, 1977 (No. 1 of 1977) and the Local

Government (Water Pollution) (Amendment) Act, 1990, (No. 21 of 1990) • European Communities (Environmental Impact Assessment) Regulations 1989, and

amendments (S.I. No. 349 of 1989); • Environmental Protection Agency Act, 1992. • Waste Management Act, 1996; • Waste Management (Use of Sewage Sludge in Agriculture) Regulations, 1998 (S.I. No.

148 of 1998); • Local Government (Planning and Development) Act, 2000; • Local Government Act, 2001; • Urban Waste Water Treatment Regulations, 2001 (S.I. No. 254 of 2001); • Waste Management (Use of Sewage Sludge in Agriculture) (Amendment) Regulations,

2001 (S.I. No. 267 of 2001); • European Communities (Water Policy) Regulations 2003 (S.I. No. 722 of 2003); • Protection of the Environment Act, 2003; and • Waste Water Discharge (Authorisation) Regulations, 2007 (S.I. No. 684 of 2007); Specific Potentially Polluting Substances The 2001 Dangerous Substances Regulations have already established environmental quality standards for 14 dangerous substances which the regulatory agencies (e.g. local authorities and the Environmental Protection Agency), must adhere to when authorizing emission limits for discharges to water. However, while local authorities may be requesting information in relation to dangerous substances as part of their licensing process, the consultation process indicated that there is a limited understanding within the authorities as to the levels or sources of dangerous substances being discharged to their collection systems. Additionally, control of diffuse pollution sources is more difficult to achieve and not easily addressed by way of the emission control approach. Recent European Regulations, which came into effect in June 2007, will have a significant effect on the use, control and release of chemicals. The Regulation of the European Parliament and of the Council Concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) will track and limit the use of chemical substances, in certain cases, within Europe. The Irish RIA for REACH (1) states that “The health benefits from REACH are expected to accrue indirectly through the


14

provision of additional information and the subsequent behavioural response and the removal of toxic chemicals from non-essential uses through authorisation and restriction”. REACH will initially concentrate on high volume substances and those of high concern, i.e. those that are carcinogenic, mutagenic or toxic to reproduction (CMR), or which are persistent, bio-accumulative and toxic (PBT), or very persistent and very bio-accumulative (vPvB). REACH is likely to result in reduced quantities of these substances being used, through the identification of substitute substances or the restriction of their use. Consequently, fewer chemicals or smaller quantities will be released into the waste water treatment system from domestic, commercial or industrial facilities, and eventually to surface water bodies. Annex B outlines the candidate substances to be controlled under Article 56 and 57 of the REACH Regulations – through the process of Authorisation. The information provided in Annex B is only for information purposes and Annex XIV of the REACH Regulations has not been developed to date. It is possible that due to their carcinogenic, mutagenic or toxic to reproduction (CMR), or persistent, bio-accumulative and toxic (PBT), or very persistent and very bio-accumulative (vPvB) nature, some of the substances proposed under the water classification system will also eventually be controlled under REACH. These systems will operate in parallel and the implementation of REACH will not adversely impact on the attainment of good status for Ireland’s water bodies. Environmental Protection Agency

The EPA licences the control of certain emissions to water bodies through the use of Emission Limit Values (ELVs). These specify the maximum concentration of specific pollutants allowed to be emitted from industries identified in the Schedules to the Protection of the Environment Act 2003. Currently, the EPA administers 651 IPPC and 246 waste licences. The licensing and enforcement duties of the EPA are divided between two sections. The licensing section assesses applications and grants licences with conditions attached. The enforcement section ensures compliance by the industries with the conditions set out in the licences. It is noted that compliance with licence conditions does not mean that the licensee cannot be prosecuted under different environmental legislation, if they are found to be causing pollution. Each applicant is required to submit, to the Agency, an assessment of the impact on the receiving environment caused by discharges from the operation of the facility. The Agency applies the principal of Best Available Technology to prevent, eliminate, abate or reduce an emission from an activity and has due regard to the relevant legislation and guidance. This is a key principal of the IPPC Directive 96/61/EC and has been defined as:

“the most effective and advanced stage in the development of an activity and its methods of operation, which indicate the practical suitability of particular techniques for providing, in principle, the basis for emission limit values designed to prevent or eliminate or, where that is not practicable, generally to reduce an emission and its impact on the environment as a whole.” (2)

(1) An Impact Assessment of the Proposed EU Chemical Policy (REACH) on Irish Industry, ERM Environmental Resources Management Ireland Limited, for Forfás, April 2005.(2) Section 5 of Environmental Protection Agency Acts, 1992 and 2003, and Section 5(2) of the Waste Management Acts

1996 to 2005


15

The calculation of the assimilative capacity of the receiving body (which can be described as the ability of a body of water to receive waste waters or toxic material without adversely affecting the quality of the water) and an assessment of the impact is also carried out by the applicant. The assessment is based upon the substances that they identify and it is reviewed by the Agency. Annex A outlines the existing standards that the EPA have been enforcing and highlights the changes in the parameter concentrations by the proposed new EQS. During the licensing process, the EPA uses information provided by the applicant as well as other data to assess and confirm the potential impact of the proposed discharges. Consultation with the EPA during the RIA suggests that the Agency does not envisage a significant change in the approach to the licensing of facilities. However, once the Regulations have been finalised, the Agency will assess their implications on the ELVs to ensure they have regard to the new EQS. The enforcement section of the EPA is responsible for ensuring licensed facilities comply with their licence conditions. Compliance with specified ELVs must be demonstrated by monitoring carried out by the licensee, which is checked/ verified by monitoring carried out by the EPA. Licensees who exceed their ELVs can be prosecuted and the court can impose fines on licensees and require them to repair environmental damage. Local Authorities

Local authorities are responsible for the control and operation of the majority of municipal Waste Water Treatment Plants (WWTP) and the associated collection systems. They are also responsible for setting limits on industrial discharges to water bodies and sewers collecting waste water (this is done in conjunction with the EPA for IPPC licensed installations). Applicants for Section 4 discharges to sewers and Section 16 discharges to water bodies, receive end-of-pipe ELVs based upon on the relevant substances they identify. Both the EPA and the local authorities rely on industry to identify the substances discharged in the effluent. If a licensee wishes to discharge any other substance they should contact their local authority and have their discharge licence revised to reflect the change. A discharge licence, and compliance with it does not protect the holder from prosecution under the legislation or any other relevant legislation in the case of pollution. Based on the level of information currently available, it is understood that the information provided by industry is sufficient in relation to the General Components but would not meet the level of assessment required to identify all 59 substances signified for the revised and new EQS (i.e. effluent is not routinely tested for all 59 substances). It is anticipated however, that there would be no individual industry which would emit all 59 substances and that the majority of industries would have a reasonable appreciation of the range of substances that could be emitted from their site. This would allow for a screening of potential emission sources to be carried out relatively quickly. Annex C outlines potential sources of the 59 substances. It is understood that the level of enforcement of Section 4 and 16 licences, and the level of knowledge of sources of emissions and their characteristics, varies significantly between local authorities. It is considered likely that the current level of resources available and the licensing and enforcement system structure within the local authorities may not be sufficient to ensure the level of control required to achieve the EQS.


16

Municipal WWTPs will be more difficult to characterise and control due to the numerous sources of potential pollutants. Up until the enactment of the Waste Water Discharge (Authorisation) Regulations 2007, emissions from municipal WWTP were not licensed and local authorities were solely responsible for their operation. These Regulations came into force in October 2007 and while applying to all discharges from agglomerations from 2010, the licensing process was phased in for larger plants from the 14th December 2007. The new licensing system will enforce ELVs on discharges from WWTP and will require greater levels of operational management and control. As these licences are being issued over a phased basis up until 2009, the ELVs in the licences will be set based upon legislation in force in Ireland at the time of the granting of the licence, but will eventually support the attainment of the EQS set in the proposed Regulation (Annex A). The EPA in the writing of the licences can take into consideration EQS which they know will be coming into force at a later date but can only enforce EQS that are actually in operation. The licences will be administered by the EPA through the current enforcement structures in place. Detailed characterisation studies have not been carried out on Irish municipal WWTP. However, it is hoped that with greater levels of monitoring under the new licensing system, more knowledge and control can be obtained. It is noted that the level of compliance currently being achieved by the Local Authorities in relation to the requirements of the Urban Waste Water Treatment Regulations 2001, is presenting significant challenges. In 2007, the EPA Office of Environmental Enforcement published a report on Urban Waste Water Discharges in Ireland for PE’s >500 (1). The report concluded that many plants are under increasing pressure resulting from development that has taken place over the last number of years. The report also identified recurring problems at plants, such as limited assimilative capacity for the discharged effluent in some receiving waters. The additional requirements of the proposed EQS are likely to present significant challenges for the Local Authorities. The costs outlined in this report relate to the additional costs associated with the reduction of pollution for those substances for which either new, or more stringent, EQS are now proposed. However, the estimates do not include the costs associated with addressing existing shortfalls in complying with obligations under the Urban Waste Water Treatment Regulations. Department of Agriculture, Fisheries and Food

The Department of Agriculture, Fisheries and Food (DAFF) is responsible for the assessment, licensing, monitoring, enforcement and development of the aquaculture industry in Ireland. Coastal fish farming is the sector of this industry with particular relevance to these Regulations. The use of Animal Medicines within this sector to protect the fish stock from infection by sea lice etc. is controlled under specific Regulations. These Regulations and the licensing process carried out by the DAFF are designed to ensure that the operations are carried out in an environmentally friendly manner. Additionally, each fish farm has to carry out an annual environmental survey and submit the associated report to DAFF.

(1) Urban Waste Water Discharges in Ireland - for Population Equivalents Greater than 500 Persons - A Report for the Years 2004 and 2005, Environmental Protection Agency, 2007.


17

3 OPTIONS

3.1 INTRODUCTION

There were three policy options, with regard to the Classification Regulations, provided by the EPA in the Screening RIA specification. These options remain the same for the RIA and are as follows: 1. The ‘do nothing’ or ‘no policy change’ option; 2. A reliance on voluntary reductions by relevant industry and activities in the use

of and concentrations of substances discharged to meet the EQS levels; and 3. Full regulation of all the substances set out in Annex VIII and Annex X of the

WFD. Section 4 of the report outlines the, Economic, Environmental and Social Impacts, of the proposed Regulations in the case of each option. Set out below is an explanation of the assumptions made within option.

3.1.1 Option 1 – Do Nothing (1)

The ‘do nothing’ or ‘no policy change’ option is included as an option for consideration as a benchmark for comparison. In the case of an EU Directive it is appropriate to state that “The do nothing option is primarily being included for benchmarking purposes. Therefore it will not be examined in great detail as part of this RIA because it is not envisaged that this option will be pursued in practice. To take no action would mean a failure to comply with our EU obligations and could result in prosecution by the European Commission.” (2)

In this analysis, the ‘do nothing’ option involves the continued use and enforcement of existing Irish and EU legislation (as set out in Section 2.5.2) to meet the surface water classification requirements of the Water Framework Directive and Water Policy Regulations. In effect therefore, no additional product, plant or process control measures, activity or emissions reduction or cessation or other measures will be required and there will consequently be no associated cost implications other than the cost associated with the full enforcement of the existing legislation. However, unless all Irish water bodies meet the requirement of ‘good water status’ and those waters of ‘high water status’ are protected from deterioration by 2015, this option is likely to result in European Commission proceedings against the State with significant cost implications.

3.1.2 Option 2 – Reliance on Voluntary Reductions

This option assumes a reliance on voluntary reductions in the concentrations to the required level at the discharge source, in order to achieve “good status” in the surface water quality of all water bodies. This would require the use of trigger and guideline values rather than legally binding EQS.

(1) The "Do Nothing" Scenario means that all current legislation will be enforced fully and that the proposed Regulations are not enacted.(2) RIA Guidelines - How to conduct a Regulatory Impact Analysis. Department of the Taoiseach, October 2005.


18

This option can be divided into the following two components: Option 2.1 – Reliance on Voluntary Reductions at Source This component assumes the reduction of concentrations in emissions from the source of use, to comply with the proposed trigger and guideline (1) values through voluntary means ie stop using certain substances. In effect, this will involve source controls on specific products or processes which are responsible for discharges, emissions and loses. This option will require operational or activity changes, product or chemical replacement or reduction in use and will cover many aspects of the Irish economy including industry, trade, agriculture, etc. The success of this option will depend on the voluntary aspect, where the participation of key stakeholders is vital. There will be cost implications for the participating stakeholders in the implementation of methods for reduction at source. There is also a risk that not all water bodies will achieve good status under this option, as the reduction in concentration of emissions may not be sufficient to meet the guideline values set out. The new Waste Water Discharge Regulations will implement the current standards and control ELVs. Given the current pressures that the WWTPs operate under, the significant financial investment that may be required to upgrade such plants if they are found to be the source of pollution, the timeframes involved, and the fact that the operators cannot control the volume of effluent entering the plant, the effectiveness of a voluntary system is open to question. Industry would also be required to implement greater controls on their emissions or potentially cease the use of certain chemicals/substances. While it is accepted, that REACH will assist in achieving this target, as it will focus on the removal from and a reduction in the use of dangerous substances, it is unclear exactly which substances will be controlled and how (2). The timeframe of REACH is also likely to be outside of the 2015 deadline for the WFD, as many chemical substances do not fall within the scope of REACH until 2018. Therefore, the question arises as to why an industry would cease using a chemical when there is no direct obvious benefit. Additionally, the enforcement of such an approach would require self regulation of emissions and depend on licensees informing local authorities when they exceed trigger and guideline values. It is also questionable as to what action can be taken once an exceedence has occurred, if there is no legally binding obligation there would be no associated punishment. Therefore, significant infrastructural investment in treatment plants may still be required to ensure the successful attainment of good water quality by 2015, which leads onto Option 2.2. Agriculture and aquaculture use certain substances under licence which would have to have voluntary EQS applied to them. If a substitute is not available or those available do not achieve the same level of results (eg increased yields or reduced infection levels), it is unlikely that an inferior product would be used as this would lead to a reduction in the quality and/ or quantity of the product and therefore competitiveness. The use of voluntary EQS is unlikely to stimulate the same level of research into the identification or development of alternatives as an enforceable ban

(1) A Trigger value would be a value beyond which the local authority or EPA should be notified and the participant should try to identify the source of the substance. A Guideline value is a point at which the participants agree to take action to reduce the level of the substance in the surface water body.(2) An Impact Assessment of the Proposed EU Chemical Policy (REACH) on Irish Industry, Final Report, April 2005, ERM Environmental Resources Management Ireland Ltd. (ERM Ireland) for Forfás.


19

on the use of a substance would. The use of voluntary EQS is therefore, unlikely to achieve the desired results. Other historical sources such as disused mines or old/illegal landfills could continue to be a diffuse source of pollution. Similarly road run-off by its nature cannot be controlled at source. This approach would require significant buy in from organisations representing farming, forestry, aquaculture and industrial interests. A significant effort and investment would be required in education, support and advertising to explain the benefits of complying with the voluntary scheme and what alternatives are available. Option 2.2 – Reliance on Voluntary Reductions at End-of-Pipe This option assumes the continued use of substances and a reduction in concentrations in emissions through the use of end-of-pipe controls. Again, this reduction is through voluntary means and will primarily focus on point source emissions of substances to receiving waters, to comply with the proposed trigger and guideline values. In effect, this option will involve the upgrade of end-of-pipe control measures for local authorities, industry with IPPC licences, Section 4 and 16 discharge licences, etc. It will also require the reduction of pollutant concentrations in non-licensed industry, trade and non-industrial discharges. Significant support from the general public would also be required to up-grade and maintain septic tank or proprietary treatment systems for domestic houses. The cost to industry to treat effluent prior to discharge may be significant and in some cases, may not be technically feasible due to the type of substance being discharged or other constraints, such as the lack of available space to install a treatment system. There may also be a question as to the effectiveness of this approach, as there would not only be a potentially significant capital investment required, but also continued investment in facility operation and associated training of personnel. Non-compliance under the voluntary approach may also be an issue as it could be hard to establish who was at fault and as there are no sanctions, the system would be open to abuse. There will be certain situations where end-of-pipe treatment will not be feasible such as in the case of diffuse sources, or where the technology for the treatment is not available or is too costly to be implemented on a site by site basis. Combined Sewer Overflow’s (CSO’s) are also a potential source of pollution which under a voluntary end of pipe system may continue to operate without being upgraded due to the associated costs. Application of certain substances will not allow for end-of-pipe treatment such as pesticide application in aquaculture, agriculture and forestry. Or as in the case of septic tanks and proprietary systems, it is known that they are a source of diffuse pollution following end of pipe treatment and this situation is unlikely to be resolved without proactive intervention. Summary

Option 2 assumes that both elements (2.1 and 2.2) are undertaken simultaneously. There will be cost implications for the participating stakeholders, in particular for those groups participating in both the reduction of concentrations at source and end-of-pipe reductions. Furthermore, there is a risk that not all water bodies will comply with the guide values under this option.


20

As Option 2 considers voluntary reduction only, it can be expected that not all stakeholders will participate in the reduction of identified pollutants and comply with the proposed target and guideline values. Therefore, the benefits are estimated to be only 50% of the benefits expected from full regulation described under Option 3. The costs, however, as outlined in Option 3 will be similar in the industrial sector where on-site waste water treatment is required. It should be assumed that some of the costs outlined in Option 3 in relation to the upgrading of Local Authority WWTPs will also be incurred, as not all industrial sectors will participate and upgrades will have to be implemented to ensure compliance with the voluntary levels. Under a voluntary system stakeholders may just assume that the local authorities will pick up the slack and therefore may not actively participate.

3.1.3 Option 3 – Full Regulation for all Required Substances

This option assumes full implementation of the proposed Regulations for all required substances to achieve compliance with the EQS and the WFD, resulting in the achievement of good water status in water bodies and the protection of high water status bodies by 2015. It is noted in Section 2.2.1 that an exemption of up to 12 years can be sought for the attainment of good status in designated water bodies. Option 3 assumes that an exemption is not sought. Option 3 requires the reduction of concentrations of specific relevant pollutants or alteration of processes which are responsible for discharges, emissions and losses, through reduction at source and/or end-of-pipe controls. It also assumes that the use of priority hazardous substances will be eliminated. This option will require mandatory participation and compliance by all relevant stakeholders. There will be additional costs for Option 3, including where end-of-pipe control measures are not appropriate (e.g. diffuse sources), and where additional measures are required to achieve compliance with the cessation or phase-out of discharges, losses and emissions of certain pollutants. The impact analysis focuses on the implementation of Option 3 as it is considered to be the most likely Option to be chosen. The EPA and local authorities will have to take into consideration the EQS set in the Regulations when applying emission limit values to their discharge licences. Exceedance of an EQS will require action to be taken by the local authorities to identify the likely source of pollution and to take action to prevent the continued exceedance of that EQS.


21

4 IMPACT ANALYSIS

4.1 INTRODUCTION

For the purposes of this RIA, the impact analysis will be structured having regard for the river basin districts (RBD) in Ireland, as the objectives and requirements of the WFD are being implemented through these structures. The WFD utilises the river basin as the water bodies natural unit for water management, and is the area of land from which all surface run-off flows through a sequence of streams, rivers, and lakes (as appropriate), into the sea and also includes the associated groundwater and coastal waters of the catchment. There are seven river basin districts in Ireland, a summary of which is provided in Annex D, along with a detailed overview of each RBD. This RIA will focus on the RBDs solely within the Republic of Ireland. Given the nature of the topic, point source emissions are more easily assessed as to the impact of a change in parameters. While it is recognised that diffuse sources of pollution will impact on surface water quality, there are a number of Regulations covering the control of this area, the benefits of which have not been fully attained. For this reason it has not been possible to quantify the impact of the new EQS limits on potential diffuse sources of pollution. For the purpose of this RIA, it has been assumed that the controls for nutrient management in agriculture and forestry which are currently in operation will be sufficient to control diffuse emissions of nutrients from these sources, if adequately enforced.

4.2 NATIONAL DANGEROUS SUBSTANCES SCREENING PROGRAM

As part of the implementation of the WFD in Ireland, a National Dangerous Substances Expert Group was established to design an appropriate screening programme to identify substances of national relevance and to assist in the development of EQS for surface waters using expert opinions and experience. As part of this screening programme, monitoring was conducted on several rivers, from 2005 - 2006, which identified elevated concentrations above proposed EQS in respect of the substances detailed in Table 4.1 and Table 4.2. For the priority action substances in Table 4.1 and specific relevant pollutants in Table 4.2, the primary aim is the reduction of pollution from these substances. However, for the priority hazardous substances, the WFD requirements are more stringent, requiring the cessation or phasing out of all emissions and discharges of these substances. Priority Substances (PS), and Priority Hazardous Substances (PHS) are defined as follows in the WFD: • "Priority substances" means substances identified in accordance with Article

16(2) and listed in Annex X. • Among these substances there are "priority hazardous substances" which means

substances identified in accordance with Article 16(3) and (6) for which measures have to be taken in accordance with Article 16(1) and (8).

• “Hazardous substances" means substances or groups of substances that are toxic, persistent and liable to bio-accumulate, and other substances or groups of substances which give rise to an equivalent level of concern.

South Western River Basin District has issued a document entitled “Significant Water Management Issues, Dangerous Substances Usage (“Bottom up Study”), Background Document”. The document states that the definition of “Dangerous Substances”


22

incorporates all of the following groups and was adopted from the Discussion Document produced by the National Dangerous Substances Expert Group: • Priority Substances are substances identified in accordance with WFD Article

16(2) and listed in Annex X (33 Substances). • Among these substances there are ‘priority hazardous substances’ which means

substances identified in accordance with WFD Article 16(3) and (6) for which measures have to be taken in accordance with Article 16(1) and (8).

• Relevant Pollutants are specific synthetic and non synthetic substances (not on priority action list) whose presence may lead to a risk of failing the objectives of the WFD.

Under Article 1(c) of the WFD, "specific measures for the progressive reduction of discharges, emissions and losses of priority substances (PS)" are to be implemented. For the priority hazardous substances (PHS), discharges, emissions and losses are to be stopped or phased out within 20 years after the measures cited have been adopted at Community level.

Table 4.1 Summary of Priority Substances and Other Pollutants Exceeding the proposed EQS

Priority Substance Parameter Priority Hazardous Substances Anthracene Identified as priority hazardous substance Benzene n/a benzo[a]pyrene Identified as priority hazardous substance benzo[b]fluoranthene Identified as priority hazardous substance benzo[g,h,i]perylene Identified as priority hazardous substance benzo[k]fluoranthene Identified as priority hazardous substance di-(2-ethylhexyl)-phthalate (DEHP) n/a Fluoranthene Identified as priority hazardous substance Lead n/a Mercury Identified as priority hazardous substance Naphthalene n/a Nickel n/a Trichloromethane n/a 4,4'-DDT n/a Isodrin n/a n/a not identified as a priority hazardous substance

Table 4.2 Summary of Specific Relevant Pollutants Exceeding the proposed EQS

Specific Relevant Pollutant arsenic chromium copper cyanide fluoride mancozeb mecoprop xylene toluene zinc

From a review of Annex A, it can be seen that potential significant impacts have been identified for the above substances due to the change in the EQS.


23

Both point and diffuse sources of pollution were identified as being responsible for the majority of all the rivers and lakes identified as being at risk, from a review of the RBD information in Annex D. Diffuse sources were usually the main source of pollution and the main contributory factors were general urban and agricultural sources. The assumption has been made that agricultural sources are predominately associated with nutrient pollutants (General Components). It is also noted that there are 22 pesticides listed within the Priority Substances, Other Pollutants and Specific Relevant Pollutants. Agriculture, forestry and aquaculture are assumed to be the predominant likely significant diffuse sources of these substances. Based upon the assumption above and that general diffuse urban run-off is associated with periods of rain and are therefore not a consistent source of pollution, point source emissions are therefore assumed more likely to be a significant source of the remaining substances (Priority Substances and Other Pollutants and Specific Relevant Pollutants). Section 4 and 16 discharges, CSOs, WTPs and WWTPs, were the main contributory factors to point sources, with IPPC facilities making up the remainder. Annex C outlines the legislation covering the control of each substance, likely sources, and potential impacts on the environment.

4.3 SECTORS AND GROUPS AFFECTED

Attainment of “good water status” by 2015 will impact both positively and negatively, on all users of surface waters. ‘Users’ of surface water resources include both those who abstract raw water for use, and those that discharge to any surface water (directly or indirectly), via either point or diffuse emission sources and includes any person or company requiring water as part of their daily requirements (e.g. for drinking, bathing, cooling, cleaning and various industrial process). Water is also vital to our natural environment, supporting and sustaining flora and fauna. For our economy, water is critical for such activities as agriculture, fishing, power generation, industry, services, transport and tourism. The RIA process examines the direct impacts (1) of the proposed EQS that will be used to classify waters. Secondary impacts such as, improved health of the community, cannot be quantified in the RIA, but are recognised as a benefit of the proposed new controls. The primary sectors which will be impacted by the proposed surface water classification systems and EQS include: • Sectors discharging to surface waters, in particular those regulated under Section

4 and 16 discharge licences, Integrated Pollution Prevention and Control (IPPC) licences, groups and authorities responsible for Combined Storm Overflows (CSOs) and Waste Water Treatment Plant (WWTP) discharges. Discharges from these sectors may have to reduce concentrations to comply with EQS, install new treatment facilities or cease (through elimination or substitution) the use of certain substances which cannot be treated by end of pipe treatment processes.

• Sectors or groups which could be identified as diffuse sources of pollutants including those currently relying on the use of septic tanks for the provision of waste water treatment, those sectors using pesticides and those spreading nutrients, including agriculture, water industry and industrial facilities discharging to receiving waters as a consequence of diffuse run-off.

(1) An impact can be either positive or negative.


24

• Sectors and groups, abstracting surface water for public and/or private water supply, industrial process or agriculture use, will experience reduced costs and better quality of supply as reducing the levels of substances in the water bodies to the proposed EQS will reduce water treatment requirements ( ie if the water quality is better then less treatment will have to be applied to the water source to ensure it meets the requirements of either the industrial use proposed or the minimum drinking water standards as set out in EU Drinking Water Directive (98/83/EC of 3 November 1998) as transposed into Irish legislation).

• Sectors, including agriculture, water industry and industrial facilities discharging to receiving waters as a consequence of diffuse run-off will need to take action to reduce discharges.

• Sectors, whose operations or activities emit substances which have proposed EQS to atmosphere, may be impacted by having to reduce the concentrations of, or avoid the emission of, pollutants to the environment.

• Groups involved in operations such as dredging or channelisation, which may disturb sediments and release pollutants into the water.

• Sectors or groups, in particular fishing and tourism, whose operations or activities are affected by the water environment and where reduction in the presence of substances proposed to have EQS will have a positive impact on business, human health or quality of life and alternatively tighter limits on the use of chemicals may impact on the aquaculture industry.

• Sectors or groups will benefit from reduced exposure from the use of polluted water as a result of the removal of the use of hazardous chemicals in the production of products and the potential emissions to air, soil and water.

Where possible, costs due to the full implementation of the Regulations and associated EQS, have been assigned to the relevant sectors. Benefits arising from the attainment of the EQS are more difficult to estimate within this RIA and qualitative comments have been made where appropriate. A summary of impact by sector is provided in Annex E.

4.4 ECONOMIC IMPACT

4.4.1 Option 1

Option 1 assumes that the proposed Regulations will not be implemented but that existing requirements are fully implemented. There will therefore, be no direct costs arising. However, if Ireland fails to reach the “good water status” by 2015 it is likely to result in European Commission proceedings against the State with likely significant cost implications. Regulations, controls and plans in place for the control of nitrates and phosphates are assumed to be adequate to address diffuse nutrient losses from agriculture. The failure to have such in place and fully implemented could result in the State not attaining “good water status” in certain instances. The costs associated with this failure have not been included in the RIA as the assumption has been made that they will be effective. Since June 2004, the EPA were obliged to take into consideration in the carrying out of their duties under Section 83(4)(a) of the Environmental Protection Agency Act 1992, the substances outlined in Annex VIII of the WFD. While there are no limits set within Annex VIII, the Agency is required to ensure that any operation under its control does not cause pollution to the environment. Strict enforcement of this is likely to result in costs similar to those outlined for IPPC facilities under Option 3.


25

The EPA is now licensing emissions from WWTPs under the Waste Water Discharge (Authorisation) Regulations, 2007. These Regulations have only just come into force and any potential positive impacts have not been identified to date. The system will operate in a similar fashion to IPPC licences with each WWTP having to apply for a licence and being assigned ELVs by the EPA with which it must comply. REACH came into effect in June 2007. The costs to Irish industry has been estimated to range from approximately €90 million to €600 million in total. This includes costs associated with the removal of certain chemicals from use. Reduced risk of damage to the environment was also identified as a key benefit of REACH. Costs outlined in the REACH RIA focused on the cost of testing, registration etc and the cost to industry of the removal of a substance from the marketplace. It did not assess the cost of at end-of-pipe treatment costs in order to control polluting substances. It is possible that some of the costs associated with end-of-pipe treatment options outlined in this RIA may not be incurred, as some of these substances may be subject to substitution or withdrawal under REACH, (thereby negating the need for treatment). While the “Do Nothing” option is not an approach that the Irish Government is likely to take, it should be noted that current Regulations, as set out in Section 2.5.2, are likely to have a significant positive impact on the surface water quality within Ireland once fully implemented. However, it is considered unlikely that this approach would be sufficient to control all parameters set out in the General Conditions and the list of 59 priority and relevant substances listed in Annex A. It is nonetheless recognised that there are challenges to be overcome in meeting the requirements set out in the Urban Waste Water Treatment Regulations. Additionally, failure of the Government to enact the proposed Regulations is likely to result in the imposition of fines by the European Courts. It is not possible to estimate the costs associated with this course of action but it can be assumed that the fines would not be insignificant.

4.4.2 Option 2

Option 2 assumes reliance on voluntary reductions in the concentrations to the required level (either at source or at the discharge point) for compliance with the Environmental Quality Standards. All current legislation will remain active. However, compliance with the EQS would be voluntary. How the EQS would be interpreted for IPPC and Section 4 and 16 licences is unclear, with one possible scenario being that the EQS would become de facto legal standards. However, it can be expected that not all stakeholders will fully participate in reduction of EQS pollutants and therefore comply with the proposed Regulations. In an effort to estimate the costs and benefits accrued from this approach, a figure of 50% was chosen to represent the mid point between the two options. The benefits are estimated to be only 50% of the benefits expected from Option 3 and conversely, the assumption has been made that the costs are also likely to be 50% of those expected from Option 3.

4.4.3 Option 3 - Overview

The most significant costs resulting from the implementation of the proposed Regulations will be borne by those responsible for limiting the discharge of substances to receiving waters. The costs to be borne will depend upon the extent to which activities are currently achieving the required EQS. For the General Components (e.g. nitrogen and phosphorus), some activities may be achieving discharge standards which do not pose a threat to the receiving waters achieving the required EQS. In such cases the


26

proposed Regulations may have no cost impact or the capital investment to upgrade plants may not be significant. However, for Priority Substances and Specific Relevant Pollutants, the new EQS may require significant capital investment and additional operating costs due to the technical challenges in treating waste water containing these substances. The treatment technologies which are known to be effective in reducing the discharge of Priority Substances and Specific Relevant Pollutants are listed in Annex F. The costs which are given in this section are for the most part based on the use of these technologies. Uncertainty remains regarding the treatment efficiencies that are achievable and the applicability of the technologies across the broad range of size and type of treatment plants in use in Ireland. Point Source Emissions

Municipal WWTPs

Municipal WWTPs typically monitor inter alia BOD, SS, total nitrogen and total phosphorus (some but not all of the General Components) but not Priority Substances or Specific Relevant Pollutants. Therefore, very little data is available to determine the load(s) of these later substances discharging from the plants into receiving waters. However, some limited data was available from the “National Dangerous Substances Screening Programme” and the “Municipal and Industrial Regulation POM Study”. The above programmes monitored the discharge and the nearby receiving water from a sample of 14 municipal WWTPs around the Country. The Population Equivalent (PE) for the WWTPs ranged from 1,000 to 2.3 million and included the Ringsend WWTP for Dublin City. Not all substances were monitored at all WWTPs. Annex G provides a summary of the Priority Substances/Specific Relevant Pollutants detected in WWTP effluent from the above monitoring programmes. Of the 59 parameters monitored, only 9 were not detected where these parameters were included in the analysis. However, it would be incorrect to assume that all other parameters are present in all effluents from all municipal waste water treatment plants. Further research is required to determine the presence and significance of these components. Substances detected in the effluent of two or more plants monitored by the studies are listed in Table 4.3. The substances listed in Table 4.3 appear to be present in the effluent from small municipal WWTPs and it may be concluded that these substances predominantly relate to domestic activities.

Table 4.3 Substances detected in the effluent of two or more WWTPs as classified in the proposed Regulations

Priority Substance/ Specific Relevant Pollutants

CAS Nr. PS /RP

Di (2-ethylhexyl) phthalate (DEHP) 117-81-7 PS Diuron 330-54-1 PS Lead and its compounds 7439-92-1 PS Nickel and its compounds 7440-02-0 PS Arsenic 7440-38-2 RP Copper 7440-50-8 RP Mecoprop 96-65-2 RP Zinc 7440-66-6 RP


27

Research in the UK has indicated that cadmium, copper, DEHP, lead, mercury, nickel and zinc are ubiquitous pollutants in WWTP effluents, and ranked of high concern in the UKWIR Priority Hazardous Substances Trace Organics and Diffuse Pollution (WFD) – Treatment Options and Potential Costs (Report Ref. No. 04/WW/17/5) Report. Studies have been carried out in the UK into the likely costs of providing for the removal of metals and organics from municipal waste water. (Ref. UK Water Industry Research, WIR). This report estimates unit costs (both capital and operational for Sand Filtration and Granular Activated Systems) for WWTPs with a range of population equivalent as follows.

Table 4.4 Upgrade Costs per WWTP (Capital and Operating Costs for Sand Filter and Granular Activated Carbon) from UK Water Industry Research, WIR

Population Equivalent (PE)

CAPITAL COSTS € M* OPEX € M/Yr*

2,000 0.486 – 0.975 0.041 – 0.045 2,000 – 10,000 0.542 – 1.068 0.044 – 0.111 10,000 – 50,000 0.821 – 1.227 0.038 – 0.435 50,000 – 200,000 1.863 – 2.030 0.071 – 1.100 1 M 5.553 – 7.427 0.240 – 5.420 * A conversion rate of UK Stg £ x 1.5 = € To calculate the costs associated with providing additional treatment to remove the substances at municipal WWTPs, the following approach was taken. • The load of substance to be removed was calculated (assuming that 50% of the

current effluent concentrations) for the five WWTPs in the various PE categories as identified in Table 4.5.

• The capital costs associated with Chemical Precipitation, Sand Filtration and Granular Activated Carbon (GAC) Treatment Systems were estimated for each of the five WWTPs. Refer to Annex J for further details.

• The costs were than applied pro-rata to all WWTPs within the relevant PE categories, to identify the potential costs on a RBD basis. Table 4.6 shows the number of WWTPs for the PE categories in each RBD.

A pilot plant and further assessment is recommended with regard to the treatment of metals to confirm this methodology.

Table 4.5 WWTPs in the various PE categories

Population Equivalent (PE) Range

300-500 500-2,000 2,000 -10,000

10,000-50,000

>50,000

WWTP from studies WWTP A WWTP B WWTP C WWTP D WWTP E Population Equivalent (PE) 400 1,200 6,650 20,000 100,000 Flow for Treatment DWF(m3/d) 90 270 1,657 4,164 22,500


28

Table 4.6 Number of WWTPs in each RBD

Population Equivalent (PE) Range RBD 300-500 500-2,000 2,000-10,000 10,000-50,000 >50,000 SWRBD 17 45 23 6 2 SERBD 28 57 33 11 1 ERBD 6 26 21 11 6 WRBD 2 29 20 6 1 SHIRBD 28 76 33 13 1 NWRBD 1 32 13 3 1 NBRBD 1 7 7 5 1 TOTAL 83 272 150 55 13

The Potential Capital Costs associated with the removal of Priority Substances and Relevant Pollutants are shown in Table 4.7. Refer to Annex J for further information. The limited information available indicates that there is the potential for very significant costs to arise. Operating costs will also need to be addressed to determine the full cost implications of removing the specified substances. Specific operating costs relating to the removal of Priority Substances and Relevant Pollutants include: • Granular Activated Carbon (GAC) regeneration (required approximately every 8

months) would equate to approximately €13.5M per annum for 573 WWTPs; • Chemicals cost associated with chemical precipitation of metals; and • Treatment and disposal of sludges arising from metal precipitation. The latter two operating costs specifically relate to metals removal and would need to be determined on a case by case basis, due the potential for huge variability in process requirements. Metal precipitation requires detailed chemical composition analysis of the influent, as well as pilot plant trials to determine the required chemical dosage and the achievable effluent concentration, as other constituents in the waste water may interfere with the process. Similarly, the sludge that results from metal precipitation may require specific treatment as they may be classified as hazardous waste. In addition, sludge resulting from metal precipitation may be difficult to dewater.

Table 4.7 Potential Capital Costs associated with the removal of Priority Substances/ Specific Relevant Pollutants

Potential Capital Costs in Euro (€) associated with the removal of Priority Substances/ Specific Relevant Pollutants from WWTPs

PE Range 300-500 500-2,000 2,000-10,000

10,000-50,000 >50,000 TOTAL

COST SWRBD 4,674,489 12,373,649 10,306,302 4,801,793 3,959,110 31,440,853 SERBD 7,699,159 15,673,288 14,787,303 8,803,287 1,979,555 41,243,432 ERBD 1,649,820 7,149,219 9,410,102 8,803,287 11,877,329 37,239,936 WRBD 549,940 7,974,129 8,962,002 4,801,793 1,979,555 23,717,478 SHIRBD 7,699,159 20,897,718 14,787,303 10,403,884 1,979,555 48,068,459 NWRBD 274,970 8,799,039 5,825,301 2,400,896 1,979,555 19,004,791 NBRBD 274,970 1,924,790 3,136,701 4,001,494 1,979,555 11,042,539 TOTAL 22,822,507 74,791,831 67,215,011 44,016,434 25,734,212 211,757,489 * Associated Operating costs have not been included in the above cost.


29

In terms of the cost impact as a result of General Components (physico-chemical), the Urban Waste Water Treatment Regulations set discharge limits for WWTPs for BOD and SS and in the case of “Sensitive Waters” also sets limits for total nitrogen and total phosphorus. Nutrient removal in the context of the Waste Water Treatment Regulations is only required in cases where the population equivalent exceeds 10,000. Due to the proposed EQS for the General Components it is feasible that nutrient removal may be required at discharges from smaller populations. Table 4.8 shows the total number of WWTPs greater than 300 PE, the number of WWTP discharging to Sensitive Waters, as defined by the UWWT Regulations and the number of WWTPs with Nutrient Removal. There are approximately 420 municipal WWTPs (PE>500) in the Country without Nutrient Removal. There are an additional 83 municipal WWTPs (500>PE>300) in the Country without Nutrient Removal (however this dataset is understood to be incomplete for PE<500). Therefore it is estimated that there are approximately 503 municipal WWTPs (PE>300) in the Country without Nutrient Removal. It would be an overestimation to assume that all plants currently without nutrient removal will require same in order to comply with the Regulations. A preliminary assessment of the receiving water data (comparison of median orthophosphate concentrations downstream of outfall to EQS from SWRBD – data available for 51% of receiving waters) indicates that approximately 39% of WWTPs may require phosphorus removal. A preliminary assessment of ammonia concentrations (SERBD data) available for 17 sites downstream of an urban pressure indicates that approximately 41% of WWTPs may require ammonia removal.

Table 4.8 Total Number of WWTPs, the Number of WWTPs discharging to “Sensitive Waters” and Number of WWTPs with Nutrient Removal for each PE Range

Total Nr.

Sensitive

Nutrient

Rem

oval

Total Nr.

Sensitive

Nutrient

Rem

oval

Total Nr.

Sensitive

Nutrient

Rem

oval

Total Nr.

Sensitive

Nutrient

Rem

oval

Total Nr.

Sensitive

Nutrient

Rem

oval

PE Range 300 - 500 500 - 2,000 2,000 - 10,000 10,000 - 50,000 >50,000 SWRBD 17 0 0 45 0 1 23 0 0 6 2 1 2 1 1 SERBD 28 3 0 57 12 2 33 7 4 11 7 3 1 0 0 ERBD 6 0 0 26 3 2 21 4 6 11 2 2 6 3 4 WRBD 2 0 0 29 2 0 20 1 8 6 1 2 1 0 1 SHIRBD 28 0 0 76 10 7 33 5 10 13 8 9 1 0 1 NWRBD 1 0 0 32 1 1 13 0 1 3 1 1 1 0 0 NBRBD 1 0 0 7 1 0 7 0 0 5 3 3 1 1 0 TOTAL 83 3 0 272 29 13 150 17 29 55 24 21 13 5 7 Note: The total number of WWTPs (PE>300) is 573. The total number of WWTPs (300PE)>300 without nutrient removal is 503. The dataset of WWTPs 300>PE<500 is understood to be incomplete. An assessment of the assimilative capacity of the receiving waters is necessary to confirm if nutrient removal is required at each of the above WWTPs. Monitoring data for General Components (physico-chemical) is readily available for WWTPs and their associated receiving waters. The WRBD, EPA and Compass Informatics are tasked with developing a tool to calculate 95%-ile, 50%ile and 30%ile flows in Irish Rivers, which at time of writing this report was not available. Once the statistical flows are determined, it will be possible to assess the assimilative capacity of the receiving waters to confirm whether Nutrient Removal is required at each of the above WWTPs.


30

A preliminary design and cost estimate for biological ammonia and chemical phosphorus removal for a plant in each PE range was prepared. A whole life cost per kg of nutrient removed was calculated (Refer to Annex J for cost estimate). The cost of removing ammonia and phosphorus from WWTP discharges was calculated for the extreme case i.e. all plants currently without nutrient removal will require nutrient removal. The numbers of plants without nutrient removal in each RBD are shown in Table 4.9 below.

Table 4.9 Number of WWTPs without Nutrient Removal

Population Equivalent (PE) Range

300-500 500-2,000 2,000 -10,000

10,000-50,000

>50,000

SWRBD 17 44 23 5 1 SERBD 28 55 29 8 1 ERBD 6 24 15 9 2 WRBD 2 29 12 4 0 SHIRBD 28 69 23 4 0 NWRBD 1 31 12 2 1 NBRBD 1 7 7 2 1 TOTAL 83 259 121 34 6 Work undertaken by UK DEFRA indicates that a figure of €9.45 (stg £ 6.30) per kg ammonia removed, represents an average cost across plants for the removal of ammonia. This figure includes both capital and operating expenditure over 30 years. Work undertaken for the Full RIA indicates that the UK DEFRA figures may be overestimated for the Irish situation, (in the context of larger scale facilities), and are possibly more representative of smaller scale plants in Ireland. Whole life costs – capital costs plus operational costs (NPV of operational costs calculated over 30 years at a discount rate of 5%) indicate removal costs range from €0.64/kg ammonia removed for PE>50,000, to €10.02/kg ammonia removed for PE<500. Operational costs were based on electrical and maintenance costs for installed plant and were not subjected to inflation increases. An ammonia concentration in the effluent of 3 mg/l was assumed, so further reduction in the effluent concentration would result in higher ammonia removal costs. This would equate to costs of over €9 Million per annum (whole life cost) for all WWTPs. If 41% of WWTPs require phosphorus removal (based on preliminary assessment) an annual cost of €3.7M (whole life cost) would be incurred. DEFRA also provides a range of unit costs for phosphorus removal depending on the population equivalent. The costs range from €4.50 (stg £ 3) per kg of P removed for PE>80,000 to €100.50 (stg £ 67) per kg of P removed for PE<2,000. Work undertaken for the Full RIA indicates that these figures may be overestimated for the Irish situation. Whole life costs – capital costs plus operational costs (NPV of operational costs calculated over 30 years at a discount rate of 5%) indicate removal costs range from €2.40/kg phosphorus removed for PE>50,000 to €12.12/kg phosphorus removed for PE<500. Operational costs were based on chemical costs, electrical costs, maintenance costs for installed plant, additional sludge treatment and disposal costs, and were not subjected to inflation increases. A phosphorus


31

concentration in the effluent of 1 mg/l was assumed, so further reduction in the effluent concentration would result in higher phosphorus removal costs. This would equate to costs of over €6 Million per annum (whole life cost) for all WWTPs. If 41% of WWTPs require ammonia removal (based on preliminary assessment) an annual cost of €2.3M (whole life cost) would be incurred. The “Municipal and Industrial Regulations Programme of Measures” study been undertaken by the SWRBD project will identify all WWTPs in the country requiring upgrading or investment based on the assimilative capacity of the receiving water (i.e. for N, P & BOD) for current and future (2015) PEs. The results of this study will enable more accurate costs to be attributed to Nutrient Removal. Preliminary results of the study indicate that the above costs may be overestimated. Additionally, the investment to be made as set out in the Water Services Investment Programme 2007 – 2009 (1), has not been taken into account within these figures. This is based upon the assumption that the 2007 – 2009 programme is focused on attaining the current quality standards and not the proposed EQS. A system for the licensing of waste water discharges from areas served by local authority sewer networks was brought into effect in September 2007. The licensing process was introduced on a phased basis (depending on PE of an area served by a sewer network) commenced on 14th December 2007 in accordance with the requirements of the Waste Water Discharge (Authorisation) Regulations 2007. The licensing process will give effect to restrictions or prohibitions on the discharge of dangerous substances and thus prevent or reduce the pollution of waters by waste water discharges. Combined Sewer Overflows (CSOs)

Combined Sewer Overflows (CSOs), stormwater overflows and urban catchment diffuse runoff, are examples of where further investment may be required to prevent uncontrolled or untreated releases, or where additional treatment may have to be provided. The Eastern River Basin District (ERBD) is currently undertaking a “Programme of Measures” study (POMs) on urban pressures. Included in the scope of the study is an assessment of the pollution loadings to surface water from CSOs and surface runoff from a number of various surfaces. The study covers the 33 largest urban centres in the country. The pollution loadings for a number of parameters have been assessed including nitrates, nitrites, total nitrogen, total phosphorous, cadmium, chromium, copper, iron, lead, mercury and zinc. The CSO discharges reviewed included on-line CSOs, high level pumped emergency overflows, pumped discharges, terminal CSOs (frequently located at WWTPs) and stormwater tank outfalls. A data review on the CSOs revealed that there was a significant deficit in data regarding frequency of spills, volumes and pollution loadings from CSOs, on a national basis. However, many of the larger drainage schemes had hydraulic models run at some stage. The POMS approach was to request a re-run of the models through the various local authorities and to determine the frequency of spills and pollution loadings for the above parameters. The POMS report found that there was no data available on CSO spill quality in an Irish context. Having investigated this matter in some detail, it was established that the most relevant source of data relating to CSO quality was contained within the UKWIR report – “Priority Hazardous Substances Trace Organics and Diffuse Pollution (Water Framework Directive) – Surface water drains and

(1) http://www.environ.ie/en/Environment/Water/WaterServices/WaterServicesInvestmentProgramme/


32

intermittent discharges from sewer networks” (1). Some of the standard parameters were not included in this RIA and for these substances, values were obtained from typical raw sewage concentrations. Where hydraulic models for particular urban centres were not available, the loadings were extrapolated. The end result of this work was a calculation of annual pollution loadings for the above named parameters from CSOs. The POM study noted that as the main drainage schemes in the large urban centres were being completed, there was a significant reduction in the number of CSOs and consequential pollution load from CSOs. A similar approach was taken to calculate the urban surface run-off diffuse loadings. Urban catchment diffuse runoff comprises of runoff from permeable or impermeable areas which may or may not be connected to storm sewer systems. Suitable catchment surfacewater runoff factors were identified based on the nature of the surface. Twelve different surface types were selected for the purposes of the POM study including highways, residential and open spaces. The Irish runoff concentrations for the above-named parameters were determined by reviewing a number of studies including the 2000 “Impact Assessment of Highway Drainage on Surface Quality” and the 2002 final report “The Three River Project – water Quality Monitoring and Management”. A rainfall dataset was selected and annual diffuse runoff pollution loadings were calculated for the selected parameters. While the ERBD POM study will provide a useful means of providing pollution load estimates from CSOs and surfacewater runoff, it only covered a limited number of substances. At the time of writing, the ERBD study had yet to be completed. While pollution loadings have been quantified in the POM study, no remedial measures or resulting costs had been proposed to deal with those pressures. Future planning for waste water collection and treatment may have to consider the collection and treatment of these sources. No meaningful costs could be applied to this section as it is very site specific. IPC/IPPC Industries

There are a total of 482 operational IPC/IPPC industries in Ireland, of which 103 discharge to waters Table 4.10 and approximately 298 discharge to sewers. Depending on conditions set in IPC/IPPC licence treatment of effluent is required to meet discharge consents which would be specific to each industry. Table 4.11 provides a provisional list of Priority Substances and Specific Relevant Pollutant substances discharging to Waters from IPPC industries. The SERBD project has sent out questionnaires to at least one industry in each NACE category to quantify the usage of each substance. This data is currently been compiled and quantities of substances can than be allocated to the various industries. The survey also addresses total nitrogen and phosphorus (General Component substances) as well as total organic carbon (TOC). The European Pollution Emission Register was also cross referenced, and the list in Table 4.11 was found to be more comprehensive.

(1) http://www.change-climate.com/library/80892/04%2DWW%2D17%2D2


33

Table 4.10 Number of IPPC Industries discharging to Waters

IPPC Industries discharging to Waters

Cod

e NACE General Classification Description

SWR

BD

SER

BD

ERBD

WR

BD

SHR

BD

NW

RBD

NBR

BD

Tota

l

Total Nr. Discharging to Waters 21 24 22 6 20 5 5 103 C Mining and quarrying of energy producing products 3 2 4 9 C Mining and quarrying, except of energy producing materials 1 1 2 D Manufacture of food products, beverages and tobacco 5 12 3 1 9 4 2 36 D Manufacture of textiles 1 1 2

D Manufacture of pulp, paper and paper products; publishing and printing 1 2 3

D Manufacture of coke, refined petroleum products and nuclear fuel 2 2

D Manufacture of chemicals, chemical products 4 5 9

D Manufacture of chemicals, chemical products and man-made fibres 8 2 2 2 1 15

D Manufacture of rubber and plastic products 1 1 D Manufacture of other non-metallic mineral products 1 3 1 1 1 7 D Manufacture of basic metals and fabricated metal products 1 2 3

D Manufacture of fabricated metal products, except machinery and equipment 1 1 2

D Manufacture of electrical and optical equipment 1 1 E Electricity, gas and water supply 2 1 4 1 1 9 D Manufacture of wood and wood products 1 1 2

Table 4.11 Substances from IPC/IPPC discharging to Waters

Substance CAS No. Benzene 71-43-2 Cadmium and its compounds 7440-43-9 Dichloromethane 75-09-2 Lead and its compounds 7439-92-1 Mercury and its compounds 7439-92-1 Nickel and its compounds 7440-02-0 (benzo-g,h,i-perylene) 191-24-1 Arsenic 7440-38-2 Chromium 7440-47-3 Copper 7440-50-8 Cyanide 57-12-5 Fluoride 16984-48-8 Toluene 108-88-3 Xylenes Total 1330-20-7 Zinc 7440-66-6 Source: Preliminary data from IPC/IPPC Questionnaires received to date, SERBD Project The UK DEFRA provides abatement costs for certain key sectors for the treatment of metals and organics to meet the required EQS as shown in Table 4.12. It is assumed that some treatment capacity is already in place.


34

Table 4.12 Costs of removing pollutants from Industries

Costs of removing pollutants by sector and type of industry in Euro (1.5 x £ sterling/kg removed, secondary treatment) (annualised, 15 years @ 3.5%) Cost of removing Metals

(€/kg) Cost of removing Organics (€/kg)

Sector Lower Bound Upper Bound Lower Bound Upper Bound Chemicals & Pharmaceutical

800.03 2105.66 3.54 7.52

Paper and Pulp 8.75 42.93 0.12 1.74 Metal Finishing 1.14 7.93 8.73 15.96 Textiles 157.94 - 2.46 9.24 The cost of meeting the EQS will need to be calculated for each source of discharge, based on the assimilative capacity of the receiving water and the level of reduction required. To identify a range of costs associated with IPCC industries discharging to water/sewer in the absence of detailed effluent data and assimilative capacity calculations, the following approach was taken: The minimum and maximum load of metals and organics for a range of industries (1 industry per NACE code, SERBD data) was identified and using the upper bound rates given in Table 4.12 a cost range for IPCC industries was calculated. The cost given is a whole life cost (annualised, 15 years @ 3.5%) for a single industrial facility. Treatment cost estimates per IPPC industry discharging directly to waters range from €40,000 to € 4.2 M (whole life costs per annum). Similarly, treatment cost estimates for IPPC industry discharging to sewer range from €90,000 to € 4.2 M (whole life costs per annum). This gives an indication of the huge range in costs associated with the treatment of pollutants for IPPC industries due to the variability in pollutant loads. There will also be costs incurred by industries resulting from additional measures associated with the requirement to cease or phase-out discharges of Priority Hazardous Substances, such as mercury and cadmium. There could be high costs associated with cessation where no suitable alternatives are available. The calculation of these costs was outside the scope of this project. The RIA on the REACH Regulations would be more informative on this matter. The cost impacts identified for the municipal WWTPs are based on the monitoring data currently available and as such would be inclusive of Priority Action Substances and Specific Relevant Pollutants originating from non-domestic i.e. IPPC and Section 16 discharges, sources discharging to sewer. The costs which have been attributed to IPPC licensed industry may be indicative of the order of costs which may be attributed to the non-domestic sector and may in turn be removed from the WWTP costs if treatment at source was undertaken. In an effort to simplify the scale of the task involved for some industries a more simplistic qualitative approach is presented here purely as a descriptive tool. By taking a sample of ELV for IPPC licensed facilities and comparing these with the proposed EQS, it is noted that in some cases dilution of several hundred times would be required to meet the EQS. Where this is not possible additional treatment may be required to be installed, or substances will have to be restricted or their use banned. The calculations are set out in Annex J.


35

Water Pollution Acts 1977 and 1990, Section 4 and 16 Discharges

All discharges of trade effluent, domestic sewerage from septic tanks direct to surface waters and domestic sewage greater than 5m3/24hrs to aquifers, must be licensed by the relevant local authority. A Section 4 licence relates to discharges directly to water bodies and a Section 16 licence relates to discharges to sewers. IPPC licensed emissions to both sewers and water bodies are controlled by the EPA. However, the local authorities are consulted and ultimately set the minimum standards/limits to be applied. The renewal and updating of existing Section 4 and 16 licences and the enforcement of licence conditions, is inconsistent around the country. The level of compliance verification may not be sufficient going forward to ensure that all the parameters are being correctly monitored and assessed. This is particularly true for parameters that have new EQS, or were not previously identified in the emission characterisation provided by the industries. Currently, the level of information available on the sources of polluting parameters is not good enough to identify and characterise the emissions associated with Section 4 or 16 discharges, (i.e. it is not possible to precisely align a specific parameter with a specific industry or other discharge source), although Annex C provides some guidance. Industries associated with Section 4 and 16 discharges are typically small to medium size industries (SMEs) which are below the threshold for IPPC licences. Hospitals, housing estates, restaurants and hotels, small agricultural operations etc make up the remaining categories of sources. From reviewing the information in Annex D, it is apparent that Section 4 discharges have been identified as potential sources of contamination and the Section 16 discharges are covered by WWTP discharges. The control of these emissions is therefore likely to require more stringent monitoring and a more detailed application process to ensure more accurate characterisation of waste water arriving at WWTP. SMEs are less likely to have the capacity or the capability to treat discharges to a higher degree. They are also unlikely to have an appreciation of the substances that they are discharging. A cost benefit analysis of the installation of treatment facilities for Section 4 or 16 discharges at SMEs is likely to indicate that the required facilities would not be installed (1). It is therefore reasonable to assume that the costs outlined in Table 4.12 (for IPPC industries) will also be applicable to Section 4 and 16 industries. At this stage it is not possible to calculate more accurate figures as there is no information available to describe the typical emissions from these sources or the scale of the facilities that may be needed. This is likely to result in considerable additional costs for local authorities, and the Department, through the provision of collection and treatment services where feasible, or the development of schemes to assist SMEs to meet potentially stricter Section 4 and 16 licence ELVs. There will also be a resource issue for the local authorities to ensure that all emissions that should have previously been licensed are now licensed, taking into account any new ELVs. Local authorities will have to develop a much more detailed knowledge of the sources of pollutants discharging to the sewer systems under their authority so that they can: 1) identify the pollutants that need to be treated; 2) place controls on emissions from these sources; and

(1) This is based on the assumptions that: there will be insufficient space on the site for the system; inadequate personnel on site to operate a system; and it would ultimatly be cheaper to dishsrge it to sewer.


36

3) allow for effective traceability of potential sources of pollution following incidents within the system.

Through the consultation process, a number of the local authorities suggested a level of resources/ additional investment they felt would be necessary to enable them to carry out this work in a satisfactory manner. Initially, to review all the licences and implement appropriate monitoring programmes, costs ranged from approximately €115,000 to €350,000 over two years, with on-going annual costs estimated to be as high as €275,000. These costs would have to be carried by the local authorities or additional funds requested from the central exchequer. For the 29 County Councils, five City Councils and five Borough Councils, the total cost for the initial two year period could range from €4,485,000 (39 x €115,000) to €13,650,000 (39 x €350,000) to review, update and implement the administrative requirements of these Regulations and could have on-going annual costs of up to €10,725,000 (39 x €275,000). A rigorous assessment of these figures was not carried out and is based upon the responses provided by the local authorities and could therefore be assumed as the maximum likely figure. Additionally, the figures were applied equally across all 39 County, City and Borough Councils. It should be noted that the local authority could pass on a significant portion of the costs incurred in the construction and refit of WWTPs, back onto the industries and sectors that discharge to the sewers and surface waters. This could be achieved through the existing mechanism of the Water Services Pricing Policy. It is felt that while this may be an effective mechanism for the recovery of costs, there will be significant opposition and resistance from industrial sectors unless there is strong scientific backing to the proportional costs being applied, (i.e. the local authorities would have to be able to identify how much they are investing in the WWTP to treat the portion of priority substances coming from industry compared to the investment being made for the portion arising from domestic sources). Other potential local authority costs

Sludge Management

New waste water treatment processes are likely to result in additional quantities of sludge from the WWTP. Actions taken by both the EPA and local authorities in relation to the control and enforcement of the new EQS may result in more contaminated sludge being produced either at the WWTP, or at on-site industrial WWTP. Further analysis of these costs has not been carried out, but it is noted that sludges produced as part of the new process may be classed as hazardous waste and could require more expensive management and have fewer disposal outlets. In parallel to this, the European Commission is planning to revise the Directive on Sewage Sludge 86/278/EEC. This revision is likely to tighten the controls on the level of contaminates permitted in sludge to be spread on land. This revision, going hand in hand with potentially higher concentrations of contaminates in the sludge as a result of the additional treatment, may lead to a situation where large volumes of sludge will have to be exported from Ireland for incineration, which could have significant costs on the running of WWTP. Landfill leachate

There are currently 65 licensed landfills in the country, of which 36 are old (existing when licensed) and 29 are new (constructed after EPA licensing commenced) (EPA


37

Dataset). Information on closed landfills is not readily available and would require investigation to determine numbers present. A report published by the EPA in 2005 on “The Nature and Extent of Unauthorised Waste Activity in Ireland”, stated that there were 25 identified unauthorised landfills in the country, ranging from approximately 1,000 tonnes to 360,000 tonnes. The quantity and composition of landfill leachate varies with the design and age of the landfill and the composition of waste accepted. In 2005 there were 32 landfills in the country accepting 1,824,066 tonnes of municipal waste, which comprised 1,193,872 tonnes of domestic waste and 630,194 tonnes of non-household waste (The National Waste Report EPA, 2005). Chemical analysis (undertaken at Balleally landfill for the “National Dangerous Substances Screening Programme”), indicated that 32 Priority Substances and 15 Specific Relevant Pollutants were detected in one or more samples (total of 12 samples). However, the leachate volume produced by Balleally was not readily available. The pollutant load determined for a specific landfill and a resultant cost for the treatment of the leachate would not be representative of all landfills currently operating in Ireland. Some facilities currently treat leachate onsite while others transport it to a municipal WWTP, where it is added to the treatment stream. In addition to the processes required to treat Priority Action Substances and Specific Relevant Pollutants, treatment of general parameters BOD, N and P would also be required. The treatment process and relevant costs will need to be identified for each landfill individually. The impact of treating landfill leachate at source would need to be assessed and compared with its treatment at a WWTP. Due to the lack of adequate information and the high variability of leachate, it is not possible to provide meaningful costs associated with this source. A study should be undertaken to help characterise leachate from landfills. Road Run-off

The National Roads Authority was consulted in relation to the control and treatment of road run-off. A study (1) has been carried out which indicates that the systems in place for the capture and treatment of road run-off are successfully mitigating potential impact from road run-off to surfacewaters, but are likely to be impacting on adjacent soils and subsurface waters. The NRA have also indicated that an updated guidance document is currently being developed in relation to the design of run-off capture and treatment systems, which should further improve the situation. However, the study also highlighted that additional maintenance of the systems once installed would need to be carried out. This is not currently done, mainly due to lack of resources. Moving forward, this may require additional resources to be allocated by the local authorities and NRA. Monitoring Costs

The WFD Monitoring Programme commenced in January 2007. The costs associated with this monitoring program have already been realised. However, it is understood that significant additional monitoring may be required as the new EQS apply to all water bodies. More rigorous compliance monitoring may also be required which will require additional resources. EQS relating to metals may also require background levels to be established for all water bodies to be monitored. The position in relation

(1) Michael Bruen, Paul Johnston, Mary Kelly Quinn, Mesfin Desta, Neill Higgins, Catherine Bradley; Impact Assessment of Highway Drainage on Water Quality 2000-MS-13 Synthesis Report, Draft. December 20, 2005.


38

to background metal concentrations has not been finalised but a monitoring programme to establish background metal levels would require significant additional resource allocation to the Agency that undertakes the work. Sampling costs for industries to confirm and/or identify the presence of priority substances are not considered to be significant. Potential on-going compliance monitoring has not been determined as there is insufficient information at this stage to estimate costs, while enforcement mechanisms have not been confirmed. However, the Regulations are likely to result in an increase in monitoring requirements and potential tracking of emissions for the Pollution Emission Register. This will require additional allocation of resources and additional costs to industry. Monitoring of emissions by the EPA from IPPC installations and waste facilities may also change as a result of the EQS, in that discharges from point sources will continue to be sampled but may require additional receiving water sampling and analysis to be carried out to show corresponding compliance with EQS. The requirement for additional monitoring will have to be assessed on a site by site basis taking into account the scale of the operation, the water quality and the risk of not obtaining good status. This would ultimately result in additional costs to industry as monitoring costs are passed on through the IPPC licence system. During discussions with the EPA it was noted that further clarification is required in relation to the issue of mixing zones and the sampling regime and compliance requirements associated with the Regulations. There would be concerns if monitoring locations were located too close to, or within, mixing zones, if the EQS did not or could not take account of changes in river flows or adverse weather conditions, and if the EQS did not allow a percentage failure rate which would allow for minor fluctuations or changes in river characteristics or laboratory error. Diffuse Nutrient Pollution

Agriculture

Agriculture has been identified as one of the key source of diffuse pollution leading to surface and groundwater being categorised as being ‘at risk’ of pollution. Nutrient enrichment, leading to eutrophic conditions in surface water bodies is the main cause for this categorisation. It is assumed for the purpose of this analysis, that the full implementation of the Good Agricultural Practice for the Protection of Waters Regulations 2006 & 2007 implemented to give effect to the Nitrates Directive (Council Directive 91/676/EEC) supported by ‘cross compliance’, will address the issue of diffuse nutrient pollution from agriculture and no additional cost is assumed for the purpose of complying with the nutrient standards proposed. Forestry

Commercial forestry is also a potential source of diffuse nutrient pollution. Regulations and guidelines have been developed to control the potential risks. These are assumed to be adequate for the purpose of this analysis. This is supported by research (1) that indicates agriculture, urban and industrial sources and septic tanks are the main sources of nutrient pollution, with forestry contributing approximately 3% in this case.

(1) KMM and Pettit (2003) Lough Leane Catchment Monitoring and Management System. A catchment based approach for reducing nutrient inputs from all sources to the Lakes of Killarney. Final Report.


39

Septic Tanks

Diffuse rural developments (i.e. one off housing or small multi-house developments) which are linked to septic tanks and/or proprietary systems, are also a potential source of pollution. These systems may potentially contribute not only nutrients, but a whole range of chemicals that are used in domestic situations, as set out in Section 2.5.2. It is probable that the current level of treatment may not be sufficient to ensure future compliance with EQS. This may result in additional costs, not only to developers and the householder who may be required to install more advanced waste water treatment facilities, but also local authorities, who may be required to provide treatment or collection facilities. Planning sections within the local authorities may also have to take the treatment of waste water into consideration requiring, for example, WWTPs to be built in advance of, or in parallel with, future development. According to the 2006 Census, there are a total of 1,462,296 private households in the country, of which 418,033 (29%) are served by individual septic tanks, a further 29,685 are served by individual treatment systems. In total, this represents approximately 31% (447,718) of private households in the country. The number of households and the type of sewerage facilities on a national basis is shown in Table 4.13 below.

Table 4.13 Type of Sewerage Facilities on a National Basis

Type of Sewerage Facility Number of Private Households Public Scheme 956,239 Individual Septic Tank 418,033 Individual Treatment System 29,685 Other 6,979 No sewerage facility 4,179 Not stated 47,181 Total Number of Households 1,462,296 Source:2006 Census Volume 6 Housing, CSO web-site 2007 The Census also provides a breakdown of the type of sewerage facility based on “Aggregate Rural Area” and “Aggregate Town Area”. In rural areas, 72% of dwellings are served by individual septic tanks according to the Census. In total, 77% of dwellings (420,988) in rural areas are either served by individual treatment systems or septic tanks as shown in Table 4.14. By comparison, only 3% of dwelling in Town Areas are served by septic tanks or individual treatment systems. Private dwelling are also classified by the Census by the period in which they are built and the breakdown is shown in Table 4.15 for rural areas. According to Census data, the greatest numbers of dwellings in rural areas per decade were built in the period after 2001. However an almost equivalent number of dwellings were built in the period before 1919, while 52% of dwellings in rural areas were built in the period up to 1980. There has been an increase in the use of proprietary systems over the past number of years in Ireland and prior to this, many rural areas were serviced by septic tanks. It is likely that many of the older dwellings (built before 1996) would have septic tank systems rather than individual treatment systems. It could be assumed that in the majority of cases, the septic tank would be of an equal age to the dwelling itself. If not regularly inspected and maintained, these septic tanks may allow seepage to the nearby water-bodies.


40

Table 4.14 Type of Sewerage Facilities in Aggregate Rural Areas (National Basis)

Type of Sewerage Facility Number of Private Households in Aggregate Rural Areas

Public Scheme 109,054 Individual Septic Tank 393,197 Individual Treatment System 27,791 Other 4,362 No sewerage facility 3,595 Not stated 11,633 Total Number of Households 549,632 Source: 2006 Census Volume 6 Housing, CSO web-site 2007

Table 4.15 Dwellings in Rural Areas classified by the period in which they are built

Period in which Built Number of Dwellings in Aggregate Rural Areas

% of dwellings built in each period

Before 1919 87,958 16% 1919 to 1940 48,206 9% 1941 to 1960 45,717 8% 1961 to 1970 30,131 5% 1971 to 1980 77,017 14% 1981 to 1990 69,306 13% 1991 to 1995 30,188 5% 1996 to 2000 55,034 10% 2001 or later 92,177 17% Not stated 13,898 3% Total 549,632 Source: 2006 Census Volume 6 Housing, CSO web-site 2007 A breakdown of the septic tanks and individual treatment systems for rural areas on a Regional Authority basis is shown in Table 4.16. The Border, West and South West regional authority areas have the highest numbers of septic tanks in the Country. The GSI web-based groundwater vulnerability map shows the South-West Region and the Border Region as having a high proportion of high and extreme groundwater vulnerability areas. The West also shows some areas of extreme vulnerability. There are also some regionally important and locally important aquifers that overlap with the vulnerable areas within each of the regions mentioned above. If septic tanks or single house treatment systems are not working correctly, waste water may seep into the groundwater and/or contaminate the nearby surface water. Additionally, poorly maintained septic tanks have the potential to become a threat to public health, as well as becoming an odour and visual nuisance. Non-functional septic tanks or single house treatment systems can also cause the deterioration of the natural habitat and amenity areas. According to the River Basin District’s “Water Matter’s” Reports, limited research to date suggests that many systems are not working properly (refer Section 2.5.2).


41

Table 4.16 Type of Sewerage Facilities in Aggregate Rural Areas (National Basis)

Sewerage Facility

Total

Border

Dublin

Mid-East

Midland

Mid-W

est

South-East

South West

West

Septic Tank 393,197 70,776 4,180 38,942 34,885 46,855 58,673 68,163 70,723 Individual Treatment System

27,791 5,524 811 4,682 1,870 2,526 5,871 3,435 3,072

Total Number 420,988 76,300 4,991 43,624 36,755 49,381 64,544 71,598 73,795

The WRBD project is currently undertaking extensive research in relation to onsite Waste Water Treatment Systems (OSWTS) affecting both surface and groundwaters. The project is developing risk maps based on soil, subsoil permeability, wet and dry index, vulnerability map, aquifer rock unit type, recharge coefficients and sensitive receptors. It is anticipated that the report from the WRBD will determine the extent to which surface waters are being impacted upon by OSWTS and it is hoped that the maps and data being developed may be used as a means of prioritising remedial works. Interim information from the WRBD suggests provisional remedial measures for existing and future systems. Some of the possible measures are as follows: • Upgrading the septic tank to a proprietary treatment system; • Provision of a sewer network and treatment facility; and • Provision of a Framework Document on the approach to site investigation

requirements for Large Scale Developments (> 5m3/day) discharging to groundwater.

Septic tanks and proprietary systems can cause environmental problems whereby: • Adequate planning is not given to their installation resulting in insufficient

soakaway areas being provided or insufficient tank volume; • They are located at sites which are unsuitable such as on poorly drained land e.g.

clays or where there is a vulnerable waterbody; • They are poorly installed e.g. provision of inadequate soakaway or installation of

structurally unsound tank; • The incorrect system is installed at a site i.e. the site would be more suited to a

different system; and/or • There is a lack of inspection, maintenance and monitoring of the systems resulting

in fouling/blocking of the system. Remediation costs for septic tanks were outlined at the OSWTS Conference in Mullingar in September 2007. Remediation of a site which is generally suitable for a septic tank and percolation area is estimated at around €7,000. For more difficult sites, which need to be engineered, the cost could be up to €20,000. There is a pilot study being undertaken in relation to “Waste Water Collection and Treatment for Rural Villages” (Septic Tank Effluent Drainage System (STEDS) – North Tipperary County Council) which is assessing: • New cost effective ways of providing waste water collection and treatment of small

villages; • A range of innovative technologies including conventional and membrane based

package plants as well as vacuum sewers as opposed to traditional gravity sewers;


42

• The potential for group sewerage schemes to provide a collection system to houses not connected to the new pilot projects; and

• The feasibility of a contractor to provide septic tank dislodging and maintenance services to households which cannot be connected to a collection system.

The cost of this remediation approach was working out at €25,000 per house. Making the assumption that one third of all septic tanks (418,033) in the country are not working properly this would equate to 139,330 systems which are defective and require upgrading. Allowing a cost of €7,000 per house this would equate to €975,310,000 (139,330 x €7,000) on a national basis. Given that in Section 2.5.2 it was identified that in some areas up to 95% of systems were located on inappropriate sites and only €7,000 per house was allowed in the calculation, it is reasonable to assume that these figures could be considered an under-estimate of the potential real cost which could be up to three time this figure, approximately €3 billion. In Section 2.5.2, outlined the number of single house proprietary systems that are being maintained and managed properly in Ireland. Of the proprietary systems assessed, it emerged that only 1% to 25% of customers maintain a service and maintenance contract with the system provider. It is assumed that the remaining units do not undergo regular servicing. Often the first indication that these system are not operating correctly is when there is an overflow of sewage into the environment. On the assumption that this low level of management is applied for all single house proprietary systems (29,685), it is reasonable to assume that between 22,634 and 29,388 units require remediation work. Using the costs from the OSWTS Conference (€7,000 per house), it may be estimated that remediation costs would amount to between €158,438,000 and €205,716,000 nationally. The Department of Civil, Structural & Environmental Engineering at Trinity College Dublin have recently undertaken a study of onsite waste water treatment in Ireland. The sewage treatment system most commonly used where it is not feasible to connect to sewer is the conventional septic tank with percolation area. The focus of the study was to investigate the performance of such onsite systems at seven different sites in Ireland over the past five years. A linked project has also been investigated the breakdown of effluent as it percolates through subsoil of different characteristics and looked at the suitability of a site for the installation of a treatment system. In general, sites requiring remediation would probably need a new percolation area being built as a minimum which would cost in the range €4,000 - €10,000 for a single house, depending on the size and type of treatment unit (1). These costs are in line with the costs outlined in the OSWTS Conference. The current reference document for the installation of septic tank in one off developments is SR6: Septic Tank Systems: Recommendations for Domestic Effluent Treatment and Disposal from a Single Dwelling House (2). This document was originally published in the 1970s and was updated in 1991. A circular (SP 5/03) from the Department of Environment, Heritage and Local Government suggested that local authorities should take into consideration the process suggested within the EPA draft “Code of Practice: Waste Water Treatment Systems for Single Houses”, which is currently going through a consultation process. Benefits from the implementation of

(1) Personal communication - Laurence Gill Department of Civil, Structural & Environmental Engineering at Trinity College Dublin(2) EN 12566 Small Wastewater Treatment Systems for up to 50 PT will come into full effect across Europe in July 2008 when it will replace SR6 with a single harmonised standard.


43

the guidance document are likely to be the improved selection and location of treatment processes and reduced diffuse pollution from these systems. Costs associated with these guidelines are going to be two fold: 1) Developers are going to have to spend significantly more money on the testing of sites for suitability and therefore the cost of making a planning application will increase; and 2) The review of the planning application will require more time and resources to be committed by the local authority and it has been suggested (1) that the review should include Environmental Health Officers, chemists, hydro-geologists, planners, civil engineers and engineering/building technicians. The cost for the site characterisation report is expected to increase the cost for the applicant from approximately €500 to €900. However, there are no costs suggested in relation to the additional time to review the applications. The code also sets out minimum maintenance requirements for septic tanks and recommends regular inspections (approximately every 6 months) and sludge pumping every 2 years. Peat Extraction

Harvesting of peat from bogs can also result in elevated levels of ammonium down-stream of the activity. It is unclear as to the level that can be attributed to these areas or what means of treatment would be appropriate given the typically hydrometric relationship between bogs and the surrounding water systems. In this case it may be appropriate to look for some form of exemption in relation to areas downstream of this activity, or design monitoring plans around these areas, taking into consideration the requirement for mixing zones. There is no detailed information available as to the quantity or nature of ammonium releases from bogs due to peat extraction. A high level assessment of the installation of treatment systems at discharge points from bogs is considered technically difficult and the benefits to be gained from it are considered to be low. Before a detailed assessment of costs is carried out, work would be required to clearly establish the level and nature of ammonium discharges from bogs during peat extraction and this should be compared with typical discharges from a bog that is not being harvested.

Pesticides

Pesticides and their use have been identified as a potential source of diffuse pollution, arising from agriculture, forestry (less than 1% of the total usage) and domestic usage. Currently, all pesticide use is controlled by Regulations (refer Section 2.5.2). Under the current system, before a plant protection product (PPP) can be placed on the market or used, it must conform to rigid controls specified in accordance with the legislation. The legislation is designed to ensure that no harmful effects arise for human or animal health and that there is no unacceptable impact on the environment. Only PPP which can be used safely are authorised for marketing and use. The conditions of authorisation are selected to minimise risks for consumers, workers and the environment. Where an EQS for a pesticide is breached, the WFD would require

(1) Gordon Daly, Waste Water Treatment for Single Rural Houses, Pleanail: Journal of the Irish Planning Institute. Issue 17. Spring 2007.


44

measures to be implemented to restore good surface water ecological status or good surface water chemical status. Table 4.17 and Table 4.18 list the pesticides identified, within the 59 substances that will be covered under the proposed system.

Table 4.17 Pesticides Identified contained within the list of 33 Priority Substances and 8 Other Pollutants

Substance Detected in Screening Program

Exceeded Proposed EQS

Priority Substances 1,2-Dichloroethane Yes No Alachlor Yes No Atrazine Yes No Chlorfenvinphos Yes No Chlorpyrifos Yes No Diuron Yes No Endosulfan Yes No Hexachlorocylohexane (Lindane)

Yes No

Isoproturon Yes No Pentachlorophenol Yes No Simazine Yes No Tributyltin Yes No Trifluarin No No Dangerous Substances Aldrin Yes No Dieldrin Yes No Endrin Yes No Isodrin Yes Yes para-para DDT Yes Yes

Table 4.18 Pesticides contained within the list of 18 Specific Relevant Pollutants

Specific Relevant Pollutants

Detected in Screening program

Exceeded Proposed EQS

Dimethoate Yes No Glyphosate Yes No Mancozeb Yes No Mecoprop Yes Yes It is not possible to estimate the potential costs associated with the control of pesticides based upon the EQS approach. The impact will depend upon the effectiveness of the control measures currently in operation and enforcement actions taken by the appropriate authority if an EQS is exceeded. The majority of the substances in the Tables 4.17 and 4.18 are primarily used as pesticides in agriculture, which is controlled by the Pesticide Control Service (PCS), under the aegis of the Department of Agriculture, Fisheries, and Food. The PCS has provided details on the quantity of substances applied to land as pesticides. The results of their studies are described in the following two publications:


45


46

• Department of Agriculture, Fisheries and Food (DAFF) (2003): Pesticide Usage Survey Report No 1 – Grassland and Fodder Crops 2003. www.pcs.agriculture.gov.ie.

• Department of Agriculture, Fisheries and Food (DAFF) (2004) Pesticide Usage Survey Report No 2 – Arable Crops 2004. www.pcs.agriculture.gov.ie.

Forestry accounts for approximately 11 % of the land cover in Ireland (1), while agriculture accounts for 67% (2). Data on the use of pesticides in forestry, held by Coilte, was unavailable at the time of writing this report. It must also be noted that there is no data available for pesticide use on privately owned forests. It was possible to ascertain that the forestry managed by Coilte is treated with cypermethin to control weevils and glyphosate to control the growth of weeds. Up to-date data on the use of substances in finfish aquaculture as pesticides, medicines and detergents was provided by the Marine Institute. None of the 59 substances covered in the RIA were described as being used in the finfish aquaculture sector (3). The report produced by the Marine Institute on “Dangerous Substance Usage in Finfish Aquaculture” outlines the substances that are used. Information regarding the substances used by shellfish aquaculture was unavailable at the time of writing. Data regarding the quantities of substances used by the industry is not available. Similarly, there is no data available regarding the use of chemical substances municipally, or domestically. Although the Central Statistics Office collate data regarding the quantities of substances imported to, and exported from Ireland annually, the data is based on categories of chemicals. There was no data available for quantities of the individual substances, except for 1,2 – Dichloroethane. Table 4.19 provides a description of the status, uses, quantities (where available), effects, and substitutes of the substances in question. More detailed information is provided in Annex K. Historically agriculture was a key source of Gross Domestic Product (GDP), a measure of the Irish economy, for Ireland. However, in recent times the importance of the primary sector (eg agriculture, forestry, aquaculture etc) to the Irish economy has reduced and now only makes up approximately 5% of the Irish GDP. Any potential impact on this sector of the economy should be considered in light of its decreasing importance to the Irish GDP. The Pesticide Control Service of the Department of Agriculture, Fisheries and Food are responsible for the control and implement of the regulatory system for biocidal products, for the classification, packaging and labelling of plant protection and biocidal products and for the national monitoring and enforcement programmes relating to residues in raw agricultural produce.

(1) Teagasc (2005) Forestry Statistics 2005, www.client.teagasc.ie/forestry/(2) Teagasc (2007) Agriculture in Ireland, www.teagasc.ie/agrifood/index.htm(3) Marine Institute (2007) Dangerous Substance Usage in Finfish Aquaculture


47

Table 4.19 Summary Table

Substance Status Uses Effects SubstitutesPriority Substances 1,2-Dichloroethane Agriculture – banned

Industry – permitted Agriculture, Industry Need for water treatment Chlorinated

hydrocarbons Alachlor Agriculture – banned Agriculture – herbicide Direct negative effects Need for water treatment Possibly acetochlor

Others not specified Atrazine Agriculture – banned Agriculture – herbicide Direct negative effects Need for water treatment Possibly acetochlor

Others not specified Chlorfenvinphos Agriculture – banned Agriculture – insecticide Direct negative effects Need for water treatment Not specified Chlorpyrifos Agriculture – permitted Agriculture – insecticide Direct negative effects Need for water treatment Not specified Diuron Agriculture – permitted

until end 2007 Agriculture – herbicide Direct negative effects Need for water treatment Not specified

Endosulfan Agriculture – banned Agriculture – insecticide Direct negative effects Need for water treatment Not specified Hexachlorocylohexane (lindance)

Agriculture – banned Industry – restricted

Agriculture – insecticide Industry

Direct negative effects Need for water treatment Not specified

Isoproturon Agriculture – restricted Agriculture – herbicide Direct negative effects Need for water treatment Not specified Pentachlorophenol Industry – restricted Industry – biocide Direct negative effects Need for water treatment Possibly copper

naphthanate or oxine copper

Simazine Agriculture – permitted until end 2007

Agriculture – herbicide Direct negative effects Need for water treatment Not specified

Tributyltin Industry – restricted Industry – biocide Accumulates/hormone disruption Not specified Trifluralin Agriculture – permitted

until March 2009 Agriculture – herbicide Direct negative effects Need for water treatment Not specified

Dangerous Substances Aldrin Agriculture- banned Agriculture – insecticide Direct negative effects Need for water treatment Not specified Dieldrin Agriculture- banned Agriculture – insecticide Direct negative effects Need for water treatment Not specified Endrin Agriculture- banned Agriculture – insecticide Accumulates Not specified Isodrin Agriculture- banned Agriculture – insecticide Bioconcentration and absorption to solids Not specified Para-para DDT Agriculture- banned Agriculture – insecticide Bioconcentration and persists Not specified Specific Relevant Pollutants Dimethoate Agriculture – permitted Agriculture – insecticide Does not persist Not specified Glyphosate Agriculture – permitted Agriculture – herbicide

Forestry – herbicide Binds to sediment, low toxicity Not specified

Mancozeb Agriculture – permitted Agriculture – fungicide Binds to sediment, high toxicity Not specified Mecoprop Agriculture – permitted Agriculture – herbicide Non toxic, low bioaccumulation Not specified

Mines

The main threat to surface waters from mines and quarries is the potential of contamination from pollutants such as metals. The Water Quality Dangerous Substances Regulations, 2001 prescribe water quality standards in relation to 14 substances for surface waters, including pesticides, solvents and metals. One of the main conclusions in EPA’s Dangerous Substances Regulations National Implementation Report, 2005, is that the majority of exceedances of the prescribed standards relate to either historical mining activities, or are due to the geology of an area contributing to naturally elevated levels of heavy metals in surface waters. The EPA and the Department of Communications, Energy, and Natural Resources (Geological Survey of Ireland and the Exploration and Mining Division) have commenced a characterisation project on historic mine sites in Ireland and their Environmental Risks. The study will develop a systematic and consistent approach to the remediation, rehabilitation and long term management of historic mine sites in Ireland and will review the potential impacts on the environment, human and animal health and safety. Water and sediment sampling will be undertaken at priority sites and the project will develop a risk categorisation methodology which will prioritise mine sites in terms of risk. The project findings are unlikely to be available until summer 2008. The River Basin Districts ‘Water Matters’ reports identify that the knowledge of disused mine sites in Ireland is presently incomplete and requires updating in order to assess the scale of their impact on the environment. The above study will enable the extent of their impact to be assessed in more detail. Recommendations from this study may result in the imposition of responsibilities for remediation works on the local authorities for disused mines, due to the difficulties in establishing ownership for these areas. It may be assumed that where no risk to the environment or to human health is established, there will be no requirement to remediate an abandoned mine. Similarly, where there is an absence of a mode of transport of pollutants to the environment from an abandoned mine, then it may be assumed that this mine will not have a greater priority for remediation over a plant where hazardous substances are mobile in the environment. The Geological Survey of Ireland (GSI) holds Mine Records containing information on over 220 individual deposits in Ireland. The database contains a range of information including data on the production figures, feasibility studies, drill logs, metallurgical studies, mining studies, mine plans, mine sections and Geological Survey studies and/or observations. Based on the current limited information, the GSI have characterised some 30 mine sites in Ireland as ‘significant’ based on their size and threat to the environment (this figure relates to both active and abandoned mines). It could be assumed that this figure will increase following the characterisation study for disused mines which is currently underway. The GSI also manages a computerized database (Minlocs) which contains summary information for approximately 6,000 known mineral localities in the State. Information maintained in the Minlocs database includes map sheet numbers, national grid coordinates, the townland name (and locality name if different), locality type, mineral type(s), sources of information and a brief description of the site. Annex H provides a list of historic mine sites throughout Ireland (i.e. it does not include active mines). This dataset includes both individual sites and districts (there


48

are 27 sites with approximately 80 individual mining operations). The list includes Bronze Age workings, 18th and 19th Century workings and modern operations (mostly operated in the second half of the 20th Century), metal operations, industrial minerals (e.g., barite, slate, talc etc.), and coal mine operations. Unmanaged or poorly managed historic mine sites may have negative impacts on the environment. Heavy metals may be leached from orphaned metal operations resulting in the contamination of soils and nearby water-bodies. Metal leaching may be exaggerated by the rapid weathering of the metal containing minerals, thus there may be a higher level of contamination at exposed mines e.g. strip mining operations. High water runoff from mine wastes can lead to the contamination of nearby surface waters and may also result in the sedimentation of surface waters. Acid mine drainage may degrade watercourses and tailing dams can cause contamination of the surrounding environment if not managed effectively. On the 4th August 2005, the Minister of Communication, Energy and Natural Resources, announced the provision of €10.6 million funding for remediation of the Silvermines area to restore the area to sustainable land uses. This funding is to be applied over a 4 year period. Some of the proposed remediation work includes: • the rehabilitation of the landscape through the backfilling of mine casts and the

establishment of self-sustaining vegetation cover in these areas; • the containment and maintenance of settlement ponds and tailings lagoons; • the establishment of a mine water treatment system to which all runoff is to be

discharged; • the development and implementation of conservation and management

programmes; and • the protection of any archaeological and conservation sites of interest. The remedial works mentioned above may also be required at the historic mines listed in Annex H. However, the scale and extent of the works may be much less in some cases than that required for the Silvermines. It is likely that the budget of €10.6 million allocated for the Silvermines area is an example of the upper-scale costs for mine remediation In 2005, Unipure Europe Ltd was appointed to establish site specific treatment costs for a full-scale mine water treatment plant at Avoca. Their report produced in 2007 (1)

indicated capital costs of €3,568,000 (Ex VAT) and operating costs of €502,000 per year. These costs relate to the construction and operation of an active treatment system (a high density sludge hydroxide plant) at Avoca. The remedial measures required at the abandoned mine sites listed in Annex H will be site specific. The treatment methodology selected for mine water will also be site-specific. Selection criteria for the appropriate treatment process should include analysis of the chemical loading in the mine water and identification of the level of reduction in the load required in order to meet the EQS in the receiving water. Other factors to be taken into account are the availability of suitable land at the site for the construction of a treatment facility, available suitable technologies and cost. Active treatment requires the regulated addition of reagents to the mine water in order to meet predetermined standards. There is a requirement for continual

(1) Unipure Europe Ltd. Avoca Mines Pilot Plant Treatment Trials A Report to Celtic Copper Heritage, European Union Interreg IIIA Project February 2007


49

monitoring and management of an active treatment plant and staff costs can be higher than that of a passive treatment system. Also associated with this type of treatment process are regular costs for consumable (i.e. chemicals), power and sludge disposal. Active treatment processes are cost effective in removing large amounts of contamination from mine waters. Passive systems use naturally occurring bio-chemical reactions to precipitate the contaminants from the mine water. These systems tend to be unsuitable for the treatment of mine water with high chemical loads and tend to be used more for coal mines. The operating costs for these systems are considerably less than that of the active systems, however, regeneration costs and sludge disposal costs can be high. The Avoca Mines Pilot Plant Treatment Trials report indicated that the costs associated with passive treatment can often be inline with costs associated with an equivalent active treatment system, as a result of regeneration costs. It should be noted that passive treatment options may be viable at some of the abandoned mines listed in Annex H. However, in the absence of monitoring data relating to the volumes and concentrations of pollutants entering the environment from the mines, it is not possible to determine the appropriate treatment process. Therefore, the data from the Avoca mines study will be used as a baseline for cost estimations in this RIA. Thus the costs associated with the Avoca mine remediation will be applied to all 27 disused mine sites listed in Annex H. On this basis national capital costs may be expected to be in the region of €96,336,000 and national annual operating costs may be in the region of €13,554,000. It is acknowledged that these figures are likely to be highly conservative and may exceed the actual remediation costs for the mine waters. However, it is anticipated that the water and sediment sampling being undertaken as part of the characterisation report will assist in identifying appropriate treatment process for each mine site, allowing the costs to be defined more accurately in the future. The BRGM report (1), notes that serious problems are arising from abandoned mines and old operations which were operated without appropriate environment management. The report identifies the need for basic mine closure plans for existing mines in order to reduce the risk to the environment. Appropriate site surveying are also required in order to identify the characteristics of the mine and enable remediation plans for the most problematic areas to be prioritised. Local authorities are liable in two circumstances of pollution, where its inaction on reported pollution leads to damage to private property or health and where the local authority is directly responsible for causing the pollution beyond what might be permitted or excused due to every effort being applied to prevent pollution. With regards to pollution where no known polluter can be proven or the polluter is insolvent, the responsibility to clean-up the pollution lies with the local authority. , The costs associated with the clean-up will have to be borne by the local authorities and possibly ultimately central government funds where no other person or agent or corporate entity can be identified as being responsible. Aquaculture Industry

As previously stated, the DCENR licences the use of Animal Medicines for the treatment of fish in fish farms. The contents of these medicines were reported to include, in some cases, pesticides which will have new EQS proposed under the

(1) BRGM (2001): Management of mining, quarrying and ore-processing waste in the European Union


50

Regulations. However, the review of the Marine Institute report on “Dangerous Substance Usage in Finfish Aquaculture” did not identify any of the substances in the proposed EQS as being used in finfish aquaculture. Under the assumption that some of the substances in the proposed EQS are used in finfish farming, there are significant implications to the operation of fish farms and the viability of the industry depending on how the new EQS are applied. This discrepancy may be as a result of the fact that the dangerous substances may be contained within medicines used in the finfish industry and these medicines may not be included in the report. It should be noted that the Marine Institute highlighted that fact that while the pesticide is contained within the medicine, it is a medicine rather than a pesticide and the use of an EQS cannot differentiate between a medicinal use and a pest control use on crops etc. Currently, the approach taken is that the application rate acts as the control measure in relation to preventing pollution in the area in which the farm is located. The Marine Institute has pointed out that the principal consideration in the use of modern pesticides is that they are designed to breakdown in the natural environment and are not persistent or bio-accumulative. The application rate is based upon the required concentration to have an effective treatment. This is likely to result in concentrations of substances in areas close to the fish farms which will exceed the proposed EQS. Consideration has to be given to establishing suitable agreed mixing zones around fish farms beyond which EQS levels must be maintained, but also take consideration of the requirement for effective treatment of the animals. This approach in itself will add an additional step to the licensing and enforcement process and place pressure on the Marine Institutes resources. However, it is felt that this is more acceptable than the application of an EQS which is so strictly applied that it results significant impact on the industry and regulatory body. Scenarios where this may arise are as follows: • The application rate of animal medicine has to be reduced resulting in a reduction

of its effectiveness, increased animal mortality and stock loss and a reduction in the quality of the product and therefore marketability; or

• In an effort to maintain the required application rates, farmers may spread the fish farms over greater areas. This is likely to results in increased costs in fuel and time, increased visual impact, potentially increased resistance to development, higher likelihood for the requirement of an EIA and therefore increased start-up costs.

In this case there are also significant additional resource pressures on the Marine Institute in relation to licensing and enforcement of the fish farms. However, as noted above in the section on Pesticides, none of the 59 substances covered in the RIA were described as being used in the finfish aquaculture sector. It is important that it is established whether the pesticides listed in the proposed EQS are actually used in the finfish aquaculture sector. Other issues

In some cases, the proposed EQS are below the current Limits of Laboratory Detection. This raises issues in relation to the reliability of analysis and compliance with the EQS. A qualitative look has been taken into the cost of testing. Laboratories with the facilities to carryout the testing required of the range of parameters and the volume of samples are not currently available in Ireland. Additionally, Good Laboratory Practice and the use of certified labs will be a requirement as the outcome of lab error will be the potential failure of a water-body to achieve Good Quality


51

status. These demands could lead to cost increases in the analysis of samples, as they may have to be sent out of the country for testing, labs may have to charge increased fees for new techniques, or new or undersized labs may lead to errors.

4.5 ENVIRONMENTAL IMPACT

4.5.1 Option 1

As Option 1 assumes that the proposed Regulations will not be implemented, there will therefore be no direct positive or negative environmental impact. However, with the implementation of other measures under the WFD, it can be assumed that there will be an overall positive environmental impact for surface waters. It is still unlikely that Ireland will achieve “good water status” by 2015 by these means alone. Therefore, it can be assumed that there will be a residual negative impact as we would assume that the implementation of the proposed Regulations would result in “good water status” by 2015. Regulations, controls and plans (as set out in Section 2.5.2) in place for the control of nitrates and phosphates, including the full implementation of the Good Agricultural Practice for Protection of Waters Regulations, 2006 and 2007, are assumed to be adequate to address diffuse nutrient losses from agriculture, a cause for not attaining “good water status”. The Waste Water Discharge (Authorisation) Regulations 2007, in December of this year, have introduced a system for the licensing or certification of waste water discharges from areas served by local authority sewer networks, by the EPA. This system will facilitate the provision of strict restrictions and prohibitions on the discharge of dangerous substances in waste water from sewerage systems, thereby ceasing and/or reducing concentrations of specific pollutants to receiving water bodies. The REACH Regulation (EC 1907/2006) with its overall aim of protecting human health and the environment will initiate a series of positive environmental impacts in Ireland with improved protection of our aquatic environment through increased controls on substances, improved substance information and communication, restrictions on use of substances of high concern (CMRs, PBT, vPvB) and the anticipated removal of some substances from the marketplace. However, the timeframe for the implementation of the REACH Regulations is much longer than the 2015 deadline under the WFD. While the Irish Government is unlikely to adopt the “Do Nothing” approach, it should be noted that current Regulations are likely to have a positive impact on the surface water quality within Ireland once fully implemented. However, it is considered unlikely that the “Do Nothing” approach would be sufficient to control all parameters set out in the General Conditions and the list of 59 priority and relevant substances listed in Annex A.

4.5.2 Option 2

Option 2 assumes voluntary compliance with EQS, relying on voluntary reductions in concentrations at the source of discharge utilising trigger and guide values rather than legally binding EQS. However, all current legislation will be in operation, with the potential scenario of integration of the trigger and guideline levels into the IPPC and Section 4 and 16 licensing regime.


52

With voluntary compliance, it can be expected that not all stakeholders will fully participate in reduction of EQS pollutants; therefore the realisation of “good status” of our surface water bodies by 2015 is considered unlikely. However, from an environmental benefit perspective, by taking the 50% approach (that Option 2 will secure 50% of the benefits of full compliance under Option 3), it is assumed that there is 50% improvement in surface water quality. It is unlikely that this will transpire as 50% of all water bodies complying with the EQS. Improved water quality may only emerge in specific water bodies or specific RBDs, according to the level of voluntary participation by stakeholders and the approach taken in the RBD management team and enforcement of the licensing regime. As the WFD requires all monitoring parameters to comply with the proposed EQS (8 general components and 59 priority substances, other pollutants and relevant pollutants), the failure of a single parameter results in the failure of the entire water body to achieve “good status”. Therefore, improved water quality may not necessarily result in compliance with the WFD.

4.5.3 Option 3

Option 3 assumes full regulation for all required substances to achieve compliance with the EQS and the WFD, and achieve the requirement of “good status” in our water-bodies and maintenance of high status waters by 2015. This will comprise full participation and compliance by all stakeholders. The primary environmental benefit of full compliance and assumed fulfilment of the WFD aim of “protection of our environment”, will be good status of all Ireland’s water bodies and the preservation of existing and future high quality waters. This will result in wide ranging benefits for all water dependants and users. Environmental benefits will extend to plant life and wildlife associated with the aquatic environment, whilst ensuring the protection and preservation of designated nature conservation areas. The attainment of water quality of good status would have beneficial impacts throughout the Irish society. The full implementation of the proposed Regulations and EQS is likely to lead to an improvement in the quality of our surface water body as a resource, leading to improved drinking water quality, public health, and social well being. This would also include the provision of better natural resources for the country’s population to use as a recreational amenity: better and more fishable rivers, cleaner water to swim, sail and kayak in, and better general environment for other outdoor pursuits. Industrial and commercial benefits would include improved international standing with international investors as a country that can develop industry in a sustainable manner, while protecting and enhancing its environment. The marketability of the “green” image of Ireland would increase, with associated benefits for tourism and the food sectors. Reduced levels of pollution could as stated, improve the health of the general population by reducing their exposure to low level concentrations of hazardous substances. Costs associated with the provision of drinking water could be reduced. The review of city and county development plans will also reflect the importance of environmental considerations in the planning process and strengthen the protection of the environment.


53

4.6 SOCIAL IMPACT

4.6.1 Option 1

Option 1 assumes that the Regulations will not be implemented; therefore in theory there should be no corresponding positive or negative aspects. However, with the ongoing implementation of the WFD, wide-ranging stakeholder participation and increasing public (including environmental NGOs, angling groups, etc) awareness and involvement, the decision to not implement these Regulations could be perceived negatively and viewed as poor policy implementation on behalf of the Government. Failure to implement the Regulations and to achieve water quality of “good status” could impact on the economic growth and success of the Irish Economy. Ireland depends heavily on tourism and one of the key selling points of Ireland is its clean image. Ireland’s reputation within Europe could be tarnished and its clean image damaged. The impact of such an event would be difficult to assess but it is feasible that tourist numbers may drop, having a knock-on effect of increasing unemployment in this sector. The Irish food export market depends heavily on the image of Ireland as being a clean and green country. If the Regulations are not implemented and Ireland fails to meet the required standards by 2015, the associated bad press and attention that Ireland would possibly receive in Europe, could impact on the marketability of Irish produce. This, like the previous point, could impact upon the economic growth of this sector. Having lower water quality than our European partners, may also reduce our ability to attract continuing investment from international companies. All these factors may impact or slow our economic growth and potentially lead to reduced investment in our economy. This could lead to higher unemployment and greater demands on our social services. Individual’s wealth, prosperity and standard of living may ultimately be affected. Having a safety and reliable supply of drinking water is considered to be a basic right. In recent times Ireland has experienced some issues with it’s water supply which has impacted on the quality of life for people in the effected areas. Critically there is also the potential for health impacts if good clean sources of drinking water cannot be found. Group water schemes or private wells supply drinking water to approximately 200,000 homes in Ireland (1). “The overall quality of drinking water supplied to less than seven per cent of the population by private group schemes remains unsatisfactory ” (2). Failure to implement the Regulations and EQS could result in the continued supply of unsatisfactory drinking water to the Irish population.

4.6.2 Option 2

Option 2 assumes voluntary compliance with EQS and relies on voluntary reductions in concentrations at the source of discharge. At this stage, it is assumed that trigger and guideline values would be used to achieve the voluntary reductions rather than legally binding EQS. However, it is assumed that all current legislation will be in operation, in conjunction with possible integration of the trigger and guideline levels

(1) http://www.citizensinformation.ie/categories/environment/water-services/water_supply(2) http://www.epa.ie/news/pr/2007/jan/name,13104,en.html


54

into the IPPC, Section 4 and 16 licensing regime and new waste water licensing and authorisation system. With voluntary compliance, it can be expected that not all stakeholders will fully participate in reduction of EQS pollutants. Therefore the realisation of “good status” of our surface water bodies by 2015 is considered unlikely. However, by considering our 50% approach, we could assume that there will be 50% improvements in water quality. However it is unlikely to transpire as 50% improvements socially, for example as improvements to human health, water supplies for human consumption, recreational uses of our water bodies, improvements to human health, etc. Therefore, it could be argued that failure to see improvements in these areas and potential poor comparisons with our European partners would ultimately results in an impact on the Irish society. This approach may also lead to an uneven competitive environment, for industries who comply with the voluntary scheme compared to those who do not. The variation in approach associated with this option may also make it difficult for local authorities to plan and manage their WWTP. Conflict may also arise in relation to charges applied under the Water Services Pricing Policy by local authorities on industries, unless a clear benefit to comply with the voluntary schemes was built into these charges. There may also be an inconsistent approach across local authorities and potentially even a city/rural divide, with greater pressure being applied in city areas compared to rural areas due to population numbers and local authority resources. Inconsistencies may also arise between the approach taken by the EPA and the local authorities around the country, with one organisation potentially applying stricter controls than the other. These inconsistencies could make Ireland less attractive to companies wanting to invest which could ultimately impact upon or economic growth and potentially employment levels.

4.6.3 Option 3 – Overview

Option 3 assumes full regulation for all required substances to achieve compliance with the EQS and the WFD, and achieve the requirement of good status in our water bodies and maintenance of high status waters by 2015. This will comprise full compliance by participating stakeholders, and full enforcement of the Regulations by the regulatory authorities. The main social benefit of full regulation will be the elimination and reduction of discharges of priority hazardous substances, priority substances and specific relevant substances, which should result in a significant reduction of such trace pollutants in our drinking water supplies and the food chain, with resulting benefits for human health. In terms of industries reliant on surface water bodies, including the fishing industry and aquaculture, food and drink, power generators, tourism industry, and so forth, improved water quality will result in improved public image associated with these industries. This improved status would only add to the Irish image as a “green” country and assist in the marketing of Irish produce and Ireland as a location to visit. In particular the fish tourism industry could see a marked improvement with potentially more rivers sustaining populations of salmon, trout and game fish. In terms of recreational users of our surface water bodies, such as those involved with angling, sailing and boating groups, water sports enthusiasts and similar users will


55

enjoy the benefits of improved water quality. With reduced health risks due to reduced chemical and bacteriologic levels, the use of water resources becomes more attractive and marketable with the associated benefit of helping the population to become more active. For society at large, the implementation of planning policy and strategies to address issues arising from sewage management and treatment will benefit future housing developments and should introduce greater consistency in the approach to planning nationally. It is also noted that the review of county and city development plans and the adoption of the EPA Code of Practice: Waste Water Treatment Systems for Single Houses, is likely to result in the reduction in the number of one off houses allowed in rural areas. There is also likely to be increased costs associated with the application for planning permission and maintenance costs associated with the operation of septic tanks and proprietary systems. However, the benefits from improved water quality are considered to outweigh these costs. The marketability of Ireland as a place to invest would be increased and successful implementation of the EQS would put us at an advantage over those countries that failed to achieve this target. As previously mentioned the “green” image of Ireland is very heavily marketed by both the tourism and the food sectors. Improving Ireland’s water quality would ultimately assisting in marketing Ireland’s products as high quality and desirable goods. All these factors would combine to help improve Ireland’s economic growth and therefore increase employment and standard of living. Alternatively, it should also be noted that the costs associated with implementing/ installing waste water treatment system may be such that operation of the business becomes unviable. This could result in companies shutting down or relocating outside of Ireland or the EU. This could significantly impact on the Irish economy.

4.7 SUMMARY OF IMPACTS

4.7.1 Environmental and Social

Under Option 1: As no changes are considered under Option 1 – Do Nothing, from the current situation, there are no additional impacts expected. However, it is noted that there are benefits to be achieved through the full implementation of the existing Regulations e.g. REACH and the Waste Water Discharge Regulation process. These have a longer time frame for full compliance than the WFD, which makes an accurate assessment of the benefits difficult. With the establishment of the RBDs and the ongoing body of work in implementing the various components of the Directive, the profile of the WFD is being elevated nationally, therefore the Do Nothing approach could be perceived negatively by various stakeholders. Under Option 2: In general, as Option 2 considers voluntary reduction only, it can be expected that not all stakeholders will fully participate in reduction of EQS pollutants and comply with the proposed Regulations. Therefore, the benefits are estimated to be only 50% of the benefits expected from Option 3. However, while such benefits are unlikely to transpire as 50% compliance with the EQS or as a 50% improvement in the water quality of a specific surface water body, there will certainly be some degree of environmental and social benefits under Option 2. However, it is difficult to determine the extent of such benefits at this stage.


56

Under Option 3: The most potential benefits are expected through Option 3 as full compliance with the EQS and proposed Regulations will be required from all stakeholders. The main benefits will include the improvement in water quality and positive impacts for all users including industry, tourism and recreation and the protection and improvement of our aquatic and marine environments. Water treatment plants may also experience improvements in operation and resulting reduction in treatment cost. Improved water supply may also lead to reduced monitoring requirements and additional cost savings for regulatory authorities. Specifically within the ERBD, as it is the most densely populated RBD in Ireland, one of the most significant potential benefits from compliance with the EQS is to improve water status with the reduction of exposure to dangerous substances. For WWTPs and groups involved in sludge management, compliance with the EQS should eventually (and indirectly) result in a reduction in the presence of pollutants in the treatment processes through source control measures. This may lead to more disposal options becoming available in the longer term, as sludge may become less contaminated as Priority Hazardous Substances are eliminated from the waste water stream. Use of the sludge as soil improvers on agricultural land could increase, with concurrent reduction in the accumulation of pollutants in the ground, crops, livestock, etc. Alternatively, if source control is not successful, treatment within WWTPs could result in sludge with higher concentrations of pollutants resulting in higher disposal costs and fewer disposal options. With agriculture and food production being such an important industry in Ireland, the benefits associated with EQS compliance include a reduced accumulation of pollutants in meat and milk through livestock watering, and in crops through irrigation, with subsequent reduction in human exposure to hazardous compounds. For the fisheries industry, the positive benefits should include improved productivity in water bodies and increased fish stocks and variety of stocks with subsequent increased revenues. There should also be a reduction in the accumulation of pollutants in fish, with a subsequent reduction in human exposure to these pollutants. Areas used for shell-fishing should also experience a reduction in algae blooms, loss of stock and subsequent increase in revenue.

4.7.2 Economic

Potential costs of €211,757,489 have been assigned to the upgrading of all WWTPs within the RBD for the removal of priority substances and specific relevant pollutants. There are also potential operational costs of €13.5 million across all the WWTPs for Granular Activated Carbon alone. In Section 2.5.1 it was approximated that the water quality in 47% of our rivers and 27% lakes is either unsatisfactory or at risk. In an effort to make the cost figure more realistic and taking into consideration the risk classification percentages in Section 2.5.1, the following assumption was made. “WWTPs are the source of pressure resulting in the risk classification identified in Section 2.5.1 in all cases”. Extending that assumption to the potential costs figure (€211,757,489) presented for the up-


57

grading of all WWTPs, the cost to Ireland to meet the proposed Regulations could be somewhere between €99,526,020 (47%) and €57,174,522 (27%). It is noted that the upgrade of all the WWTPs may not necessarily be required following more detailed investigations and that the figures have not taken into account the current Water Services Investment Programme 2007 – 2009, as it is assumed that any investment is aimed at the attainment of current quality standards and not the proposed EQS. However, whole life costs were estimated to be €9 million per annum over 30 years, should facilities for ammonia removal be required in WWTPs with no current capacity to do so. Costs were also developed for phosphorous removal, as set out in Section 4.4.3 Municipal WWTPs. Whole life costs were estimated to be €6 million per annum over 30 years and as with the ammonia facilities, no account was taken of the investment programme within the Water Services Investment Programme 2007 – 2009(1) . Preliminary treatment cost estimates per IPC/IPPC industry range from €40,000 to €4.2 million. Section 4 and Section 16 licences have not been costed, as there is insufficient information in relation to the pollutants that need to be removed to meet the EQS and the characterisation of the discharges from the industries. However, potential administrative costs for local authorities have been estimated to range from €4.485 - €13.650 million in the first two years and approximately €10.725 million per annum after that. Costs for IPPC facilities were estimated to range from €40,000 to €4.2 million per site. Costs associated with the up-grade or resolution of diffuse pollution from septic tanks and proprietary systems associated with one off houses or small numbers of houses are estimated to range from €975 million to approximately €3 billion. Remediation costs for diffuse pollution for current and diffuse mines were also estimated, while accepting that each mine should be individually assessed. Site specific costs for the Avoca mine were estimated to be €3.5 million for capital investment and €0.5 million per annum operational costs. When applied on a national basis this represents a capital investment of €96 million with operational costs of €13 million per annum. The following additional costs could not be estimated in a meaningful way at this stage; • the design, construction and operation of pilot waste water treatment plants prior

to commissioning of full plants; • characterisation projects to establish background concentrations of metals; • projects for the characterisation of discharges from different sources; • the review of licensing of approximately 420 waste water treatment facilities and

on-going enforcement costs; • increased monitoring costs for industry, Local Authorities and the EPA; • the economic impact from the removal of a substance(s) from use eg pesticides

and the impact on agricultural production, medicine and the impact on aquaculture; and

• control measures relating to other diffuse sources of pollution.

(1) http://www.environ.ie/en/Environment/Water/WaterServices/WaterServicesInvestmentProgramme/


58

A summary of impact by sector is provided in Annex E.

Table 4.20 Summary of Economic Costs

Sector Cost Due to Amount € Municipal WWTP - Priority Substance Removal

Capital Cost 211,757,489

Operational Cost per annum 13,500,000 Municipal WWTP - Ammonia – All WWTP


9,000,000

Municipal WWTP - Ammonia – 39% of WWTP


2,300,000

Municipal WWTP -Phosphorous – All WWTP


6,000,000

Municipal WWTP -Phosphorous – 41% WWTP


3,700,000


Treatment of discharges directly to waters

40,000 – 4,200,000


Treatment of discharges directly to sewers

90,000 – 4,200,000

Administration - Local authorities – County, City and Borough Councils

Administrative costs first two years 4,485,000 – 13,650,000

On-going annual administrative costs 10,725,000 Septic Tanks - Local authorities or central government

Septic Tank Remediation 975,310,000 – 3 billion

Septic Tanks - Local authorities or central government

Proprietary systems 158,438,000 -205,716,000


Remediation – capital investment 96,336,000


Remediation – annual operational costs 13,554,000

The following topics are identified as likely to cause potential additional costs, but accurate figures could not be calculated due to uncertainties around what work has to be completed in each area: • Combined Sewer Overflows upgrading; • Impact on agriculture, aquaculture and forestry; • Section 4 and 16 industries – provision of on-site treatment systems; • Sludge management; • Road run-off treatment; • Monitoring costs including laboratory costs; and • Treatment of ammonium releases during peat extraction.


59

5 CONSULTATION

5.1 INTRODUCTION

The Screening RIA recommended public consultation be undertaken as part of the full RIA, so that any other interested parties are given the opportunity to comment on the proposed Surface Water Classification Regulations via an open and transparent consultation process. The EPA undertook a public consultation process on the proposed standards between 31st July and 27th September 2007. An advertisement was placed in the national newspapers informing the public where the consultation documentation could be obtained and to whom submissions were to be made. The Agency sought the views of interested parties on the proposed standards and in particular, attempted to ascertain the following:

a) Are the standards set at an appropriate level? b) Is the basis for their derivation clear and appropriate? c) Are there particular difficulties posed by these standards to normal operations of

various sectors of the community? A link (1) was placed on the front page of the EPA web site. The link led to a specific consultation page, which gave a preliminary introduction to the proposed standards and additional links to the relevant documentation. Documentation on the web page included: • Water Framework Directive, Proposed Quality Standards for Surface Water Classification,

A Discussion Document for Public Consultation. EPA, 2007 • Screening Regulatory Impact Assessment of the Proposed Surface Water Classification

Regulations including Environmental Quality Standards. ERM, 2007 • Proposed Environmental Quality Standards For General Components In Surface Waters

In Ireland. South Eastern River Basin District Programmes of Measures and Standards Project, July 2007

• Proposed Environmental Quality Standards For Specific Relevant Pollutants in Surface Waters in Ireland. WRc for the South Eastern River Basin District Programmes of Measures and Standards Project, July 2007; and

• Proposed Quality Standards for Surface Water Classification (Summary Document). EPA, July 2007.

In addition, relevant Stakeholder Organisations were contacted by the EPA, informing them of the consultation process and offering to meet with them to explain the consultation documents and inviting them to make a submission. Meetings were held with Sustainable Water Network (SWAN), Irish Business and Employers Confederation (IBEC) and Irish Creamery Milk Suppliers Association (ICMSA). Letters were also sent to the individual Local Authorities advising them of the consultation process and inviting submissions. The level of response from the initial consultation process was not as extensive as hoped for. In a further effort to ensure a better response from the consultation process, ERM in co-operation with the EPA, developed a questionnaire and circulated

(1) http://www.epa.ie/ and http://www.epa.ie/whatwedo/wfd/monitoring/proposedstandards/


60

it to all City and County Directors of Services, Water and Sanitary Services Section. This was followed up with a phone call to discuss the process and the importance of submissions to the RIA. It resulted in eight responses. Following from the Screening RIA, it was decided to consult with specific organisations, including the Marine Institute, National Roads Authority, licensing and enforcement personnel within the EPA, water services and planning specialists in the DEHLG, IBEC and Local Government Management Services Board. Contact was made with these organisations and meetings were set up where appropriate. All representatives were encouraged to make written submissions as well as partaking in the meeting. The stakeholders that were engaged in the consultation process were primarily government department and regulatory agency representatives. No submissions were received from the general public or educational institutions. Stakeholder Organisations: Steering Group • Environment Protection Agency (EPA); • Department of Environment, Heritage and Local Government (DEHLG). Other Stakeholders • DEHLG, Water Services Section and Planning Advisors; • River Basin Management Project Coordinators; • Local Government Management Services Board • Irish Business and Employers Confederation; • Marine Institute; • National Roads Authority; • EPA licensing and enforcement sections; • All City and County Director of Services, Water and Sanitary Services Section;

The key concerns and observations identified through the consultation process to date were (as quoted): • The level of awareness within the Local Authorities is very low. There appears to be a

belief that the responsibility for the Water Framework Directive (WFD) and associated Regulations lies with the River Basin Management Co-ordinators. This shows a potential lack of understanding of the implementation of the WFD;

• A request was made for a further consultation to be undertaken that reviews the

classification system in its entirety (all quality elements), since it is impossible to link the individual standards being proposed to overall WFD classification at this stage;

• Respondents felt that the consultation process was too short and not engaging enough.

The consultation process should be extended for a period and a more pro-active approach is made to make Local Authority Laboratory and scientific staff aware of these proposed changes;

• The Discussion Document is very complicated and difficult to understand in places;

• Further information is needed on some of the metrics used in order to make a robust analysis of their appropriateness;

• The understanding of the meaning of the WFD normative definitions of high, good and moderate status is key to the setting of WFD standards and that the consultation paper fails to explain how these concepts have been translated into the Proposed Standards;


61

• EQS values were below limits of detection;

• The approach of having an "Annual Average" (AA) limit as well as a "Maximum Allowable Concentration" (MAC) should apply to all physico-chemical parameters (BOD, DO, ammonia, nitrate, nitrite, pH, o-phosphate, chloride, etc.) as is the case for priority substances set at EU level;

• EQS values were not taking into consideration information and experience already in

existence in relation to pesticides and may lead to contradiction in authorisation across different Directives;

• Concern at the dominance of physio-chemical standards, in the Proposed Standards,

derived from datasets of water-bodies ‘considered to be of high and of good biological status’, but with inadequate links to biological impacts and few biological classification tools yet completed to confirm that status;

• The EPA was urged to stress the very preliminary nature of the Proposed Standards and

the need for continuous review in light of new knowledge, especially on ecological classification and pressure-impact pathways. It was stressed that this revision should not be delayed until the next River Basin Management cycle, but rather should proceed iteratively;

• The application of EQS values in freshwater ecosystems is not directly transferable to

transitional and marine waters. Implication of transitional water and coastal water EQS need further consideration;

• Laboratories, concern was raised at whether there were sufficient numbers of appropriate

laboratories located in Ireland to handle the level of testing that will be required. The reliability upon the results is high as one failure will cost the water body its status as “Good Quality”; and

• Cost associated with and provision of resources to carry out monitoring, was a concern

for both the public and private sector. Comments in relation to specific parameters are outlined in Annex I and have been passed on to the appropriate task group.


62

6 INSTITUTIONAL REQUIREMENTS, ENFORCEMENT AND COMPLIANCE

6.1 INTRODUCTION

The proposed water quality standards to give effect to the Water Framework Directive environmental objectives for surface waters are to be introduced within the framework of the Water Policy Regulations (S.I. No. 722 of 2003), and will require the making of separate Regulations by the Minister for the Environment, Heritage and Local Government to give legal effect to the standards proposed. It is anticipated that the implementing Regulations will impose a general obligation on all public bodies to ensure compliance with the water quality standards in the performance of their functions. In addition, agencies and bodies with responsibility for authorising the discharge of pollutants e.g. EPA, local authorities etc, will be required to ensure that all existing authorisations and that all new authorisations to be issued by such authorities in the future, set down emission limits for pollutants discharged that aim to ensure achievement of the environmental objectives established. It is likely that considerable extra resources will be required to enable existing institutional arrangements meet the policy expectations and obligations.

6.2 INSTITUTIONAL APPLICATIONS

In general the existing institutional arrangements should be sufficient, with further resourcing, to meet the requirements of the proposals. The regulatory framework is largely in place through the Local Government (Water Pollution) Acts 1977-1990 while the Water Services Act 2007 provides an up to date framework for the role of the Minister and the local authorities in their role as Water Authorities. In addition the national policy framework is well established with the Departments policy positions on rural housing, the recent guidelines on planning and the continued roll out of the provisions and applications associated with the Water Framework Directive. Particular concentration on developing the role of the local authorities should now become a focus for the Department and the Agency. It is self evident that the demands that will arise on the authorities will be significant in both financial terms and in the management of personnel resources. It is critical that the local authorities be brought into the process as soon as possible to enable them to develop an understanding of the level of demand that will fall most heavily upon their environmental and water services divisions. To do this a series of recommended actions are set out in Section 7. Broadly the authorities will need to devote resources over the immediate future to establish a more comprehensive understanding of the nature and extent of Section 4/16 licences and to complete an audit of the current condition of non-public waste water management, particularly in areas identified as being at risk or already polluted having regard for the status of waters under the Water Framework Directive. In addition the Agency, in co-operation with the River Basin Offices, the local authorities and with the support of the Department, will need to explore the need for greater use of the provisions of Section 15 of the 1977 Act and Section 21 of the 1990 Act. Given the diffuse nature of pollutants arising in rural areas the consideration of local by-laws would need to have regard for the completed audit referred to above. This would also necessitate consideration of the need to establish a local capacity for scrutiny and confirmation of standards maintenance in septic tanks and individual treatment systems in order to counteract the current poor levels of maintenance of such facilities. Clearly this would be a service best provided through the local


63

authorities as the OEE network of enforcement officers demonstrates in regard to solid waste management. The resourcing of such a service would however require consideration by the Department in light of on-going restrictions on human resources and finances of local authorities. Other matters arising in regard to enforcement are addressed below in Section 6.3. In regard to the role of the local authorities as Planning Authorities, the Department’s Planning Guidelines address the relationship between the spatial applications associated with the adoption of County/City Development Plans, and the need to integrate the policies and objectives of such plans with the protection of water quality. This could have critical application in regard to the control of rural planning applications in areas at risk. Notwithstanding the Planning Guidelines recommendations in regard to the tailoring of policies to local circumstances SR6 may need re-visitation with a view to updating it in regard to the use of septic tanks in such areas.

6.3 ENFORCEMENT

Enforcement of the proposed EQS can be facilitated through the current Regulations outlined in Section 2.5.2 and the Waste Water Discharge (Authorisation) Regulations 2007. The obtaining of a discharge licence for a municipal WWTP will be a new requirement, which will be placed on the operators of these facilities (typically the local authorities). This will require the initial processing of approximately 490 (number of WWTP in the country with a PE >500) licence applications by the EPA (before June 2009) and will also apply to all future WWTP facilities. The structures and systems currently in place should be sufficient to allow this to be carried out. However, the licensing process will increase the current licence number administered by the EPA by approximately 50%. The new Regulation will also require all current IPPC and waste licences with discharges to waters to be assessed to ensure that they do not compromise the achievement of water quality of “good status” by 2015. To achieve the processing and assessment of those IPPC installations with discharges to waters and WWTP licences issued prior to signing into force the proposed Regulations will require additional resources to be allocated to the licensing section of the EPA. Local authorities will be responsible for the enforcement of single media discharges through Section 4 permits and discharges to sewers through Section 16 licences. The Regulation and EQS will require a level of control over the Section 4 and 16 licences beyond that which is currently being enforced throughout the country. Standard emission limit values and common conditions will have to be replaced through stricter control of emissions under these licences and potentially more onerous conditions on SMEs. The level of engagement that is likely to be required between the local authorities and the individual companies to identify all potential pollutants will be greater. Local authorities will require a greater understanding of the RBD system as consideration will have to be taken of emissions both up- and down-stream of any discharges as there may not be natural processes within the water body that will reduce the concentration of pollutants once discharged meaning that they may increase in concentration as they move down-stream. All licences issued by the EPA and local authority will have to be assessed and reviewed as necessary on a cyclic basis taking into consideration results of monitoring to be carried out to ensure compliance with the objectives of the WFD, by December 2012 at the latest. Monitoring results which do not meet the required standards are


64

likely to require the local authorities, through the RBDM schemes, to review discharges of pollutants, identify potential sources, implement revised control measures, and to review the results on an ongoing basis. This is likely to require significantly greater levels of communication between the relevant enforcement agencies for the variety of potential sources of pollution, including, the EPA, local authorities within the RBD’s, and the Department of Agriculture, Fisheries and Food for example. Future developments will also have to be more closely controlled, with the possibility that infrastructure such as WWTP will have to be put in place prior to or in conjunction with proposed developments. The Minister for the Environment, Heritage and Local Government published planning guidelines under the Planning and Development Act 2000 on Sustainable Rural Housing in 2005. The guidelines highlight that sites for new houses in unsewered rural areas must be suitable to the installation and operation of on-site waste water treatment systems taking into account local ground conditions. The Circular letter (SP 5/03) issued by the DEHLG to planning authorities in 2003 also emphasised the importance of sound development plan policies relating to the protection of surface and ground water quality. As stated in the “Waters Matters” reports the design of new facilities will have to consider soil, geology, surface water and ground water as well as proposed new water quality standards. These reports also state that effective controls on planning, design, construction and operation of on-site systems are required to avoid water quality problems. Planning permissions do not currently stipulate any maintenance requirements for these systems as it is assumed that once they are running the owner will want to maintain then and will therefore ensure it is carried out. Studies have highlighted that this is not the case. There is no legal framework in existence currently which gives the power to local authorities to force people to maintain their septic tanks, unless they can prove that the septic tank is causing water pollution or specific bye-laws are enacted (as in the case of County Cavan). It is also unclear if future planning permissions could place a responsibility on owners to maintain the systems. This would also require local authority resources to ensure these conditions were being complied with.

6.4 COMPLIANCE

The new WFD monitoring programme has been established to meet the requirements of the WFD and has been operational since 22 December 2006. The monitoring programme will be used to assess compliance with the proposed EQS. In this programme monitoring is carried out at representative water-bodies. The list of waterbodies included in the programme will be reviewed, and altered if deemed necessary, following the first monitoring cycle. Compliance with the EQS may prove to be difficult in the current format as there has been no agreement on how to address high background levels of some substances eg metals, which could be above the proposed EQS. This may require additional monitoring to be carried out to establish a baseline characterisation for all surface water bodies. Additionally, a number of the levels suggested are below current limits of detection. Costs associated with the monitoring of the EQS are already incurred and established


65

through the water framework monitoring programme and are not addressed in this RIA.

6.5 SUMMARY

Compliance with the EQS will be required once the Regulations are brought into force. Failure to achieve the required EQS will result in Ireland having a non-compliance with the EQS which will result in the associated water body being reported as having not achieved “Good Status”. The current institutional structures which are in place have the capacity to achieve the targets set out in the proposed Regulations without the necessity for a new body to be developed. However, the communication structures will have to be significantly strengthened to ensure that all relevant authorities now what roles they play in the enforcement and attainment of the EQS. The achievement of the EQS is not considered to be unreasonable and the licensing system in existence for IPPC, waste, wastewater discharges, and Section 4 and 16 discharges should be able to incorporate the EQS into the calculation of the emission limit values for each licence. The enforcement of the EQS would be achieved through the existing licensing systems within the local authorities and EPA. The current structures also allow for the review of the EQS both through the licensing systems and the advisory role of the EPA. Under the WFD the EPA is also responsible for: • Reporting to the European Commission; • Developing Classification Systems; • Setting Standards; and • Devising the Monitoring. Given the current role of the EPA it is envisaged that they would be responsible for the review of the EQS.


66

7 RECOMMENDATIONS

The following recommendations are made following consideration of the findings presented within the RIA. Recommendations have been grouped to assist in the identification of where further actions need to be taken. Option Selection 1) The full implementation of the proposed Surface Water Classification Regulations

including Environmental Quality Standards is recommended, as either of the other options would be contrary to Government policy and non-compliant with EU law. Failure to implement the Regulations is likely to result in fines being imposed on Ireland by the EU and the attainment of water quality of good status is unlikely to be achieved.

Local Authority Functions 2) As the local authorities are likely to be the key implementing bodies, there is an

immediate need to establish a consultation process with the County and City Managers Association in regard to the implications for the authorities for resources and systems. Concern has to be noted in regard to the role the authorities will play following completion of the work of the existing River Basin District projects.

3) As implementing bodies the local authorities will need to put in place a more robust management system for Section 4 and 16 licensing than is currently in place. The authorities will need to also apply a more robust operational regime in their management of waste water treatment facilities and municipal waste management facilities. This will require a greater allocation of trained staff and the introduction of comprehensive monitoring systems to ensure the authorities meet their statutory obligations. There is little point in implementing a regulatory framework in the absence of having adequate resources available to the implementing authorities as is evidently the case in regard to the current framework. It is recommended, therefore, that an immediate audit of current capacity of staff and other resources be undertaken to facilitate the completion of a needs analysis arising from the requirements of the proposed Regulations. The needs analysis should set out, on an authority by authority basis, the full staff and financial resources available to the authorities to implement the existing regulatory framework and the expected needs arising from the proposed Regulations. The analysis should also set out the actual requirements for capacity and resoucing to appropriately implement the existing framework, and the expected needs arising from the proposed Regulations. The gap in capacities and resources should then be fully set out in order to determine the real resource needs of the authorities in regard to their current and future statutory role. This identified gap should then be translated into the deficit in financial resources arising for local authorities as a result of the existing regulatory and proposed regulatory framework, and this should be the basis for consideration of the allocation of extra resources, on the part of the Department of the Environment, Heritage and Local Government and the Department of Finance.

4) The implementation of the proposed Regulations will require specific consideration by the corporate planning structures of the local authorities given the potential cross departmental impact of the proposed Regulations including planning, housing, environmental and infrastructural services and the possible resistance to their implementation by local elected representatives;


67

5) Planning sections within the local authorities should have to take the treatment of wastewaste into consideration requiring, for example, WWTPs to be built in advance of or in parallel with any future development. This approach needs to be implemented during strategic development planning and carried through to the assessment of individual planning applications.

6) Future planning for waste water collection and treatment may have to consider the collection and treatment of CSO discharges.

7) Costs incurred in the construction and refit of WWTPs, should be passed back, where possible, onto the industries and sectors that discharge to the sewers. This could be achieved through the existing mechanism of the Water Services Pricing Policy.

8) The control of the Section 4 and 16 emissions requires more stringent monitoring and a more detailed consistent application across the State. Local authorities should undertake an audit of their Section 4 and 16 licences to ensure that all emissions to sewer and surface water are being appropriately licensed and policed.

Septic Tanks 9) Maintenance of proprietary treatment systems is vital for their continuing

effective running of one off housing effluent treatment systems. A comprehensive state wide audit of the up-take of maintenance agreements for such systems should be completed to determine the extent of non maintenance and their location. This information should be used to assess the need for and focus any scheme considered to be necessary to up-grade existing on site wastewater treatment systems.

10) A succinct guidance document drawing together the principle features of waste water related regulation should be prepared and local authority staff trained in regard to its application.

11) The current reference document for the installation of septic tanks in one off developments is SR6: Septic Tank Systems: Recommendations for Domestic Effluent Treatment and Disposal from a Single Dwelling House. This is to be replaced by EN 12566 - Small wastewater treatment systems for up to 50 PT. Prefabricated septic tanks. The Department of Environment, Heritage and Local Government must ensure that clear instruction is provided to the local authorities in the use of EN 12566 and the status of the EPA draft “Code of Practice: Waste Water Treatment Systems for Single Houses”. Specific guidelines in regard to the local authority as a planning authority may also be required having regard to the provisions of the existing Departmental guidance on rural housing.

Environmental Protection Agency 12) Once the Regulations have been finalised the EPA should assess the Regulations

to determine the implications on the ELVs of IPPC installations and Waste licensed facilities, to ensure that they can and will meet the new EQS.

13) The RIA process had identified that the level of enforcement of Section 4 and 16 licences, and the level of knowledge of sources of emissions and their characteristics, varies significantly between local authorities. The level of resources available and the licensing and enforcement systems within the local authorities may not have the capacity to implement the level of control required to achieve the EQS. This gap in understanding the current position must, as a matter of urgency, be addressed by completion of a comprehensive audit of such licences in each local authority.

14) The EPA should continually review the costs and assumptions applied within this RIA, to ensure that the economic impacts identified on the various stakeholders, public and private, from the implementation of the proposed


68

Regulations are kept up to date. This review will allow for the effective management of investment and planning by central and local government.

15) EQS relating to metals may also require background levels to be established for all water bodies to be monitored. This function is likely to sit best within the monitoring programme currently being operated by the EPA.

Research, Studies and Guidance Advice 16) Detailed characterization studies of Irish municipal WWTP should be a

requirement of the incoming licensing regime for such treatment facilities. 17) The renewal and updating of existing Section 16 licences (and those of Section 4)

and enforcement of licence conditions, is inconsistent around the country. Having regard for Section 63 of the Water Services Act 2006 a set of guidelines to underpin a nationwide system of consistent enforcement should be considered by the Department.

18) Guidance for Sectors, including agriculture, water industry and industrial facilities, discharging to receiving waters as a consequence of diffuse run-off, will be required to enable such sectors to take action to reduce discharges.

19) Municipal WWTPs should be required to monitor Priority Substances or Specific Relevant Pollutants and that data is made available to determine the loads of these substances discharging from the plants into the receiving water. This information while collected by the water services section needs to be provided to and taken into consideration by, the planning sections of local authorities.

20) The levels or sources of dangerous substances being discharged to local authority collection systems should be studied to determine their impact on the treatment regimes managed by local authorities.

21) Additional work is also required in relation to the development of a pilot plant (and further assessment is recommended) with regard to the treatment of metals as set out in Section 4 (pg 28) of this RIA.

22) In regard to landfill sites the treatment process and relevant costs will need to be identified for each landfill individually. The impact of treating landfill leachate at source would need to be assessed and compared to continuing of treatment at a WWTP. Due to the lack of adequate information and potential variability of leachate it is not possible to provide meaningful costs associated with this source. This gap in information needs to be addressed.

23) It should be determined if the EPA ERTDI programme is an appropriate vehicle to advance the research recommended in this RIA to close out the gaps in information required to fully consider the impact of these Regulations.

Other Issues 24) Additional maintenance of the road run off systems once installed would need to

be carried out. This is not currently being done, mainly due to lack of resources. Moving forward this may require additional resources to be allocated by the local authorities and NRA.

25) There is a need to ensure that there is sufficient capacity in monitoring laboratories through out the State to ensure a robust system can be put in place. The volume of monitoring likely to be required due to the implementation of these Regulations and other recent Regulations is likely to place significant pressure on laboratory resources across Europe.

26) Clarification needs to be sought in relation to the issue of naturally occurring background levels for metals which exceed the EQS. The monitoring to be carried out for recommendation 15 should feed into this process. Further clarification is also required around the issue of percentile flow in rivers and EQS, and mixing zones around fin-fish farming.


69

8 GLOSSARY OF TERMS

Term Definition Coastal Waters Coastal water means surface water on the landward side of a line, every point of which is

at a distance of one nautical mile on the seaward side from the nearest point of the baseline from which the breadth of territorial waters is measures, extending where appropriate up to the outer limit of transitional waters.

Cyprinid Waters Waters which support or become capable of supporting fish belonging to the cyprinids or other species such as pike, perch and eel as defined in the Freshwater Fish Directive (78/659/EEC).

CSO Point Source Combined Storm Overflow from a sewer system Diffuse Pollution Pollution which originates from various activities and which cannot be trace to a single

source and originates from a spatially extensive land use (eg agriculture, settlements, transport, industry)

Discharge The release of polluting substances from individual or diffuse sources in the installation through effluent directly or indirectly into water bodies as defined under Article 2(1) of Directive 2000/60/EC.

ELV Emission Limit Value – typically associated with a licensed discharge issued by the EPA or local authority

EPA Environmental Protection Agency EQS Environmental Quality Standards General Components Physico-chemical parameters including BOD, DO, MRP, Total Phosphorus, TON, pH,

temp, Ammonium IPPC Integrated Pollution Prevention & Control (Protection of the Environment Act) Lake A body of standing inland surface water Mesotrophic This term is applied to clear water lakes and ponds with beds of submerged aquatic

plants and medium levels of nutrients. NRA National Roads Authority Oligotrophic A term applied to lakes and ponds with clear water and low levels of nutrients. Pollutant A containment whose concentration has increased to an objectionable level and which

may harm the recipient. REACH Regulation of the European Parliament and of the Council Concerning the Registration,

Evaluation, Authorisation and Restriction of Chemicals RIA A tool used to assess the likely effects of a proposed new Regulations or regulatory

change. RBD River Basin District – includes coastal/marine waters up to one nautical mile beyond the

baseline from which territorial waters are measured. It is an area of land and sea made up of one or more neighbouring river basins together with their associated groundwater and coastal waters.

River A body of inland water flowing for the most part on the surface of the land but which may flow underground for part of its course

Salmonid Waters High quality waters suitable for the maintenance of viable self sustaining populations of wild salmon and trout, as defined in the Freshwater Fish Directive (78/659/EEC).

SMART Specific, Measurable, Accepted, Realistic and Time-Dependant – the criteria against which an new Regulation should be assessed against as set out in the RIA Guidelines

Transitional Transitional waters are bodies of surface water in the vicinity of river mouths which are partly saline in character as a result of their proximity to coastal waters but which are substantially influences by freshwater flows.

Water Body The basic compliance reporting and management unit for the Water Framework Directive into which all rivers, lakes, ground, transitional and coastal waters are divided.

Water Policy Regulations European Communities (Water Policy) Regulations 2003 S.I. No. 722 of 2003 WFD Water Framework Directive – Directive 2000/60/EC establishing a framework for

Community Action in the field of water quality WTP Water Treatment Plant WWTP Waste water Treatment Plant


70

ANNEX A Comparison of Proposed & Existing EQSs for General Components (Physico-Chemical)

ANNEX B Candidate Substances for Control under Annex XIV of REACH Regulations

ANNEX C Potential Sources of Substances ANNEX D RBD Summary Information ANNEX E Summary of Sectoral Impacts ANNEX F Potential Treatment Options ANNEX G Priority Substances/Relevant detected in WWTP effluent

(Presence or Absence) ANNEX H Historic Mine Sites Inventory ANNEX I Specific Paramater Comments from Consultation Process ANNEX J Cost Calculations and Assumptions ANNEX K Pesticides

Annex A

Comparison of Proposed & Existing EQSs for General Components (Physico-Chemical)

Table A.1 Comparison of Proposed & Existing EQSs for General Components (Physico-Chemical) (1)

Ref no.

General Component (physico-chemical)

Proposed EQS Impact on Existing EQS

Water Quality Parameters – 1992 – Limiti

Water Quality Parameters – 1992 - Reference

EPA Proposed Water Quality Standards - 1997ii

EPA Proposed Water Quality Standards - 1997

EPA (Licensing)(Amendment) Regulations 2004 S.I. No. 394 of 2004

S.I. No. 258/1998 — Local Government (Water Pollution) Act, 1977 (Water Quality Standards For Phosphorus) Regulations, 1998

Directive 2006/11/EC on Dangerous Substancesiii

1 BOD TAV <2 mg/l annual median

EQS <5 mg/l max individual value

Existing EQS in place – slight lowering of limit – no significant impact

SW Regs - A1: A2: A3: Freshwater Fish Dir g value: Salmonid Waters Regs I/MAC value:

5 mg/l 5 mg/l 7 mg/l </= 3 mg/l (s) </= 6 mg/l (c) </= 5 mg/l

Salmonid Waters - National Regs: EPA Proposed (Salm & Cyp):

</=5 mg/l </=5 mg/l

Referenced in Schedule of Regs – Water (12)

- -

2 DO Rivers: TAV Lower Limit >9 mg/l Daytime

Minimum

TAV Super Sat <11 mg/l Daytime

Maximum

EQS >7 mg/l over 24 hours

Minimum

Existing EQS in place – no significant impact

SW Regs - A1: A2: A3: Bathing Regs: Freshwater Fish Dir: Salmonid Waters Regs I/MAC value: Shellfish 79/923/EEC – g value:

>60% <50% >30% >/=70/</-120 50%/100% 50%>/=9 >/= 80%

Salmonid Waters – FW Regs: EPA Proposal Cyprinid Waters: -FW Directive: EPA Proposal: BW Regs: EPA Proposal:

50% Samples >/= 9 mg/l (min 6mg/l) 50% Samples >/= 9 mg/l (min 6 mg/l) 50% Samples >/= 7 mg/l (min 4 mg/l) 50% Samples >/= 7 mg/l (min 4 mg/l) 50% 70% satn >/= do </= 120% satn (during bathing season 70% satn >/= do </= 120% satn (during bathing season

- - -

(1) Note: The consultation document issued in July as part of the Screening process is constantly under review.

Ref no.










3 MRP Rivers: TAV High Sites

<16 µg P/l TAV Good Sites

<30 µg P/l EQS High Sites

<34 µg P/l EQS Good Sites

<50 µg P/l

Trans Waters: 0-26psu (Winter

Median) TAV 50µg/l

26-35psu (Winter Median)

TAV 50µg/l – 40µg/l

Existing EQS in place - no significant impact

SW Regs - A1: A2: A3: BW Regs: Dangerous Subs Dir 76/464/EEC: Groundwater 80/68/EEC: DW Regs:

0.22 mg/l 0.30 mg/l 0.30 mg/l - List II List II 2.2 mg/l

Rivers – Q rating: 5

4-5 4

3-4 3

2-3 </=2

0.015 mg/l 0.020 mg/l 0.030 mg/l 0.030 mg/l 0.050 mg/l 0.070 mg/l 0.070 mg/l


Rivers: Q: - ug/l (Med Conc.) 5 15 4-5 20 4 30 3-4 30 3 50 2-3 70 <=2 70

-

4 TotalPhosphorus

Determined Intercalibration

n/a Freshwater Fish DirI78/659/EEC:

None specified

Lakes – Clear: Ultra-Oligotrophic Oligotrophic Mesotropic Eutrophotic Hypertropic Lakes – Other: Oligotrophic Mesotropic Eutrophotic Hypertropic

<5 ug/l 5-10 ug/l 10-20 ug/l 10-20 ug/l 20-50 ug/l <10 ug/l 10-20 ug/l 10-35 ug/l 35-100 ug/l


Lakes: Stat: - ug/l (Avg Conc.) U/O <= 5 Oligo >5<=10 Meso <10<=20 Eutro <10<=20 Hyper <10<=50

-

Ref no.










5 TON (DIN) Trans Waters: 0-35psu (Winter

Median) EQS 2.6mg/l –

0.25mg/l EQS 185µM -

18µM

Coastal Waters: >34.5psu (Winter

Median) High sites - EQS

12µM, TAV 10µM High sites - EQS 0.17mg/l, TAV

0.14mg/l Good sites - EQS 18µM, TAV 15µM Good sites - EQS 0.25mg/l, TAV

0.21mg/l

Existing EQS in place – but introduction of new testing – some impact

Nitrate SW Regs –A1 A2 A3 BW Regs: DW Regs: Nitrite Dangerous Subs Dir 76/464/EEC: Freshwater Fish Dir I/MAC value: Salmonid Waters Regs I/MAC value: Groundwater 80/68/EEC: DW Regs: Nitrogen Kjedahl SW Regs - A1: A2: A3: BW Regs: DW Regs:

11.3 mg/l - 11.3 mg/l List II </= 0.003 mg/l </= 0.015 mg/l List II 0.03 mg/l 1 mg/l 2 mg/l 3 mg/l - 1 mg/l

Nitrogen Kjedahl: SW Regs EPA Proposal: Nitrate SW Regs EPA Proposal: Nitrite Salmonid Waters: FW Regs: EPA Proposal: Cyprinid Waters Freshwater Dir: EPA Proposal:

2 mg/l 2 mg/l 50 mg/l 50 mg/l 50 ug/l 200 ug/l 100 ug/l 400 ug/l


- -

Ref no.










6 Ammonium Rivers/Lakes: TAV High Sites <0.035 mg/l N

TAV Good Sites <0.060 mg/l N

(Median)

Existing EQS in place – lowering of limit & new testing – significant impact

Ammonia specified: SW Regs - A1: A2: A3: BW Regs: Dangerous Subs Dir 76/464/EEC: Freshwater Fish Dir I/MAC value: Salmonid Waters Regs I/MAC value: Groundwater 80/68/EEC DW Regs:

0.16 mg/l 1.17 mg/l 3.1 mg/l - List II <0.82 mg/l (total ammonium) </=0.82 mg/l (total ammonium) List II 0.23 mg/l (ammonium)

Salmonid Waters: National Regs: EPA Proposed: Cyprinid Waters Freshwater Fish EPA Proposed

20 ug/l NH3

20 ug/l NH3

20 ug/l NH3

20 ug/l NH3


- -

Ref no.










7 Temp TAV annual maximum

temperature <21.5˚C (caveat

for lagoons) EQS rise above

ambient temperature <1.5˚C (for

thermal discharges)

Need to determine baseline data to assess impact.

SW Regs - A1: A2: A3: Freshwater Fish Dir : Salmonid Waters Regs: Shellfish Regs: DW Regs:

25oC 25oC 25oC - - - 25oC

Salmonid Waters: EPA Proposed: Cyprinid Waters EPA Proposed SW Regs:

Discharge must not result in variation of more than 1.5 oC, temp downstream of thermal discharge must not exceed 21.5 oC … Discharge must not result in variation of more than 1.5 oC, temp downstream of thermal discharge must not exceed 21.5

oC … Discharge must not result in variation of more than 3 oC, temp downstream of thermal discharge must not exceed 28

oC … Discharge must not result in variation of more than 3 oC, temp downstream of thermal discharge must not exceed 28

oC …25oC

- - -

Ref no.










8 pH Rivers/Lakes: EQS Soft Water 4.5< pH < 9.0

TAV Soft Water 5.5 < pH < 9.0

EQS Hard Water 6< pH < 9.0

Existing EQS in place – no significant impact

SW Regs - A1: A2: A3: BW Regs: Freshwater Fish Dir I/MAC value: Salmonid Waters Regs I/MAC value: Shellfish 79/923/EEC: DW Regs:

5.5-8.5 5.5-9.0 5.5-9.0 >/=6</=9 6-9 >/=6 </=9 7-9 6<ph<9

SW Regs EPA Proposal: Rest: EPA Proposal:

5.5<ph>9.0 5.5<ph>9.0 6<ph>9.0

- - -

Table A.2 Comparison of Proposed & Existing EQSs for Priority Substances and Other Pollutants

Proposed EQS Report on Water Quality Parameters, 1992, ERUi

Report on Proposed Water Quality Standards, 1997, EPAii

Ref no. Priority Substances

Annual Average

Concentration (µg/l)*

Maximum Allowed

Concentration (µg/l)**

Impact on Proposed EQS

References: Limits: References: Limits:

EPA (Licensing)(Amendment) Regulations

2004 S.I. No. 394 of 2004

Directive 2006/11/EC on

Dangerous Substances

Priority Substances 1 Alachlor 0.3 0.7 Existing EQS in place – no

significant impact Drinking Water

Regs Surface Water Regs

(A1 waters)

0.0001 mg/l

0.0005 mg/l

Pesticides: SW Regs:

EPA Proposal (SW):

0.5 ug/l (specified cmpds)

0.1 ug/l (individual cmpds)

0.5 ug/l (total all cmpds)

Referenced in Schedule of Regs –

Water (9)

-

2 Anthracene 0.1 0.4 No previous EQS in place – significant impact

-

- EPA Proposal forPAHs

0.2 ug/l (total for 6 specified

compds*USEPA)


Water (5)

Referenced in Annex I – List II of

Directive 3 Atrazine 0.6 2 Existing EQS in place – no



(A1 waters)

0.0001 mg/l

0.0005 mg/l

CSTE Proposal EPA Proposal

1.0 ug/l 2.0 1.0 ug/l


Water (9)


Directive

4 Benzene 10/8 50 No previous EQS in place – significant impact

- - CSTE Proposal 10.0 ug/l EPA Proposal 10.0 ug/l


Water (4)


Directive 5 Brominated

diphenylether iii

0.0005/0.0002 n/a No previous EQS in place – significant impact

- - - - Referenced inSchedule of Regs –

Water (5)

-

6 Cadmium and its compounds (depending on water hardness classes) iv

0.08-0.25/0.2 0.45-1.5 Existing EQS in place – lowering of limit - significant impact

Drinking Water Regs & Surface

Water Regs

0.005 mg/l EU Dir 83/513/EEC:

SW Regs: EPA Proposal:

5 ug/l 5 ug/l 5 ug/l


Water (7)

Referenced in Annex I – List I of

Directive

7 C10-13-Chloralkanes

0.4 1.4 No previous EQS in place – significant impact


Water (1)

-



8 Chlorfenvinp

hos 0.1 0.3 No previous EQS in place

– significant impact - - - - Referenced in

Schedule of Regs – Water (5)

-

9 Chlorpyrifos (Chlorpyrifos-ethyl)

0.03 0.1 No previous EQS in place – significant impact

-

- - - Referenced inSchedule of Regs –

Water (5)

-

10 1,2-Dichloroethane

10 n/a No previous EQS in place – significant impact

- - EU Dir90/415/EEC CSTE Propsal EPA Proposal

12 ug/l 10 ug/l 10 ug/l


Water (5)


Directive

11 Dichloromethane


- - CSTE PropsalEPA Proposal

10 ug/l 10 ug/l


Water (5)


Directive 12 Di (2-

ethylhexyl) phthalat (DEHP)

1.3 n/a No previous EQS in place – significant impact


Water (5)

-

13 Diuron

0.2 1.8 Existing EQS in place – no significant impact

Drinking Water Regs

Surface Water Regs (A1 waters)

0.0001 mg/l

0.0005 mg/l

Various countries EPA Proposal

40/150 25 ug/l


Water (9)

-

14 Endosulfan 0.005 0.01 Existing EQS in place – lowering of limit - significant impact

Drinking Water Regs


0.0001 mg/l

0.0005 mg/l


0.001 ug/l 0.001 ug/l


Water (9)


Directive

15 Fluoranthene 0.1 1 No previous EQS in place – significant impact

- - EPA Proposal forPAHs


compds*USEPA)


Water (5)

-

16 Hexachlorobenzene

0.01vi 0.05 Existing EQS in place – lowering of limit - significant impact

Drinking Water Regs


0.0001 mg/l

0.0005 mg/l

EU Dir 88/347/EEC

EPA Proposal

0.03 ug/l 0.03 ug/l


Water (9)


Directive

17 Hexachlorobutadiene

0.1vi 0.6 Existing EQS in place – no significant impact

Drinking Water Regs


0.0001 mg/l

0.0005 mg/l

EU Dir 88/347/EEC


0.01 ug/l 0.01 ug/l 0.01 ug/l


Water (9)


Directive



18 Hexachloroc

ylohexane (Lindane)

0.02/0.002 0.04 Existing EQS in place – lowering of limit - significant impact

Drinking Water Regs


0.0001 mg/l

0.0005 mg/l

EU Dir 84/491/EEC Freshwater

Estuary marine


Freshwater Rest

0.1 ug/l 0.02 ug/l 0.02 ug/l 0.1 ug/l

0.1 ug/l 0.02 ug/l


Water (9)


Directive

19 Isoproturon 0.3 1 Existing EQS in place – no significant impact

Drinking Water Regs


0.0001 mg/l

0.0005 mg/l

EPA Proposal 0.5 ug/l Referenced in Schedule of Regs –

Water (9)

-

20 Lead and its compounds

7.2 n/a Existing EQS in place – no significant impact


Water Regs

0.05 mg/l SW Regs EPA Proposal

50 ug/l 50 ug/l


Water (7)


Directive 21 Mercury and

its compounds

0.05vi 0.07 Existing EQS in place – lowering of limit - significant impact


Water Regs

0.001 mg/l EU 82/176/EEC SW Regs

EPA Proposal

1 ug/l 1 ug/l 1 ug/l


Water (7)


Directive 22 Naphthalene 2.4/1.2 n/a No previous EQS in place

– significant impact

EPA Proposal forPAHs


compds*USEPA)


Water (5)


Directive 23 Nickel and

its compounds

20 n/a Existing EQS in place – lowering of limit - significant impact

Drinking Water Regs

0.05 mg/l EPA Proposal 100 ug/l Referenced in Schedule of Regs –

Water (7)


Directive 24 Nonylphenol

s 0.3 2 Existing EQS in place – no



(A1 waters)

0.0005 mg/l

0.0005 mg/l

SW Regs EPA Proposal

0.5 ug/l 0.5 ug/l


Water (5)

-

25 Octylphenols 0.1/0.001 n/a Existing EQS in place – lowering of limit - significant impact

Drinking Water Regs


0.0005 mg/l

0.0005 mg/l

- - Referenced inSchedule of Regs –

Water (5)

-



26 Pentachloro-

benzene 0.007 n/a Existing EQS in place –

lowering of limit - significant impact

Drinking Water Regs


0.0001 mg/l

0.0005 mg/l


EPA Proposal (SW):





Water (9)

-

27 Pentachlorophenol

0.4 1 Existing EQS in place – slight lowering of limit -

some impact

Drinking Water Regs


0.0005 mg/l

0.0005 mg/l

EUR 90/280/EEC CSTE Proposal EPA Proposal

10 ug/l 10 ug/l 10 ug/l


Water (5)


Directive

28 Polyaromatic hydrocarbons (PAH)vii

n/a n/a Existing EQS in place – lowering of limit - significant impact

Drinking Water Regs


0.0002 mg/l

0.0002 mg/l

EPA Proposal for PAHs


compds*USEPA)


Water (5)

-

(benzo-a-pyrene)

0.05 0.1 See above See above See above See above See above See above -

(benzo-b-fluoranthene)

n/a

See above See above See above See above See above See above -

(benzo-k-fluoranthene)

∑=0.03

n/a See above See above See above See above See above See above -

(benzo-g,h,i-perylene)


(indeno(1,2,3-cd)pyrene)

∑=0.002


29 Simazine 1 4 Existing EQS in place – no significant impact

Drinking Water Regs


0.0001 mg/l

0.0005 mg/l


1 ug/l 1 ug/l


Water (9)


Directive

30 Tributyltin 0.0002 0.0015 Existing EQS in place – lowering of limit - significant impact

Drinking Water Regs


0.0001 mg/l

0.0005 mg/l

(Tributylintin oxide)


0.001 ug/l 0.001 ug/l


Water (9)

-

31 Trichlorobenzene (all isomers)

0.4 n/a Existing EQS in place – no significant impact

- - EU 90/415/EEC 0.4 ug/l EPA Proposal 0.4 ug/l


Water (5)


Directive 32 trichlorometh

ane 2.5 n/a Existing EQS in place –


- - EU Dir88/347/EEC

EPA Proposal:

12 ug/l 12 ug/l


Water (5)


Directive



33 Trifluarin 0.03 n/a No previous EQS in place

– significant impact CSTE Proposal 0.1 ug/l

EPA Proposal 0.1 ug/l Referenced in


-

Other Pollutants 34 DDT total v 0.025 n/a Existing EQS in place –


Drinking Water Regs


0.0001 mg/l

0.0005 mg/l

EU Dir 86/280/EEC

N/A Use prohibited


Water (9)


Directive

para-para DDT

0.01 n/a Existing EQS in place – lowering of limit - significant impact

Drinking Water Regs


0.0001 mg/l

0.0005 mg/l

EU Dir 86/280/EEC

N/A Use prohibited


Water (9)


Directive

35 Aldrin n/a Existing EQS in place – lowering of limit - significant impact

Drinking Water Regs


0.0001 mg/l

0.0005 mg/l


EPA Proposal (SW):





Water (9)


Directive

36 Endrin n/a Existing EQS in place – lowering of limit - significant impact

Drinking Water Regs


0.0001 mg/l

0.0005 mg/l

EU Dir 88/347/EEC

N/A Use prohibited


Water (9)


Directive

37 Dieldrin n/a Existing EQS in place – lowering of limit - significant impact

Drinking Water Regs


0.0001 mg/l

0.0005 mg/l

EU Dir 88/347/EEC

N/A Use prohibited


Water (9)


Directive

38 Isodrin

∑=0.010

n/a Existing EQS in place – lowering of limit - significant impact

Drinking Water Regs


0.0001 mg/l

0.0005 mg/l

EU Dir 88/347/EEC

N/A Use prohibited


Water (9)


Directive

39 Carbontetrachloride


- - CSTE Proposal 12 ug/l EU Proposal 12 ug/l


Water (5)

-



40 Tetrachloroet

hylene 10 n/a No previous EQS in place

– significant impact - - - - Referenced in


-

41 Trichloroethylene

10 n/a Existing EQS in place – no significant impact

- - EU 90/415/EEC 10 ug/l EPA Proposal 10 ug/l


Water (4)

-

Table A. 3 Comparison of Proposed & Existing EQSs for Specific Relevant Pollutants

Proposed Working

Survey Value

Report on Water Quality Parameters, 1992, ERUi


Ref no. Specific Relevant Pollutants

Annual Average

Concentration (µg/l)



EPA (Licensing)(Amendment) Regulations 2004

S.I. No. 394 of 2004

Directive 2006/11/EC on Dangerous Substances

42 Arsenic 25 Existing EQS in place – no change


Water Regs

0.050 mg/l SW Regs: EPA Proposal:

50 ug/l 50 ug/l


Referenced in Annex I – List II of Directive

43 Chromium

4.7 (III) 3.4/0.6 (IV)

Existing EQS in place – lowering of limit - significant impact


Water Regs

0.05 mg/l SW Regs EPA Proposal

50 ug/l 50 ug/l



44 Cypermethrin 0.0001 No previous EQS in place – significant

impact

None - - - Referenced in Schedule of Regs – Water (9)


45 Copper 5-30 FW15 TW

Existing EQS in place – no change

Drinking Water Regs

Surface Water Regs (A1 waters) Salmonid Waters

Regs

0.5 mg/l

0.05 mg/l

0.005 mg/l

Freshwater Regs:

EPA Proposal:

SW Regs: EPA Proposal:

5-112 ug/l dissolved CU for

spec. hardness 5-112 ug/l

dissolved CU for spec. hardness

100 ug/l 100 ug/l



46 Cyanide 10 Existing EQS in place – no change


Water Regs

0.05 mg/l SW Regs: EPA Proposal:

50 ug/l 50 ug/l


-

47 2,4 D 0.3 No previous EQS in place – significant

impact

- - EPA Proposal: 50 ug/l Referenced in Schedule of Regs – Water (9)


48 Diazinon 0.01 No previous EQS in place – significant

impact



49 Dimethoate 0.48 No previous EQS in place – significant

impact



50 Fluoride 500 (RW) 1500 (SW)

Existing EQS in place – no change


Water Regs

1.0 mg/l SW Regs: EPA Proposal

1000 ug/l 1000 ug/l

- -

Proposed Working

Survey Value




Annual Average





S.I. No. 394 of 2004


51 Glyphosate 65 Existing EQS in place no significant impact

Drinking Water Regs


0.0001 mg/l

0.0005 mg/l


EPA Proposal (SW):





-

52 Linuron 0.5 No previous EQS in place – significant

impact

-

- CSTE ProposalEPA Proposal

1 ug/l 1 ug/l



53 Mancozeb 2 Existing EQS in place no significant impact

Drinking Water Regs


0.0001 mg/l

0.0005 mg/l


EPA Proposal (SW):





-

54 Mecoprop 5.5 Existing EQS in place – lowering of limit - significant impact

Drinking Water Regs


0.0001 mg/l

0.0005 mg/l

UK EPA Proposal

10 ug/l 1 ug/l



55 Monochlorobenzene

1.3 No previous EQS in place – significant

impact

- - CSTE ProposalEPA Proposal

1 ug/l 1 ug/l


Referenced in Annex I – List I of Directive

56 Phenol 7.7 Existing EQS in place no significant impact

Drinking Water Regs


0.0005 mg/l

EPA Proposal 0.5 ug/l Referenced in Schedule of Regs – Water (4)

Referenced in Annex I – List I of Directive

57 Toluene 74 No previous EQS in place – significant

impact

None specified - CSTE Proposal EPA Proposal

10 ug/l 10 ug/l



58 Xylenes Total 10 Existing EQS in place no significant impact

Drinking Water Regs


0.0001 mg/l

0.0005 mg/l

CSTE proposal EPA Proposal

10 ug/l 10 ug/l


-

Proposed Working

Survey Value




Annual Average





S.I. No. 394 of 2004


59 Zinc 8-100 FW 40 TW

Existing EQS in place no significant impact

Surface Water Regs (A1 waters) Salmonid Waters

Regs Freshwater Fish

3.0 mg/l

0.03 mg/l

0.03 mg/l

SW Regs: FW Regs - Salmonid:

EPA Proposal

EU 78/659/EEC - Cyprinid:

EPA Proposal:

3 mg/l 30 ug/l @ hardness

10 & more 30 ug/l @ hardness

10 & more 300 ug/l @

hardness 10 & more 30 ug/l @ hardness

10 & more



* This parameter is the Environmental Quality Standard expressed as an annual average value (EQS-AA). Unless otherwise specified, it applies to the total concentration of all isomers. ** This parameter is the Environmental Quality Standard expressed as a maximum allowable concentration (EQS-MAC). Where the MAC-EQS are marked as "not applicable", the AA-EQS values are considered protective against short-term pollution peaks in continuous discharges since they are significantly lower than the values derived on the basis of acute toxicity. i Report on Parameter of Water Quality – Interpretation and Standards, Environmental Research Unit, 1992 ii Environmental Quality Objectives and Environmental Quality Standards, A discussion document, EPA, 1997 iii For the group of priority substances covered by brominated diphenylethers (No. 5) listed in Decision 2455/2001/EC, an EQS is established only for congener numbers 28, 47, 99, 100, 153 and 154. iv For Cadmium and its compounds (No. 6) the EQS values vary dependent upon the hardness of the water as specified in five class categories (Class 1: <40 mg CaCO3/l, Class 2: 40 to <50 mg CaCO3/l, Class 3: 50 to <100 mg CaCO3/l, Class 4: 100 to <200 mg CaCO3/l and Class 5: ≥200 mg CaCO3/l). v DDT total comprises the sum of the isomers 1,1,1-trichloro-2,2 bis (p-chlorophenyl) ethane (CAS number 50-29-3; EU number 200-024-3); 1,1,1-trichloro-2 (o-chlorophenyl)-2-(p-chlorophenyl) ethane (CAS number 789-02-6; EU Number 212-332-5); 1,1-dichloro-2,2 bis (p-chlorophenyl) ethylene (CAS number 72-55-9; EU Number 200-784-6); and 1,1-dichloro-2,2 bis (p-chlorophenyl) ethane (CAS number 72-54-8; EU Number 200-783-0). vi These EQS are valid if Member States apply an EQS for mercury of 20 µg/kg, an EQS for hexachlorobenzene of 10 µg/kg and an EQS for hexachlorobutadiene of 55 µg/kg, these EQS being for prey tissue (wet weight), choosing the most appropriate indicator from among fish, molluscs, crustaceans and other biota. If Member States do not apply the EQS for biota they shall introduce EQS for water in order to achieve the same level of protection as the EQS for biota. They shall notify the Commission and other Member States, through the Committee referred to in Article 21 of Directive 2000/60/EC, of the reasons and basis for using this approach, the alternative EQS established, including the data and the methodology by which they were derived, and the categories of surface water to which they would apply. viii For the group of priority substances of polyaromatic hydrocarbons (PAH) (No. 28), each individual EQS is applicable, i.e., the EQS for Benzo(a)pyrene, the EQS for the sum of Benzo(b)fluoranthene and Benzo(k)fluoranthene and the EQS for the sum of Benzo(g,h,i)perylene and Indeno(1,2,3-cd)pyrene must be met.

Annex B

Candidate Substances for Control under Annex XIV of REACH Regulations

Candidate Substances for Control under Annex XIV of REACH Regulations

a) Substances meeting the criteria for classification as carcinogenic category 1 or 2 in accordance with Directive 67/548/EEC;

b) Substances meeting the criteria for classification as mutagenic category 1 or 2 in accordance with Directive 67/548/EEC;

c) Substances meeting the criteria for classification as toxic for reproduction category 1 or 2 in accordance with Directive 67/548/EEC;

d) Substances which are persistent, bioaccumulative and toxic in accordance with the criteria set out in Annex XIII of this Regulation;

e) Substances which are very persistent and very bioaccumulative in accordance with the criteria set out in Annex XIII of this Regulation;

f) Substances – such as those having endocrine disrupting properties or those having persistent, bioaccumulative and toxic properties or very persistent and very bioaccumulative properties, which do not fulfil the criteria of points (d) or (e) – for which there is scientific evidence of probable serious effects to human health or the environment which give rise to an equivalent level of concern to those of other substances listed in points (a) to (e) and which are identified on a case-by-case basis in accordance with the procedure set out in Article 59.

Exemptions to the restrictions as detailed by Article 56, paragraphs 1 and 2 shall not apply to the use of substances in scientific research and development. Annex XIV shall specify if paragraphs 1 and 2 apply to product and process orientated research and development as well as the maximum quantity exempted. Exemptions to the restrictions as detailed by Article 56, paragraphs 1 and 2 shall not apply to the following uses of substances: a) Uses in plant protection products within the scope of Directive

91/414/EEC; b) Uses in biocidal products within the scope of Directive 98/8/EC; c) Uses as motor fuels covered by Directive 98/70/EC of the European

Parliament and of the Council of 13 October 1998 relating to the quality of petrol and diesel fuels;

d) Uses as fuel in mobile or fixed combustion plants of mineral oil products and use as fuels in closed systems.

Annex C

Potential Sources of Substances

Table C1 Summary information for chemical substances covered under the proposed Directive – the primary European legislation is referenced here, enacting Irish Regulations are not included.

Priority Substance CAS No. Legislation Governing

Description of uses and sources (1) Potential or known aquatic environment impacts (1)

Priority Substance Polyaromatic Hydrocarbons: Benzo-a-pyrene, benzo-b-fluoranthene, benzo-g,h,i-perylene, benzo-k-fluoranthene, indeno(1,2,3-cd)pyrene

50-32-8, 205-99-2, 191-24-2, 207-99-2, 207-08-9, 191-39-5

Directive 2005/69/EC restricts the marketing and use of extender oils rich in PAH, thus limiting the production of tyres made from these oils and tyre debris containing carcinogens. PAHs are also subject to the POPs Regulations (850/2004).

Released unintentionally from a very wide range of combustion by-products, metal treatment, wood treatment (creosote) and others

Direct effects on aquatic organisms. Accumulation in food chain and sediments.

1,2-Dichloroethane 107-06-2 Use as pesticide banned under Directive 79/117/EEC

Production of vinyl chloride monomer for PVC production (there are no known substitutes of this substance in this process)

May affect human health. Increased need/costs for drinking water treatment.

Alachlor 15972-60-8 Decision taken in April 2006 by EU Standing Committee on Food Chain and Animal Health (SCFA) not to authorise this substance (i.e. not to add substance to Annex 1 of Directive 91/414/EEC).

Plant protection product (herbicide) Direct effects on aquatic organisms and increased need/costs for drinking water treatment

Anthracene 120-12-7 European risk assessment has not yet been completed. But actions have been taken with regard to most uses of creosote (with exception of specified industrial uses - railway sleepers and telephone poles) and coal tar protective coatings.

Released as a result of coal tar distillation and petroleum production. Chemical intermediate, wood preservative (creosote), combustion by-product

Direct effects on aquatic organisms.

(1) Information in this column has been obtained from the RIA's carried out by the EU and DEFRA, referenced within this document, through searches on the World Wide Web and from the European Pollution Emissions Register



Atrazine 1912-24-9 EU decision not to authorise this substance taken in April 2004.


Benzene 71-43-2 Directive 82/806/EEC places a ban on the use of benzene in toys placed on the market when the concentration of free form benzene exceeds 5mg/kg of the weight of the toy or of part of the toy. Draft Risk Assessment completed.

Unintentionally present in a number of products, as a result of combustion and synthesis of other chemicals. It is emitted by natural emission sources such as volcanoes and forest fires. It is also used in a wide range of applications and in some of these there are no known substitutes. Primarily used as a reagent in the production of chemical substances: dyes, detergents, coatings, plastics, fibres, pesticides, adhesives and coatings, lubricating oil additives, dry cleaning, paint and production of some types of rubber. Also found in crude oil, gasoline and cigarette smoke.

Carcinogenic and (therefore) increased need/costs for drinking water treatment.

C10-13-Chloralkanes 85535-84-8 Directive 2002/45/EC places a ban on the marketing and use of substances or preparations containing more than 1% SCCPs in metalworking and leather finishing.

Metal working fluids, flame retardant Accumulation in food chain and sediments

Cadmium and its compounds

7440-43-9 Directive 91/338/EEC prohibits the use of cadmium and its compounds in three areas: pigments, stabilisers and surface treatment (with a general exemption where justification exists on the grounds of safety or reliability and where the use of cadmium is unavoidable). Directive 91/157/EC introduces restrictions on the marketing of certain batteries and accumulators containing mercury and amends Member State legislation on the recovery and controlled disposal of batteries and accumulators.

Emissions are primarily through non-ferrous metal production from primary concentrates (such as zinc and aluminium) and iron and steel manufacture, and also through the use of phosphate fertilisers where it is found as a contaminant. Cadmium is used for corrosion-resistant metal plating, nickel-cadmium, batteries, pigments and plastic stabilisers, discharges by several industrial sectors, some safety critical applications such as in airplane brake linings and safety equipment. The metal is also used in bearings and low melting point alloys.

Direct effects on aquatic organisms. Accumulation in food chain and sediments. Contamination of seafood.



Chlorfenvinphos 470-90-6 EU decision taken not to authorise this substance. Plant protection product (insecticide) Direct effects on aquatic organisms and increased need/costs for drinking water treatment

Chlorpyrifos

2921-88-2 Included in Annex 1 but with stringent use restrictions.

Plant protection product (insecticide) Direct effects on aquatic organisms and increased need/costs for drinking water treatment

Di (2-ethylhexyl) phthalat (DEHP)

117-81-7 It is understood that while the EU environmental risk assessment for DEHP indicates that no further risk reduction is necessary, there are concerns for human health (including indirect exposure via the environment). While the use of DEHP (and other phthalates) in toys and childcare articles is currently restricted across the EU, it is possible that other measures may be introduced when the RRS is completed and agreed.

Plasticiser in soft-PVC Accumulation in food chain and sediments

Dichloromethane 75-09-2 Preliminary risk assessment carried out for the Commission concluded that its current uses (pharmaceutical, adhesives, specialities, foam blowing, aerosols) posed no unacceptable risks – other than as a VOC.

Used as a processing solvent in pharmaceutical industry in the manufacture of steroids, antibiotics, vitamins, and tablet coatings. Also used in paint removers, adhesives, as a flame retardant, as an extracting and degreasing agent, in electronics and manufacturing. Sources of emissions include direct releases of dichloromethane are to the air from its use as a solvent in industry and in certain aerosol sprays and paint strippers. Solvent, aerosol, foam blowing agent

Increased need/costs for drinking water treatment

Diuron 330-54-1 EU Review currently on-going. In April 2006, EU SCFA postponed vote on substance.




Endosulfan

115-29-7 EU decision taken not to authorise this substance in 2005.

Plant protection product (insecticide) Direct effects on aquatic organisms and increased need/costs for drinking water treatment

Fluoranthene 206-44-0 Tar-based paints, creosote, fluorescent and vat dyes. Byproduct of combustion.

Direct effects on aquatic organisms, in particular in sediments.

Hexachlorobenzene 118-74-1 Subject to the POPs Regulations (850/2004). No use in EU but unintentional byproduct. Contained as a contaminant in fungicides and chlorinated organics e.g. in PVC

Accumulation in food chain and sediments

Hexachlorobutadiene 87-68-3 Hexachlorobutadiene is not used in the EU). It will be addressed by POPs Regulations.

No use in EU but unintentional byproduct Accumulation in food chain and sediments

Hexachlorocylohexane (Lindane)

608-73-1 EU decision taken not to authorize this substance. Also to be restricted under POPs regulation (850/2004).

Plant protection product (insecticide) and formed as an unwanted by-product in various organic chemicals.

Direct effects on aquatic organisms and increased need/costs for drinking water treatment

Isoproturon 34123-59-6 Included in Annex 1 but with stringent use restrictions.


Lead and its compounds 7439-92-1 Directive 89/677/EEC places restrictions on the marketing and use of lead carbonates and sulphates the use of which is prohibited in paint. Directive 91/157/EC introduces restrictions on the marketing of certain batteries and accumulators containing lead.

Batteries, rolled products, compounds, shots, weights, PVC stabilisers, electronics industry and many other products. Sources of emissions include iron and steel and non-ferrous metal production, the energy and chemical industry and sewage treatment plants as well as natural sources.

Direct effects on aquatic organisms Accumulation in food chain and sediments. Contamination of seafood.



Mercury and its compounds

7439-76-6 Directive 89/677/EEC places restrictions on the marketing and use of mercury compounds for the protection of the hulls of boats or of any totally or partially submerged appliances or equipment, the preservation of wood, the impregnation of heavy duty industrial textiles and the treatment of industrial waters. Directive 91/157/EC (as amended) introduces restrictions on the marketing of certain batteries and accumulators containing mercury (<0.0005%). The Commissions has recently set out proposals ([COM(2006) 69 final) to place restrictions on the marketing of certain measuring devices containing mercury. Other measures of relevance include the WEEE/ROHS Directives, Large Combustion Plants Directive, Clean Air for Europe (CAFE) Programme, etc. and other measures set out in the Commission’s Mercury Strategy.

Used in the manufacture of thermometers, barometers, diffusion pumps, mercury-vapour lamps, advertising signs, mercury switches, batteries and other electrical apparatus. Other uses are in the chlor-alkali industry and in dental fillings. Sources of emissions include waste incineration, non-ferrous metal production, coal combustion, and chlorine manufacturing plants using mercury cells.Mercury is also released to waste water by industrial processes using the metal and its compounds

Direct effects on aquatic organisms Accumulation in food chain and sediments. Contamination of seafood.

Naphthalene 91-20-3 EU risk assessment identified only the use of naphthalene in the manufacture of grinding wheels as leading to unacceptable risks to the environment from deliberate uses. The risk reduction strategy proposed that emissions be controlled through an appropriate EQS under the WFD and that limits for concentrations in sewage sludge be set under the Sludge Directive (86/278/EEC). Naphthalene oils that contain concentrations of benzo-a-pyrene > 0.005% have been banned under Directive 2001/90/EC.

Chemical intermediate, wood preservative (creosote), combustion by-product. The most significant sources in the environment are combustion sources.




Nickel and its compounds

7440-02-0 Directive 94/27/EC places restrictions on the use of nickel in jewellery and personal objects coming into contact with the skin.

More than 300.000 products mainly as alloys, e.g. stainless steel. Sources of emissions include the combustion of coal and heavy fuel oil, refineries and from refinery products (including road tar), mining and refining operations, municipal waste incineration and windblown dust as well as natural sources.


Nonylphenols 25154-52-3 Directive 2003/53/EC bans the use of nonylphenol and its ethoxylates across the uses giving rise to significant environmental emissions and risks.

Used as a chemical intermediate, industrial detergent and others

Direct effects on aquatic organisms. Hormone-like effects.

Octylphenol (tert) 140-66-9 Euopean Risk Reduction Strategy (completed in August 2006) recommends ban on all uses of Octylphenol except in critical applications.

Used as a chemical intermediate, industrial detergent and others


Pentabromodiphenlyether 32534-81-9 Directive 2003/11/EC places a ban on the marketing and use of penta BDE (and octaBDE) and on the marketing of articles containing concentrations in excess of 0.1% by mass of pentaBDE (and octaBDE) across the EU.

Flame retardants Accumulation in food chain and sediments

Pentachloro-benzene 608-93-5 There are no production sites in the EU for this substance. Past use as an intermediate in the production of the pesticide active ingredient, quintozene has been prohibited in the EU (Decision 2000/816/EC).

Found as an impurity in a small number of pesticide products.

Accumulation in food chain and sediments



Pentachlorophenol 87-86-5 Directive 91/173/EEC bans the use of pentachlorophenol and its compounds in concentrations equal to or greater than 0.1% by mass, except in substances and preparations intended for use in industrial installations: in the treatment of wood; in the impregnation of heavy-duty textiles; as a synthesising and/or processing agent in industrial processes. Use of PCP in wood treatment and industrial processes is later restricted under Directive 1999/51/EC.

Biocide in wood or textiles Direct effects on aquatic organisms.

Simazine 122-34-9 EU decision not to authorize this substance taken in March 2004. Essential uses (on beans, rhubarb, asparagus and hardy ornamental nursery stock, strawberry and hops) continue until 31 December 2007 with stringent use restrictions.


Tributyltin 688-73-3 The main sources of TBT in the environment have been banned already (e.g. antifouling paints). Future use in wood preservatives is to be banned by industry. A Risk assessment is being prepared for Commission. Risk reduction measures are being proposed by industry in relation to the remaining uses that pose unacceptable risks.

Found as impurities within other organotins, antifouling agent on ships.

Accumulation in food chain and sediments. Hormone-like effects. Contamination of seafood.

Trichlorobenzene (all isomers)

120-82-1 Directive 2005/’59/EC sets a threshold of 0.1% by mass for all uses except as an intermediate.

Chemical intermediate, process solvent Direct effects on aquatic organisms. Accumulation in food chain and sediments

Trichloromethane 67-66-3 Risk Assessment to be completed in early 2007. Chemical intermediate, e.g.production of HCFC (blowing agent and refrigerant)

Direct effects on aquatic organisms, in particular in sediments



Trifluarin 1582-09-8 EU review currently on-going as of December 2006.


Other Pollutants Aldrin 309-00-2 Plant protection product (insecticide) Direct effects on aquatic

organisms and increased need/costs for drinking water treatment

Dieldrin 60-57-1 Plant protection product (insecticide) Direct effects on aquatic organisms and increased need/costs for drinking water treatment

Endrin 72-20-8 Hazardous waste sites. Used as a pesticide. Does not dissolve very well in water. Tends to bind to sediment. Can accumulate in animal tissue

Isodrin 465-73-6 Plant protection product (insecticide) Direct effects on aquatic organisms and increased need/costs for drinking water treatment

para-para DDT 50-29-3 Historic Pesticide Biomagnifies in aquatic environments. Persistant and carcinogenic

Carbontetrachloride 56-23-5 Was used in the production of refrigeration fluid, propellants for aerosol cans, pesticides, cleaning fluids, degreasing agent and fire extinguishers.

Only a small amount sticks to soil particles; the rest evaporates or moves into the groundwater. Does not accumulate in animals. May accumulate in plants

Tetrachloroethylene 127-18-4 Used for drycleaning and metal degreasing Significant amount evaporates. Mobile in groundwater. Does not bioaccumulate



Trichloroethylene 79-01-6 Used as a solvent for cleaning metal parts, an ingredient in adhesives, paint removers

Typically evaporates but may stick to particles. Does not bioaccumulate

Table C2 Summary information for chemical substances covered under the proposed Directive

Specific Relevant Pollutant

CAS No. Legislation Governing


Antimony 7440-36-0 Extracted by mining, a by-product of smelting lead and other metals. Alloys, glass/ceramics, flame retardant, stabiliser in rubber, infrared detectors, cosmetics

Most antimony ends up in soil, where it attaches strongly to particles that contain iron, manganese, or aluminium, Antimony is found at low levels in some rivers, lakes, and streams.

Barium 7440-39-3 Used in drilling muds, paint, bricks, ceramics, glass, and rubber.Released during burning of coal and oil.Barium sulfate is sometimes used to perform medical tests and to take x-rays

Accumulation in food chain and sediments.

Boron 7440-42-8 Used mostly to produce glass. Also fire retardants, bleaching agents, leather tanning industries, cosmetics, photographic materials, soaps, cleaners, some wood preservatives and high-energy fuel.

Boron does not appear to accumulate in fish or other organisms in water. It does accumulate in plants

Chromium

7440-47-3 Heat-resistant applications: metallurgical, chemical and refractory. Essential alloy in stainless steel. Used to form high performance alloys e.g. high temperature parts of jet engines. Also used for making bricks in furnaces, as dyes and pigments, for chrome plating, as a chemical catalyst, in leather tanning and wood preserving. Sources of emissions include chemical manufacturing, combustion of fossil fuels, waste incineration and steel/glass production

Chromium can strongly attach to soil and only a small amount can dissolve in water and move deeper in the soil to underground water. Does not accumulate in animals.

Cobalt 7440-48-4 Released during burning of coal or oil or the production of cobalt alloys.

Cobalt released into water or soil will stick to particles. Some cobalt compounds may dissolve.

(1) Information in this column has been obtained from the RIA's carried out by the EU and DEFRA, referenced within this document, through searches on the World Wide Web and from the European Pollution Emissions Register




Epichlorohydrin 106-89-8 Used in the production of glycerin, the manufacture of plastics, as a solvent for cellulose, resins and paints and as an insect fumigant

Insoluble in water

Epoxiconazole 106325-08-0 Plant protection product (insecticide) Direct effects on aquatic organisms and increased need/costs for drinking water treatment

Fenitrothion 122-14-5 Plant protection product (insecticide) Direct effects on aquatic organisms and increased need/costs for drinking water treatment

Fluoride

16984-48-8 Used as a cracking catalyst in oil refineries, drinking water treatment, for etching glass and enamel, rust removal products, as a preservative in glues, cleaning products, manufacture of silicon semiconductor chips as an insecticide and as a wood preservative and in the manufacture of lubricants, dyes, plastics, and pesticides. Sources of emissions include coal combustion and process waters and waste from various industrial processes.

Binds strongly to sediment. Will accumulate in plants and animals.

Glyphosate 1071-83-6 Plant protection product (herbicide) Rapidly binds to sediment Malathion 121-75-5 Plant protection product (insecticide) Limited: Breaks down quickly,

does not tend to bind to sediment Mancozeb 8018'-01-7 Plant protection product (fungicide) Binds to soil. Has a carcinogenic

byproduct Maneb 12427-38-2 Plant protection product (fungicide) Highly toxic to fish and aquatic

species, carcinogenic Mecoprop 7085-19-0 Plant protection product (herbicide) Virtually non-toxic to fish, Low

tendency to bioaccumulate




Molybdenum 7439-98-7 Used in aircraft parts, electrical contacts, industrial motors, and filaments, metal alloys, pigments, plastic, catalysts, flame retardant, lubricants, dietary supplement. Discharges come from many industrial uses, combustion of fossil fuels and incineration of waste

No information was obtained

Nonylphenol ethoxylates 9016-45-9 Surfactants in detergent formulations, wetting agents and as dispersants or emulsifiers in some pesticides.

Endocrinal effect on aquatic organisms. Byproducts bioconcentrate

Pirimiphos-methyl 29232-93-7 Plant protection product (pesticide) No information was obtained Selenium 7782-49-2 Byproduct of copper, silver or lead processing, also from

anode mud of copper refineries and the lead chambers of sulfuric acid plants

Bioconcentrate and bioaccumalate in aquatic fauna

Thiram 137-26-8 Plant protection product (fungiicide)

No information was obtained Tin 7440-31-5 Mining, coal and oil combustion, and the production and

use of tin compounds. Binds to sediment, may form particles or dissolve in water. Bioaccumulates

Toluene 108-88-3 Primarily used as a reagent in the production of chemical substances: dyes, detergents, coatings, plastics, fibres, pesticides, adhesives and coatings, lubricating oil additives, dry cleaning, paint and production of some types of rubber. Also found in crude oil, gasoline and cigarette smoke

Does not usually persist or bioconcentrate

Vanadium 7440-62-2 Metal alloys, catalysts, pigments, dietary supplement Found in some iron ores, and crude petroleum deposits. Mainly used to make steel and automobile parts

Xylene 1330-20-7 Primarily used as a reagent in the production of chemical substances: dyes, detergents, coatings, plastics, fibres, pesticides, adhesives and coatings, lubricating oil additives, dry cleaning, paint and production of some types of rubber. Also found in crude oil, gasoline and cigarette smoke

Low tendency to bioaccumulate. Typically evaporates or is broken down by microorganisms




Zineb 12122-67-7 Plant protection product (fungicide) No information was obtained

Annex D

RBD Summary Information

D1 RBD SUMMARY INFORMATION

Table B.1 Summary of RBD Information

Characteristics ERBD SERBD SWRBD SHIRBD WRBD NWIRBD Neagh/Bann IRBDLand area (km2) 6,269 12,834 11,222 17,963 12,070 7,385 1,787 Population size 1,518,000 516,177 523,423 618,884 374,000 201,941 116,290Land use (%) • Agriculture • Urban • Natural areas

• 75% • 4.7% • 8%

• 45.4% • 0.1% • 54.4%

• 65.1% • 1.6% • 33.4%

• 70.7% • 0.15% • 29.15%

• 47.02% • 0.03% • 52.96%

• 52% • 1% • 47%

• 88% • 2% • 10%

Hydrometric areas 07, 08, 09 and 10 11, 12, 13, 14, 15, 16 and 17

18, 19, 20, 21 and 22 23, 24, 25, 26, 27 and 28

29, 30, 31, 32, 33, 34 and 35

01,03,36,37, 8,39,40

03, 06, 36

RBDs & relevant Local Authorities (Lead Authority in Bold)

Cavan, Drogheda Borough, Dublin City, Dun Laoghhaire/ Rathdown, Fingal Kildare, Louth Meath, Offaly South Dublin, Westmeath, Wicklow.

Carlow, Cork, Kildare, Kilkenny, Laois, Limerick, North Tipperary, Offaly, South Tipperary, Waterford, Waterford City, Wexford, Wicklow.

Cork County, Cork City, Kerry, Limerick, Waterford County, South Tipperary.

Cavan, Clare, Cork, Galway, Kerry, Laois Leitrim, Limerick, Limerick City, Longford, Mayo, Meath, Offaly, Roscommon, Sligo, Tipperary North, Tipperary South, Westmeath.

Clare, Galway City, Galway, Leitrim, Mayo, Sligo, Roscommon.

Cavan, Donegal, Leitrim, Longford, Monaghan, Sligo.

Cavan, Louth, Meath,

Monaghan.

Table D.2 Status of River Water Bodies

Characteristics ERBD SERBD SWRBD SHIRBD WRBD NWIRBD Neagh/Bann IRBDRiver water body numbers

356 655 885 884 951 665 71

‘at risk’ or ‘probably at risk’ (no/%)

311 87.4

546 83.3

416 47

680 76.9

468 49.2

366 55.1

67 94.4

Affected by point source pollution (no/%)

74 20.8

127 19.4

87 9.8

165 18.7

59 6.2

65 9.8

25 35.2

Affected by diffuse source pollution (no/%)

294 82.6

498 76.1

235 26.6

449 50.8

302 31.7

185 27.8

58 81.7

Affected by morphology pressures (no/%)

227 63.7

232 35.4

204 23.1

489 55.3

309 32.5

199 29.9

60 84.5

Affected by abstraction & flow regulation (no/%)

23 6.5

21 3.2

35 4.0

34 3.8

8 0.8

71 10.7

9 12.7

Table D.3 Status of Lake Water Bodies

Characteristics ERBD SERBD SWRBD SHIRBD WRBD NWIRBD Neagh/Bann IRBDLakes assessed 26

12

90

113

322

180

2


20 77

7 58.3

38 42.2

84 74.4

80 24.9

49 27.2

2 100

Affected by point source pollution (no/%)

4 15.3

2 16.7

5 5.6

13 11.5

7 2.2

9 5

2 100

Affected by diffuse source pollution (no/%)

4 15.4

6 50

5 6.7

64 56.7

14 4.3

48 26.7

0 0


13 50

0 0

34 37.8

42 37.2

25 7.8

21 11.7

0 0

Affected by abstraction (no/%)

9 34.6

4 33.3

15 16.7

13 11.5

27 8.3

22 12.2

0 0

Table D.4 Status of Transitional & Coastal Water Bodies

Characteristics ERBD SERBD SWRBD SHIRBD WRBD NWIRBD Neagh/Bann IRBDCoastal & transitional areas (km2)

388 1,107 3,855 1,487 4,882 2,275 190


5 62.5

6 66.7

5 18.5

1 9.1

4 13.4

5 21.7

4 80

Coastal Affected by morphology pressures (no/%)

4 50

6 66.7

3 11.1

1 9.1

3 10

2 8.6

2 40

Affected by pollution (no/%)

3 37.5

2 22.2

2 7.4

0 0

1 3.3

4 17.3

1 20

Transitional Waters ‘at risk’ or ‘probably at risk’ (no/%)

13 100

18 85.7

26 60.5

14 70

18 26.5

9 40.9

6 66.7

Affected by pollution (no/%)

12 92.4

13 61.9

24 55.8

12 60

9 13.3

2 9.1

2 22.2


11 84.6

11 52.4

14 32.6

11 55

10 14.7

7 31.8

6 66.7

Affected by abstraction (no/%)

0 0

0 0

6 14

2 10

0 0

3 13.6

0 0

D1.2 EASTERN RIVER BASIN DISTRICT (ERBD)

D1.2.1 Overview

The ERBD region covers an area of approximately 6269km2, with an estimated 39% of Ireland’s population. It is the most densely populated RBD, with significant industrial capacity, however agriculture is reported to be the highest overall land use at 75%. As reported in the ERBD Characterisation Report, the region contains 88 wastewater treatment plants, 156 Section 4 industrial discharge points, 213 active integrated pollution control licensed discharges, 117 known pumping stations and combined sewer outfall discharge points, 12 mines, 72 quarries, 87 active and inactive landfills (26 licensed) and 124 water treatment plants. There are 356 river water bodies in total in the ERBD. Summary of findings of the risk assessment are as follows:

Table D1.3.1 Summary of ERBD Rivers Risk Assessment

% of rivers deemed categories 1a ‘at risk’ or 1b ‘probably at risk’

Sources Main Contributory Factors

21% Point Sources 39% Section 4 discharges 24% CSOs 17% WWTPs 14% IPPCs 6% WTPs & others

82% Diffuse Sources 73 % general diffuse sources from urban & agricultural pressures

6% Hydrological Impacts Abstraction 64% Morphological

Impact 63% intensive land use 35% channelisation

Table D1.1.2 Summary of Numbers of Point Source Impacts on Rivers

Catchment RP1 RP2 RP3 RP4 RP5 Total WWTP CSOs IPPC Section 4 WTP & other Boyne 12 10 3 6 1 32 Nanny 2 5 3 8 0 18 Liffey 1 8 7 11 3 30 Avoca 5 4 2 20 4 35

The report details a total of 21% of the ERBD rivers were characterised as being ‘at risk’ or ‘probably at risk’ from point sources, 82% from diffuse sources, 6% at risk from hydrological impacts (abstraction) and 64% from morphological impacts. This is the second highest RBD in Ireland for rivers characterised at risk or probably at risk. Of these, the most significant point source impacts in terms of at risk water bodies were Section 4 discharges (45 water bodies) and CSO’s (27 water bodies) with urban and agricultural pressures reported most significant in terms of diffuse pollution. Channelisation and intensive land use are reported to be the most significant hydromorphological pressures in the ERBD. There are in excess of 500 natural standing waters, however only 7 fall within the definition of lakes (>50 ha surface area threshold). Furthermore, an additional 19 lakes are also included as they contain significant abstractions (12 lakes) and are located within Special Areas of Conservation (16 lakes). Summary of findings of the RBD risk assessment are as follows:

ERM ENVIRONMENTAL RESOURCES MANAGEMENT DRAFT 13 JUNE 2007 SCREENING RIA FOR SURFACE WATER

5

Table D1.3.3 Summary of ERBD Lakes Risk Assessment

% of lakes deemed ‘at risk’ or ‘probably at risk’


16% Point Sources Section 4 discharges (4 water bodies)

15% Diffuse Sources Agricultural pressures (4 water bodies)

35% Hydrological Impacts Abstraction 50% Morphological Impact Impoundments & intensive

land use

Table D1.3.1.23 Summary of Numbers of Point Source Impacts on Lakes

Catchment LP1 LP2 LP3 LP4 LP5 Total

WWTP CSOs, TP Overflows IPPC Section 4 WTP & other

Boyne 1 0 1 1 0 3 Nanny 0 0 0 0 0 0 Liffey 0 0 0 3 0 3 Avoca 0 0 0 0 0 0 There are 13 identified transitional water bodies within the ERBD. These are more commonly known as estuaries that form the transitional zone between the freshwater and the coastal water body. A total of 92% of transitional waters were characterised at being at risk.

Table D1.3.5 Summary of ERBD Transitional Waters Risk Assessment

% of transitional waters ‘at risk’ or ‘probably at risk’


92.4% Pollution Effect (Point & Diffuse)

CSOs

0% Hydrological Impacts - 84.6% Morphological Impact Coastal defences and

structures

Table D1.3.6 Summary of Numbers of Point Source Impacts on Transitional Waters

Catchment TP1 TP2 TP3 TP4 TP5 Total


Boyne 1 1 0 0 0 2 Nanny 2 3 0 0 0 5 Liffey 1 4 0 1 0 6 Avoca 2 4 2 3 0 11 Within the ERBD, there are 8 identified coastal water bodies. Coastal water bodies are defined within the WFD as marine non-transitional waters located within one nautical mile of the shore but a 12 mile limit is considered for chemical quality. A total of 62.5% of coastal water bodies were considered to be at risk from all pressures, as detailed in Table below:

Table D1.3.7 Summary of ERBD Coastal Waters Risk Assessment

% of coastal waters ‘at risk’ or ‘probably at risk’



6




WWTPs and Pump Station Overflows

50% Morphological Impact Coastal defences and structures, port tonnage

Table D1.3.8 Summary of Numbers of Point Source Impacts on Coastal Waters



Boyne 0 0 0 0 0 0 Nanny 0 0 0 0 0 0 Liffey 2 2 0 0 0 4 Avoca 0 0 0 0 0 0 D1.3 SOUTH EASTERN RIVER BASIN DISTRICT (SERBD)

D1.3.1 Overview

The SERBD region covers an area of approximately 12,834m2, with an estimated population of 516,177. Agriculture is reported to be the lowest overall land use of all RBDs at 45.4% with natural areas highest comprising of 54.4%. From the EPA, CSO, RBD and other datasets, the SERBD region contains 241 wastewater treatment plants, at least 139 Section 4 licensed discharge points, 112 known pumping stations and combined sewer outfall discharge points, 36 active integrated pollution control licensed discharges to surface waters, 31 mines, 67 quarries, 12 landfills and 72 water treatment plants. There are 655 river water bodies in total in the SERBD. Summary of findings of the risk assessment are as follows:

Table D1.4.1 Summary of SERBD Rivers Risk Assessment



19.4% Point Sources 36% Section 4 discharges 35% WTPs & others 13% CSOs 11% WWTPs 5% IPPCs

76.1% Diffuse Sources General diffuse sources from urban & agricultural pressures

3.2% Hydrological Impacts Abstraction 35.4% Morphological

Impact -

Table D1.4.2 Summary of Point Source Impact Numbers on River Water Bodies

Catchment RP1 RP2 RP3 RP4 RP5 Total WWTP CSOs IPPC Section 4 WTP & other


7

Catchment RP1 RP2 RP3 RP4 RP5 Total All rivers in catchment 18 22 8 62 60 170

83.3% of the rivers within the SERBD were characterised as being ‘at risk’ or ‘probably at risk’. Of these, 19.4% were from point sources, 76.1% from diffuse sources, 3.2% at risk from hydrological impacts (abstraction) and finally 35.4% from morphological impacts. Of these, the most significant source of impact is from diffuse sources from urban and agricultural pressures. With regard to lakes, there are only 12 lakes in the SERBD that fall within this risk assessment. Of these 12 lakes, 7 are characterised to be at risk or probably at risk. A summary of findings of the risk assessment are as follows:

Table D1.4.3 Summary of SERBD Lakes Risk Assessment



16.7% Point Sources - 50% Diffuse Sources Urban & Agricultural

pressures 33.3% Hydrological Impacts Abstraction 0% Morphological Impact None

Table D1.4.4 Summary of Point Source Impact Numbers on Lakes

Catchment LP1 LP2 LP3 LP4 LP5 Total WWTP CSOs IPPC Section 4 WTP & other All lakes in catchment 0 0 0 0 0 0 Note: EPA data did not provide breakdown of contributory factors. There are 1107 km2 of coastal and transitional water bodies identified within the SERBD. These are summarised as follows: A total of 85.7% of transitional waters were characterised at being at risk.

Table D1.4.5 Summary of SERBD Transitional Waters Risk Assessment




CSOs WTPs and other causes


structures

Table D1.4.6 Summary of Point Source Impact Numbers on Transitional Waters

Catchment TP1 TP2 TP3 TP4 TP5 Total WWTP CSOs IPPC Section 4 WTP & other


8

Catchment TP1 TP2 TP3 TP4 TP5 Total All transitional waters in catchment 0 7 0 2 7 16 66.7% of coastal waters were characterised at being at risk from the pressures, as detailed in the Table below:

Table D1.4.7 Summary of SERBD Coastal Waters Risk Assessment




Diffuse


structures, port tonnage

Table D1.4.8 Summary of Point Source Impact Numbers on Coastal Waters

Catchment CP1 CP2 CP3 CP4 CP5 Total WWTP CSOs IPPC Section 4 WTP & other All coastal waters in catchment 0 0 0 0 0 0 D1.4 SOUTH WESTERN RIVER BASIN DISTRICT (SWRBD)

D1.4.1 Overview

The SWRBD region encompasses an estimated area of 11,222m2 in the south west of Ireland. This region has an estimated population of 523,423. The highest reported land use is agriculture at 65.1% while natural areas covering 33.4% of the region. As abstracted from the EPA, CSO, RBD and other datasets, the SWRBD region contains 241 wastewater treatment plants, at least 169 Section 4 industrial discharge points, 162 known pumping stations and combined sewer outfall discharge points, 31 active integrated pollution control licensed discharges, 0 mines, 84 quarries, 58 landfills and 42 water treatment plants. In the SWRBD, there are 885 river water bodies in total. Only 47% of the rivers within the SWRBD were characterised as being ‘at risk’ or ‘probably at risk’. This is the lowest percentage of regional river water bodies at risk in Ireland. A summary of findings of the risk assessment are as follows:

Table D1.5.1 Summary of SWRBD Rivers Risk Assessment




9



9.8% Point Sources 57% Section 4 discharges 21% CSOs 21% WTPs & others

26.6% Diffuse Sources general diffuse sources from urban & agricultural pressures

4% Hydrological Impacts Abstraction 23.1% Morphological

Impact -

Table D1.5.2 Summary of Point Source Impact Numbers on Rivers

Catchment RP1 RP2 RP3 RP4 RP5 Total WWTP CSOs IPPC Section 4 WTP & other All rivers in catchment 0 3 0 8 3 14

9.8% of the river water bodies were characterised as being ‘at risk’ or ‘probably at risk’ were from point sources, 26.6% from diffuse sources, 4% at risk from hydrological impacts (abstraction) and 23.1% from morphological impacts. Of these, the most significant source of impact is from diffuse sources from urban and agricultural pressures. There are 90 lakes within the SERBD region that fall within this risk assessment. Of these 90 lakes, 38 are characterised to be at risk or probably at risk. A summary of findings of the risk assessment are as follows:

Table D1.5.3 Summary of SWRBD Lakes Risk Assessment



5.6% Point Sources - 6.7% Diffuse Sources Agricultural & urban

pressures 16.7% Hydrological Impacts Abstraction 37.8% Morphological Impact None


Catchment LP1 LP2 LP3 LP4 LP5 Total WWTP CSOs IPPC Section 4 WTP & other All lakes in catchment 0 0 0 0 0 0 Note: EPA data did not provide breakdown of contributory factors. With regard to coastal and transitional water bodies identified within the SWRBD, there are 3,855 km2 included in the characterisation risk assessment. These are summarised as follows: A total of 60.5% of transitional waters were characterised at being at risk.


10

Table D1.5.6 Summary of SWRBD Transitional Waters Risk Assessment




47% CSOs 26 % WTPs & others 24% WWTP

14% Hydrological Impacts - 32.6% Morphological Impact -


Catchment TP1 TP2 TP3 TP4 TP5 Total WWTP CSOs IPPC Section 4 WTP & other All transitional waters in catchment 8 16 0 1 9 34 For coastal waters within the SWRBD, 18.5% were characterised at being at risk from the pressures, as detailed in the Table below:

Table D1.5.8 Summary of SWRBD Coastal Waters Risk Assessment




CSOs




Catchment CP1 CP2 CP3 CP4 CP5 Total WWTP CSOs IPPC Section 4 WTP & other All coastal waters in catchment 0 1 0 0 0 1 D1.5 SHANNON INTERNATIONAL REGIONAL BASIN DISTRICT (SHIRBD)

D1.5.1 Overview

The SHIRBD region is classified as an international regional basin district, and responsibility for its management is shared with Northern Ireland. This region occupies an area of approximately 17,963m2 and it is the largest RBD region in Ireland. This region has an estimated population of 618,884. With regard to land use, the highest use is agriculture at 70.7%. As abstracted from the EPA, CSO, RBD and other datasets, the SHIRBD region contains 186 wastewater treatment plants, at least 143 Section 4 industrial discharge


11

points, 90 known pumping stations and combined sewer outfall discharge points, 52 active integrated pollution control licensed discharges, 32 mines, 108 quarries, 115 landfills and 44 water treatment plants. There are 884 river water bodies in the SHIRBD, the main river being the River Shannon. 76.9% of the rivers in the SHIRBD region are characterised as being ‘at risk’ or ‘probably at risk’. A summary of the risk assessment findings are as follows:

Table D1.6.1 Summary of SHIRBD Rivers Risk Assessment



18.7% Point Sources 33% WWTPs 30% Section 4 discharges 24% WTPs & others 15% CSOs 6% IPPCs

50.8% Diffuse Sources 96% general diffuse sources from urban & agricultural pressures

3.8% Hydrological Impacts Abstraction 55.3% Morphological

Impact 70% channelisation 18% intensive land use

Table D1.6.2 Summary of Point Source Impact Numbers on River Water Bodies

Catchment RP1 RP2 RP3 RP4 RP5 Total WWTP CSOs IPPC Section 4 WTP & other All rivers in catchment 71 15 13 63 51 213

Point source elements characterised 18.7% of the river water bodies as being ‘at risk’ or ‘probably at risk’, 50.8% from diffuse sources, 3.8% at risk from hydrological impacts (abstraction) and 55.3% from morphological impacts. Of these sources, the most significant source of impact in the SHIRBD region is from diffuse sources from urban and agricultural pressures. In the SHIRBD region, there are 113 lakes which were assessed as part of this risk assessment. Of these 113 lakes, 84 or 74.4% are characterised to be at risk or probably at risk. A summary of findings of the risk assessment are as follows:

Table D1.6.3 Summary of SHIRBD Lakes Risk Assessment



11.5% Point Sources 35% WTPs & Others 29% Section 4 Discharges 24% WWTPs 6% CSOs 6% IPPC

56.7% Diffuse Sources 100% Agricultural pressures 11.5% Hydrological Impacts 100% Abstraction 37.2% Morphological Impact 100% Impoundment


12


Catchment LP1 LP2 LP3 LP4 LP5 Total WWTP CSOs IPPC Section 4 WTP & other All lakes in catchment 0 0 0 0 0 0 Note: EPA data did not provide breakdown of contributory factors.


Catchment LP1 LP2 LP3 LP4 LP5 Total

WWTP CSOs & TP Overflows IPPC Section 4 WTP & other

All lakes in catchment 4 1 1 5 6 17 For coastal and transitional water bodies identified within the SHIRBD, there are 1,487 km2 included in the characterisation risk assessment. These are summarised as follows: Within the SHIRBD, a total of 70% of transitional waters were characterised at being at risk.

Table D1.6.6 Summary of SHIRBD Transitional Waters Risk Assessment




47% WWTPs 37% Section 4 11% IPC 5% CSOs

14% Hydrological Impacts - 32.6% Morphological Impact 40 % Coastal defences and

structures 25% Channelling/Dredging




All transitional waters in catchment 9 1 2 7 0 19 For coastal waters within the SHIRBD, 9.1% were characterised at being at risk from the pressures, as detailed in the Table below:


13

Table D1.6.8 Summary of SHIRBD Coastal Waters Risk Assessment



0% Pollution Effect (Point & Diffuse)

50% IPC 50% Section 4 licences Note 1




Catchment CP1 CP2 CP3 CP4 CP5 Total


All coastal waters in catchment 0 0 1 1 0 2 Note 1: Discrepancy in data here. O% according to EPA national report. 2 incidences according to RBD report. D1.6 WESTERN RIVER BASIN DISTRICT (WRBD)

D1.6.1 Overview

The WRBD region encompasses an estimated area of 12,070km2 in the west of Ireland. This region has an estimated population of 374,000. The highest reported land use is natural area with 52.96%, agriculture at 47.02% and urban the lowest of all RBDs while natural areas covering 33.4% of the region. As abstracted from the EPA, CSO, RBD and other datasets, the WRBD region contains 271 wastewater treatment plants, at least 257 Section 4 industrial discharge points, 60 known pumping stations and combined sewer outfall discharge points, 9 active integrated pollution control licensed discharges, 31 mines, 58 quarries, 4 landfills and 64 water treatment plants. In the WRBD, there are 951 river water bodies in total, the largest number of river bodies in a RBD in Ireland. 49.2% of the rivers within the WRBD are characterised as being ‘at risk’ or ‘probably at risk’. A summary of findings of the risk assessment are as follows:

Table D1.7.1 Summary of WRBD Rivers Risk Assessment



6.2% Point Sources 75% Section 4 discharges 22% WWTPs (urban) 5% IPPCs

31.7% Diffuse Sources Primarily general diffuse sources from urban & agricultural pressures

0.8% Hydrological Impacts - 32.5% Morphological

Impact -


14


Catchment RP1 RP2 RP3 RP4 RP5 Total WWTP CSOs IPPC Section 4 WTP & other All rivers in catchment 4 7 3 4 5 23 Note 1 Note 1: Some discrepancies in figures between Irish and western reports. 6.2% of the river water bodies were characterised as being ‘at risk’ or ‘probably at risk’ were from point sources, 31.7% from diffuse sources, only 0.8% at risk from hydrological impacts (abstraction) and 31.7% from morphological impacts. Of these, the most significant source of impact is from diffuse sources from urban and agricultural pressures. There are 322 lakes within the WRBD region that fall within this risk assessment. This is the largest number of lakes within any of the RBDs. Of these 322 lakes, 80 are characterised to be at risk or probably at risk. A summary of findings of the risk assessment are as follows:

Table D1.7.3 Summary of WRBD Lakes Risk Assessment



2.2% Point Sources WWTPs Section 4 discharges (4 water bodies) Note 1

4.3% Diffuse Sources Agricultural pressures 8.3% Hydrological Impacts Abstraction 7.8% Morphological Impact Impoundment Note 1: National report details 2.2% point source impact on lakes. The Western RBD reports 2.2% as summary, but then in breakdown of figure the report details 0% point source impact on lakes. Discrepancy in data here.


Catchment LP1 LP2 LP3 LP4 LP5 Total WWTP CSOs IPPC Section 4 WTP & other All lakes in catchment 0 0 0 0 0 0 Note: EPA data did not provide breakdown of contributory factors. With regard to coastal and transitional water bodies identified within the WRBD, there are 1,487 km2 included in the characterisation risk assessment. These are summarised as follows: A total of 70% of transitional waters were characterised at being at risk.

Table D1.7.5 Summary of WRBD Transitional Waters Risk Assessment




WWTP, CSOs


15




structures


Catchment TP1 TP2 TP3 TP4 TP5 Total WWTP CSOs IPPC Section 4 WTP & other All transitional waters in catchment 7 1 0 0 0 8 For coastal waters within the WRBD, 13.4% were characterised at being at risk from the pressures, as detailed in the Table below:

Table D1.7.7 Summary of WRBD Coastal Waters Risk Assessment




Diffuse

0% Hydrological Impacts - 10% Morphological Impact Coastal defences and



Catchment CP1 CP2 CP3 CP4 CP5 Total WWTP CSOs IPPC Section 4 WTP & other All coastal waters in catchment 0 0 0 0 0 0 Only two artificial water bodies were identified during the preliminary RBD characterisation assessment in the Western RBD. These water bodies are the Eglinton Canal and the Cong Canal. No heavily modified water bodies were designated during the assessment. No monitoring results for these water bodies were readily available for review as part of this Screening RIA. D1.7 NORTH-WESTERN INTERNATIONAL RIVER BASIN DISTRICT (NWIRBD)

D1.7.1 Overview

The NWIRBD region covers an area of approximately 7,385m2 covering both Ireland and Northern Ireland with an estimated population of 201,941. Agriculture is reported to be the highest overall land use at 52%, with 1% for urban and 47% for natural land use. As abstracted from the EPA, CSO, RBD and other datasets, the region contains 58 wastewater treatment plants, 21 known Section 4 industrial discharge points, 22 known pumping stations and combined sewer outfall discharge points, 13 active


16

integrated pollution control licensed discharges (with NBIRBD, 1 mines, 0 quarries, 8 landfills and 68 water treatment plants. In total, there are 665 river water bodies in the NWIRBD, of which 55.1% are characterised as a risk or probably at risk. A summary of findings of the risk assessment are as follows:

Table D1.8.1 Summary of NWIRBD Rivers Risk Assessment



9.8% Point Sources No info available

27.8% Diffuse Sources general diffuse sources from urban & agricultural pressures

10.7% Hydrological Impacts - 29.9% Morphological

Impact -


Catchment RP1 RP2 RP3 RP4 RP5 Total WWTP CSOs IPPC Section 4 WTP & other All rivers waters in catchment 0 0 0 0 0 0 No info available The report details a total of 9.8% of the ERBD rivers were characterised as being ‘at risk’ or ‘probably at risk’ from point sources, 27.8% from diffuse sources, 10.7% at risk from hydrological impacts (abstraction) and 29.9% from morphological impacts. In the NWIRBD region, there are 180 lakes included in the assessment, of which 27.7 were characterised as at risk or probably at risk. Summary of findings of the risk assessment are as follows:

Table D1.8.3 Summary of NWIRBD Lakes Risk Assessment



5% Point Sources - 26.7% Diffuse Sources - 12.2% Hydrological Impacts - 11.7% Morphological Impact -


Catchment LP1 LP2 LP3 LP4 LP5 Total WWTP CSOs IPPC Section 4 WTP & other All lakes in catchment 0 0 0 0 0 0 Note: EPA data did not provide breakdown of contributory factors.


17

There are 2,275 km2 of transitional and coastal waters identified for assessment in the NWIRBD region. A total of 40.9% of transitional waters were characterised as being at risk.

Table D1.8.5 Summary of NWIRBD Transitional Waters Risk Assessment




WWTPs

13.6% Hydrological Impacts Abstraction 31.8% Morphological Impact Coastal defences and

structures


Catchment TP1 TP2 TP3 TP4 TP5 Total WWTP CSOs IPPC Section 4 WTP & other All transitional waters in catchment 1 0 0 0 0 1


Catchment TP1 TP2 TP3 TP4 TP5 Total WWTP CSOs IPPC Section 4 WTP & other All transitional waters in catchment 7 1 0 0 0 8 Within the NWIRBD, 21.7% of coastal water bodies were considered to be at risk from pressures, as detailed in the Table below:

Table D1.8.8 Summary of NWIRBD Coastal Waters Risk Assessment




Diffuse sources

8.6% Morphological Impact Coastal defences and structures, port tonnage


Catchment CP1 CP2 CP3 CP4 CP5 Total WWTP CSOs IPPC Section 4 WTP & other All coastal waters in catchment 0 0 0 0 0 0


18

D1.8 NEAGH/BANN INTERNATIONAL RIVER BASIN DISTRICT (NBIRBD)

D1.8.1 Overview

The Neagh Bann IRBD region encompasses an estimated area of 1,787m2. This region has an estimated population of 116,290. The highest reported land use is agriculture at 88% while natural areas cover only 10% of the region. As abstracted from EPA, CSO, RBD and other datasets, the Neagh Bann region contains 21 wastewater treatment plants, 9 known Section 4 industrial discharge points, 16 known pumping stations and combined sewer outfall discharge points, 13 active integrated pollution control licensed discharges (with NWRBD), 1 mine, 0 quarries, 2 landfills and 17 water treatment plants. In the NBIRBD, there are 71 river water bodies in total. A total of 94.4% of the rivers within the NBIRBD were characterised as being ‘at risk’ or ‘probably at risk’. This is the highest percentage of regional river water bodies at risk in Ireland, however the region contains the lowest number of river water bodies. A summary of findings of the risk assessment are as follows:

Table D1.9.1 Summary of NBIRBD Rivers Risk Assessment



35.2% Point Sources No info available from EPA data. 81.7% Diffuse Sources General diffuse sources from urban &

agricultural pressures 12.7% Hydrological Impacts Abstraction 84.5% Morphological

Impact -


Catchment RP1 RP2 RP3 RP4 RP5 Total WWTP CSOs IPPC Section 4 WTP & other All rivers waters in catchment 0 0 0 0 0 0 EPA data shows no information. 35.2% of the river water bodies were characterised as being ‘at risk’ or ‘probably at risk’ were from point sources, 81.7% from diffuse sources, 12.7% at risk from hydrological impacts (abstraction) and 84.5% from morphological impacts. Of these, the most significant source of impact is from diffuse sources from urban and agricultural pressures. There are only 2 lakes within the NBIRBD region that fall within this risk assessment. Of these 2 lakes, both are characterised to be at risk or probably at risk. A summary of findings of the risk assessment are as follows:


19

Table D1.9.3 Summary of NBIRBD Lakes Risk Assessment



100% Point Sources - 0% Diffuse Sources None 0% Hydrological Impacts None 0% Morphological Impact None


Catchment LP1 LP2 LP3 LP4 LP5 Total WWTP CSOs IPPC Section 4 WTP & other All lakes in catchment 0 0 0 0 0 0 Note: EPA data did not provide breakdown of contributory factors. With regard to coastal and transitional water bodies identified within the NBIRBD, there are 190 km2 included in the characterisation risk assessment. These are summarised as follows: A total of 66.7% of transitional waters were characterised at being at risk.

Table D1.9.5 Summary of NBIRBD Transitional Waters Risk Assessment




WWTP


structures


Catchment TP1 TP2 TP3 TP4 TP5 Total WWTP CSOs IPPC Section 4 WTP & other All transitional waters in catchment 2 0 0 0 0 2 For coastal waters within the NBIRBD, 80% were characterised at being at risk from the pressures, as detailed in the Table below:

Table D1.9.7 Summary of NBIRBD Coastal Waters Risk Assessment




WTPs & others

0% Hydrological Impacts - 40% Morphological Impact Coastal defences and



20


Catchment CP1 CP2 CP3 CP4 CP5 Total WWTP CSOs IPPC Section 4 WTP & other All coastal waters in catchment 0 0 0 0 2 0


21

Annex E

Summary of Sectoral Impacts

TableE.1 Summary of Sectoral Impacts Sector/ Stakeholder

Likely Positive Impacts Likely Negative Impacts

Agriculture • Reduced accumulation of pollutants in the food chain;

• Improved water quality for abstraction purposes

• Cessation/ reduction of point source discharges to surface waters (IPPC licensed activities): • Cessation/ reduction of activities including nutrient spreading, pesticide application, etc. causing

diffuse source • Investments in waste & effluent management to reduce diffuse source pollution to surface waters. • Investments where septic tanks or similar systems are used as treatment facilitates, prior to

discharge to surface waters. Aquaculture • Improved productivity in fish stocks;

• Increases in revenue; • Reduced accumulation of pollutants in

the food chain; • Improved water quality for

abstraction purposes;

• Cessation/ reduction of chemical and pesticide use and applications, which may lead to a reduction in quality of the fish stock, reduced productivity, lower profits;

• Cessation/reduction of point source discharges to surface waters (IPPC licensed or LA permitted activities);

• Increased costs due to the need to spread the farms out more which could lead to increased visual impact.

Commercial • Improved water quality for abstraction purposes;

• Improved public image of Ireland & its environment

• Alternative options for disposal and management of sludge (through control of dangerous substances at source);

• Cessation/ reduction of point source discharges to surface waters through changes to IPPC licences or LA discharge permits;

• Investment in wastewater treatment facilities to achieve necessary cessation or reduction of pollutants;

• Improvements where septic tanks or similar systems are used as treatment facilitates, prior to discharge to surface waters;

• Alternative options for disposal and management of sludge; • Increased monitoring of discharges; • Improvements for waste & effluent management to reduce diffuse source pollution to surface

waters (e.g. underground pipelines).

Sector/ Stakeholder


Construction • Improved water quality for abstraction purposes;

• Improved planning policy andstrategies to facilitate the WFD aims

• Improvements for waste handling & management to reduce diffuse source pollution to surface waters.

• Cessation/ reduction of activities including washing operations, runoff etc. causing diffuse pollution

Electricity • Improved water quality for

abstraction purposes;

• Cessation/ reduction of use of specific chemicals/ substances causing diffuse pollution • Cessation/ reduction of point source discharges to surface waters through changes to IPPC licences

or LA discharge permits; • Investment in wastewater treatment facilities to achieve necessary cessation or reduction of

pollutants; Leisure & Catering

• Improved water quality for abstraction purposes;

• Improved water quality for recreational uses;

• Improved public image for Ireland’s tourism industry regarding its environment


• Investment in wastewater treatment facilities or septic tank system (or similar) to achieve necessary cessation or reduction of pollutants;

• Cessation/ reduction of use of specific chemicals/ substances (cleaning agents, etc) causing point or diffuse source pollution

Manufacturing • Improved water quality for abstraction purposes

• Alternative options for disposal and management of sludge (through control of dangerous substances at source);




• Alternative options for disposal and management of sludge; • Increased monitoring of discharges; • Cessation/ reduction of specific chemical use, where treatment is not sufficient to remove from

discharge to surface water, • Improvements for waste & effluent management to reduce diffuse source pollution to surface

waters (e.g. underground pipelines).

Sector/ Stakeholder


Motor & Transport (including water transport)

• Improved water quality for abstraction purposes

•




• Alternative options for disposal and management of waste & sludge (including bilge waste); • Increased monitoring of discharges; • Cessation/ reduction of specific chemical use, where treatment is not sufficient to remove from


waters (e.g. underground pipelines). Services • Improved water quality for

abstraction purposes • Cessation/ reduction of point source discharges to surface waters through changes to IPPC licences

or LA discharge permits; • Investment in wastewater treatment facilities to achieve necessary cessation or reduction of

pollutants; • Improvements where septic tanks or similar systems are used as treatment facilitates, prior to

discharge to surface waters; • Alternative options for disposal and management of sludge; • Increased monitoring of discharges; • Cessation/ reduction of specific chemical use, where treatment is not sufficient to remove from


waters (e.g. underground pipelines). Environmental Protection Agency

• Fulfilment of EPA’s role under WFD in protecting the environment.

• Upgrade of the IPPC & Waste licensing system for proposed EQS; • Additional monitoring & reporting requirements;

Sector/ Stakeholder


Local Authorities

• Improved water quality for drinking water and abstraction purposes;

• Less pollution incidents and cases of contamination drinking watersupplies;

• Improvements where septic tanks or similar systems are used as treatment facilities, prior to

discharge to surface waters;

• Improved treatment efficiency in water treatment plants & potentially decreased costs;

• Less investment required for water treatment facilities;

• Alternative options for disposal and management of sludge (throughcontrol of dangerous substances at source);

• Restriction on the level and location of developments in certain areas;

• Reduced monitoring requirements

• Upgrade of the LA permitting system for proposed EQS; • Upgrade of wastewater treatment facilities and possibly CSOs to achieve proposed EQS;

• Alternative options for disposal and management of sludge (through control of dangerous substances at end of pipe);

• Additional monitoring of wastewater requirements for discharges; • Additional reporting requirements; • Change in planning policies & strategies; • Review of all city and county development plans;

• Increased demands on resources to carry-out monitoring and enforcements work;

General Public • Reduction in exposure to dangerous substances;

• Improved water quality for drink water and abstraction purposes;

• Improved water quality for bathing, leisure and recreational uses

• Change in planning policies & strategies; • Improvements where septic tanks or similar systems are used as treatment facilities, prior to

discharge to surface waters;

Other • Improved water quality for plant and wild life

• Preservation of areas designated as nature conservation areas.

Annex F

Potential Treatment Options

Table F1 Potential Treatment options

Priority Action Substances

Number Substance CAS Number Potential Treatment Process

1 Alachlor 159772-60-8 Adsorbtion (Freundlich Adsorption Isotherm Constant = 376)

2 Anthracene 120-12-7 Adsorbtion (Freundlich Adsorption Isotherm Constant = 479)

3 Atrazine 1912-24-9

4 Benzene 71-43-2 Adsorbtion (Freundlich Adsorption Isotherm Constant = 1.0)

5 Pentabromodiphenlyether 32534-81-9

6 Cadmium and its compounds 7440-43-9

Chemical Precipation e.g. Sulphide Precipiation, Ion Exchange, Reverse Osmosis

7 C10-13-Chloralkanes 85535-84-8

8 Chlorfenvinphos 470-90-6

9 Chlorpyrifos 2921-88-2

10 1,2-Dichloroethane 107-06-2 Adsorbtion (Freundlich Adsorption Isotherm Constants = 1.8/3.6)

11 Dichloromethane 75-09-2 Packed Tower Aeration (PTA)

12 Di (2-ethylhexyl) phthalat (DEHP) 117-81-7

Adsorbtion (Freundlich Adsorption Isotherm Constant (110 = Diethyl phthalate)

13 Diuron 330-54-1

14 Endosulfan 115-29-7 Adsorbtion (Freundlich Adsorption Isotherm Constant = 194)

15 Fluoranthene 206-44-0 Adsorbtion (Freundlich Adsorption Isotherm Constant = 664)

16 Hexachlorobenzene 118-74-1 Adsorbtion (Freundlich Adsorption Isotherm Constant = 450)

17 Hexachlorobutadiene 87-68-3 Adsorbtion (Freundlich Adsorption Isotherm Constant = 258)

18 Hexachlorocylohexane (Lindane) 608-73-1 Adsorbtion (GAC)

19 Isoproturon 34123-59-6

20 Lead and its compounds 7439-92-1 Can be precipitated under alkaline conditions

21 Mercury and its compounds 7439-92-1 Chemical Precipation, Ion Exchange, Reverse Osmosis

22 Naphthalene 91-20-3 Adsorbtion (Freundlich Adsorption Isotherm Constant = 132)

23 Nickel and its compounds 7440-02-0 Chemical Precipation (Hydroxide Precipitation @ pH 10), Ion Exchange, Reverse Osmosis

24 Nonylphenols 25154-52-3 Adsorbtion (Freundlich Adsorption Isotherm Constant = 250)

25 Octylphenols 1806-26-4 Chorine Dioxide, Ozone, Activated Carbon

26 Pentachloro-benzene 608-93-5

27 Pentachlorophenol 87-86-5 Adsorbtion (Freundlich Adsorption Isotherm Constant = 436)

28 Polyaromatic Hydrocarbon (PAH) n/a

(benzo-a-pyrene) 50-32-8 Adsorbtion

(benzo-b-fluoranthene) 205-99-2

(benzo-k-fluoranthene) 207-99-2

(benzo-k-fluoranthene) 207-08-9

(benzo-g,h,i-perylene) 191-24-2

(indeno(1,2,3-cd)pyrene) 191-39-5

29 Simazine 122-34-9

30 Tributyltin 688-73-3

31 Trichlorobenzene (all 12202-48-1 Adsorbtion (Freundlich Adsorption Isotherm

Priority Action Substances


isomers) Constant = 157)

32 trichloromethane 67-66-3

33 Trifluarin 1582-09-8

34 DDT total n/a Adsorbtion (Freundlich Adsorption Isotherm Constant = 322)

para-para DDT 50-29-3

35 Aldrin 309-00-2

36 Endrin 60-57-1 Adsorbtion (Freundlich Adsorption Isotherm Constant = 666)

37 Dieldrin 72-20-8 Adsorbtion (Freundlich Adsorption Isotherm Constant = )

38 Isodrin 465-73-6

39 Carbontetrachloride 56-23-5 Adsorbtion (Freundlich Adsorption Isotherm Constant = )

40 Tetrachloroethylene 127-18-4 Adsorbtion (Freundlich Adsorption Isotherm Constant = 51 )

41 Trichloroethylene 79-01-6 Adsorbtion (Freundlich Adsorption Isotherm Constant = 28 )

Relevant Pollutants


Arsenic 7440-38-2 Chemical Precipation, Ion Exchange, Reverse Osmosis.

Chromium 7440-47-3 Chemical Precipation

Cypermethrin

Copper 7440-50-8

Chemical Precipation (Sulphide Precipiation, Hydroxide Precipitation), Ion Exchange, Reverse Osmosis

Cyanide 57-12-5

2,4-D Adsorption

Diazinon

Dimethoate

Fluoride 16984-48-8 Some Fluoride precipitates with magnesium in excess lime softening, Desalination

Glyphosate 1071-83-6 Chlorination/Oxygenation

Linuron

Mancozeb 8018'-01-7

Mecoprop 96-65-2

Monochlorobenzene

Phenol Adsorption

Toluene 108-88-3 Adsorption (Freundlich Adsorption Isotherm Constant = 200/174 )

Xylenes Total 1330-20-7 Adsorption (Freundlich Adsorption Isotherm Constant = 100 )

Zinc 7440-66-6 Chemical Precipation (Hydroxide Precipitation @ pH 11)

Freundlich Adsorption Isotherm Constants from Dobbs and Cohen 1980. The Isotherms are for the compounds in distilled water, with different Activiated Compounds. The values should only be used as rough estimates as the values that will be obtained using other types of water and other activated carbon.

Annex G

Priority Substances/Relevant detected in WWTP effluent (Presence or Absence)

Table 1.1 Priority Substances/Relevant detected in WWTP effluent (Presence or Absence)

WWTP

1 WWTP 2 WWTP

3 WWTP 4 WWTP

5 WWTP

6 WWTP

7 WWTP

8 WWTP

9 WWTP 10 WWTP 11 WWTP 12 WWTP 13 WWTP 14

Population Equivalent PE

Substance

2,380,000 328,000 20,000 13,833 6,650 6,415 5,200 5,000 1,200 10,600 4,750 7,000 5,000 6,000 1 Alachlor √ 2 Anthracene √ 3 Atrazine √ 4 Benzene X X X 5 Pentabromodiphenlyether √ 6 Cadmium and its compounds √ X X X X X X X X 7 C10-13-Chloralkanes √ 8 Chlorfenvinphos √ 9 Chlorpyrifos X

10 1,2-Dichloroethane X X X

11 Dichloromethane √ X X X X X X

12 Di (2-ethylhexyl) phthalat (DEHP) √ √ √ √ √ √ √ √ √ X X 13 Diuron √ X X √ X X X X X 14 Endosulfan X 15 Fluoranthene √ X X X X X X X 16 Hexachlorobenzene √ X X 17 Hexachlorobutadiene X 18 Hexachlorocylohexane (Lindane) X 19 Isoproturon √ 20 Lead and its compounds √ X X X X X X X √ 21 Mercury and its compounds √ X X X X X 22 Naphthalene √ X X X X X X X 23 Nickel and its compounds √ X √ √ X X X √ √ √ √ √ √ X 24 Nonylphenols √ 25 Octylphenols √ 26 Pentachloro-benzene X 27 Pentachlorophenol √ X X 28 Polyaromatic Hydrocarbon (PAH) - (benzo-a-pyrene) √ X X (benzo-b-fluoranthene) √ (benzo-k-fluoranthene) √ (benzo-k-fluoranthene) √ (benzo-g,h,i-perylene) √ (indeno(1,2,3-cd)pyrene) √

29 Simazine √

30 Tributyltin √ X X X X X X X X X X X X 31 Trichlorobenzene (all isomers) √ 32 trichloromethane √ 33 Trifluarin X 34 DDT total √ para-para DDT √

35 Aldrin X 36 Endrin √ X X X X X X X X 37 Dieldrin √ X X X X X X X X X X X X X 38 Isodrin √ X X X X X X X X X X X X X 39 Carbontetrachloride √ 40 Tetrachloroethylene √ 41 Trichloroethylene √ 42 Arsenic √ X √ X X X X X X 43 Chromium √ √ X X X X X X X

44 Cypermethrin X 45 Copper √ X √ √ √ √ √ √ √ √ √ √ √ √ 46 Cyanide √ 47 2,4 D X 48 Diazinon X 49 Dimethoate X 50 Fluoride √ 51 Glyphosate √ 52 Linuron X 53 Mancozeb √ X X X X X X X X 54 Mecoprop √ √ √ √ X X 55 Monochlorobenzene X 56 Phenol X 57 Toluene √ X X 58 Xylenes Total √ X X 59 Zinc √ √ √ X X √ X √ √ √ √ √ √ √ Note: Priority Action Substances (1-41), Relevant Pollutants (42-69) WWTP 1 - 12 Samples over 12 month period

WWTP 2 to 9 - Once off grab samples WWTP 10 to 14 - Once off composite samples

√ Present in WWTP effluent X Not detected above LOD i.e. LOD<EQS for freshwaters/marine waters (to identify magnitude of the pressure from each parameter) X Not detected above LOD, i.e. LOD>EQS for freshwaters/marine waters (to identify magnitude of the pressure from each parameter)

Not tested

Annex H

Historic Mine Sites Inventory

Table H1 Historic Mine Sites Inventory Mine name Counties Commodities mined Abbeytown Co. Sligo Pb, Zn Ahenny Co. Kilkenny Slate Allihies Caminches Leelogues Mountain mine

Co. Cork Cu (As, Mo, Pyrite)

Avoca East West Shelton Abbey

Co. Wicklow Cu, Au, Ag Cu, Au, Pb, Zn, Ag Tailings

Ballycorus Co. Dublin Pb Ben Bulben Co. Sligo Barytes Bunmahon Co. Waterford Cu Caim Co. Wexford Pb Clare phosphates Doolin Noughaval

Co. Clare Phosphates Phosphates

Connacht Coalfield Bencroy Geevagh Kilronan (Arigna) Slieveanierin Spion Kop/Altagowlan

Cos. Roscommon, Leitrim and Sligo

Coal (bituminous)

Connemara veins Clements Doorus Glengowla Tiernakill

Co. Galway Pb, Ag (Fe, Zn, Cu) Pb, Ag, Zn (Au, Cu, Ba, F) Ni, Fe, Cu, S, (Mo)

Donegal metal veins Carrickart Glenaboghil Glentogher Keeldrum

Co. Donegal Pb, Zn, Ag, Cu

Donegal talc Carrowtrasna Crohy Head Glendowan

Co. Donegal Talc Talc Talc

East Clare deposits Ballyvergin Kilbricken Miltown

Co. Clare Pb, Zn Pb, Zn Pb, Zn

Glendalough Glendalough Upper Lake Glendasan Glenmalure

Co. Wicklow Pb (Ag)

Gortdrum Co. Tipperary Cu, Hg, Ag Keel Co. Longford Zn (Cd) Portroe Corbally Kiloran

Co. Tipperary Slate

Mine name Counties Commodities mined Kingscourt Drumgill Drumgoosat Drummond

Cos. Cavan, Meath and Monaghan

Gypsum

Lady’s Well Co. Cork Barytes Leinster Coalfield 28 Acres Clogh Coolbaun Deerpark Flemings Modubeagh Moneenroe Rossmore Slatt Upper Wolfhill

Cos. Laois, Kilkenny and Carlow

Coal (anthracite)

Monaghan veins Coolartra Hope Lemgare Lisglassan Tamlaght Tassan Tullybuck

Co. Monaghan Pb, Sb

Munster Coalfield Kanturk Cratloe

Cos. Cork and Limerick Coal (anthracite)

Silvermines Ballygowan Ballynoe Shallee Silvermines (Gortmore, Garryard, etc)

Co. Tipperary Zn, Pb, Cu, Barytes

Slieve Ardagh Coalfield Ballynunty Coalbrook Commons Earlshill Foilacamin Gorteen Lickfinn Lisnamrock

Co. Tipperary Coal (anthracite)

Tynagh Co. Galway Pb, Zn, Cu, Barytes West Cork veins Ballycummisk Derreenalomane Derryginagh Mount Gabriel

Co. Cork Cu, barites Cu, barites Cu, barites Cu, barytes

Source: Geological Survey of Ireland

Annex I

Specific paramater comments from consultaiton process

Physico-chemical standards Dissolved Oxygen

• The standard should be expressed as percentage saturation.

• The issue of deoxygenation of profundal waters in lakes needs clarification in regard to oxygen levels, area and duration.

• EQS for stratified waters needs further clarification regarding % of

water column, deoxygenation, duration and or extent whilst bearing in mind the monitoring programme.

• The percentiles for the DO in transitional and coastal waters should be

either 5% or 95% for both upper and lower limits as in each case they are specifying a limit which should be respected by the bulk (95%) of the samples.

Ammonium (Un-ionised)

• Consideration should be given to a modification or exemption to the proposed ammonium EQSs for water bodies draining Peatlands.

• The ammonium standard is quite low for high to good status and may

create analytical difficulties in some laboratories. Nitrate

• Is it Total Oxidised Nitrogen or Dissolved Inorganic Nitrogen? • The proposal to use winter medians for nutrients needs to be reviewed

in the light of the Nitrates Directive's closed period. It is likely that the closed period will affect the pattern of run off of nutrient with a likely increase in levels immediately after the closed period is over. It is suggested that there is a need to look at sampling practices and the use of a median value, particularly a winter median value, over this period to prevent results being obtained that are not representative of what is happening on the ground.

• Does the standard for transitional waters apply to the "winter median"? The proposed nitrate standard for Transitional Waters (2.6 mg/l) needs serious consideration. Also, it is now established that phosphate (and not nitrate) is the limiting nutrient for eutrophication in some estuaries.

Molybdate Reactive Phosphorus (MRP) and Total Phosphorus (TP)

• For rivers - are these median or maximum values? • The combination of TAVs and EQSs is problematic • With regard to the proposed river phosphate standards - it is

important to note that: • The European Environment Agency states that natural

concentrations of P (i.e. Total P) in freshwater vary from catchment to catchment, depending on factors such as geology and soil type - and range from 0 to 50 µg/l P (Ref. 4). Thus, difference may be more related to soil cover than to pollution -

raising the question - is 1 set of phosphate standards sufficient for the whole of Ireland?

• The EC Freshwater Fish Directive (78/659/EEC) (Ref. 7) states that phosphorus limit values of 65 µg/l P for salmonid waters and 130 µg/l P for cyprinid waters, may be regarded as indicative in order to reduce eutrophication (this refers to Total P).

• Intercalibration will not be setting phosphorus standards for lakes.

• Should there be a comment regarding the EQS values for MRP and the

corresponding value in the P Regs, in view of the fact that the latter is more stringent

Turbidity and Suspended Solids

• The EPA is urged to reconsider the decision to defer setting a standard on turbidity and suspended solids. Pressures of siltation due to economic development as well as forestry practices are significant and the effects on salmonid fish are well reported.

Microbiology

• Should there be proposed microbiological standards Specific Relevant Pollutants In relation to Specific relevant Pollutants that are pesticide active substances used in plant protection products, viz. 2,4_D, cypermethrin, dimethoate, glyphosate, linuron, mancozeb and mecoprop, it is considered that:

• The proposed standards are not set at an appropriate level • The basis for the derivation for the proposed standards is not

appropriate • The proposed standards could pose significant difficulties for farmers

and other users by reducing access to safe effective substances. • The proposed standards could expose Government Departments and

Agencies to legal action in respect of regulatory decisions taken, due to conflict with safe uses established by regulatory evaluations conducted in accordance with EU requirements.

• Alternative EQS values for pesticides based on EU regulatory data are proposed

• Some standards appear to be raised, such as dichloromethane, (10 to 20 ug/l), and some not proposed, although current standards exist, due apparently to lack of data. These changes need to be reviewed and discussed further. DC

Due to the lack of data for most of the priority substances and relevant pollutants in the Irish marine environment, there may not be a suitable scientific basis for applying the standards suggested for application by regulatory control. Compliance with the proposed standards in the marine environment may present difficulty because of:

• The range of the natural occurrence values in marine waters • Pollution from freshwater discharges, run-off and atmospheric inputs • Biodiversity of marine organisms, including higher trophic levels, and

presence of sensitive taxa A screening programme to determine the natural occurrence of these substances in the Irish marine waters should be commenced in advance of the proposed standards coming under a regulatory system. The cost of this programme should be assessed in the RIA as an element of compliance assessment. The Screening RIA did not assess the impact of the cost of administration and enforcement of compliance with the regulations on DCMNR through permits which it issues such as aquaculture and foreshore licences. The proposed standard for cypermethrin could result in local, short-term exceedences where this chemical is used at marine finfish farming establishments. The impacts of the standards upon marine finfish farming should be fully assessed in the RIA since the cost burden will rest with the Department of Communications, Marine and Natural Resources in administration and enforcement and with the finfish farmers through the cost of feeds and treatments, limited production opportunities, potential for lost harvest etc. In the case of the metals, it should be explained that the range of the limits for freshwater reflect the decreasing toxicity as the hardness of the water increases. Biological Need for an explanation of the derivation of the EQR values for the river macroinvertebrate classification system. The omission of phytoplankton element for rivers needs explanation.

Annex J

Cost Calculations and Assumptions

ENVIRONMENTAL RESOURCES MANAGEMENT

1

J1 WASTE WATER TREATMENT PLANT COSTS

Assumptions for Phosphorus and Ammonia Removal at WWTPs

1) 1 mg/l orthophosphate and 3 mg/l ammonia in effluent (if a higher level of treatment is required this will result in higher costs)

2) Ammonia removal in a biological suspended growth system 3) Phosphorus removal is chemical P precipitation with Iron salt 4) Capital costs for ammonia removal include aeration tank, aeration system,

monitors and pumps/flow splitters 5) Operational costs for ammonia removal include electricity costs and maintenance

costs 6) Capital costs for phosphorus removal include bunded storage tank and dosing

pumps 7) Operational costs for phosphorus removal include chemical costs, additional

sludge thickening and disposal, electrical costs and maintenance costs 8) No allowance for increase in loading or increase of operational costs 9) Net present value of operational costs calculated by applying a discount rate of 5%

over 30 years 10) Whole life costs include capital costs and NPV of operational costs (discounted at

5% over 30 years) 11) Cost per kg of ammonia or phosphorus is whole life cost 12) Table 1.2 and 1.3 reflects cost if all plants currently without nutrient removal will

require same (this is the extreme case, more detailed information on the assimilative capacity of the receiving waters is required to accurately access numbers which will require nutrient removal)

Assumptions for Priority Substances and Relevant Pollutants Removal at WWTPs

1) Table 1.1 refers to Capital costs only for removal of Priority Substances and Relevant Pollutants

2) It was assumed that discharge consent would be 50% of current effluent concentrations (current effluent data from Dangerous Substances Screening Programme)

3) Treatment process includes tertiary filtration, chemical precipitation and Granular Activated Carbon

4) It was assumed for chemical precipitation one mixing tank, one clarification tank and one pH correction tank is required

ENVIRONMENTAL RESOURCES MANAGEMENT ENVIRONMENTAL PROTECTION AGENCY

J1

Table 1.1 Capital, Operating and Whole Life Costs for one WWTP in each PE range

Description >50,000 PE 10,000-50,000 PE 2,000-10,000 PE 500-2,000 PE 300-500 PE CAPEX OPEX TOTAL CAPEX OPEX TOTAL CAPEX OPEX TOTAL CAPEX OPEX TOTAL CAPEX OPEX TOTAL Chemical P Precipitation Storage Tank/Bund/Dosing Pumps/Shower 57,105 57,105 52,536 52,536 42,094 32,631 32,631 32,631 32,631 Chemical Costs pa 172,587 172,587 31,940 31,940 12,710 12,710 2,343 2,343 781 781 Electrical Costs pa 2,500 2,500 2,500 2,500 2,500 2,500 2,500 2,500 2,500 2,500 Maintenance (5% ME costs pa) 938 938 1,013 1,013 1,013 1,013 700 700 700 700 Extra sludge 166,303 166,303 30,777 30,777 16,330 16,330 2,661 2,661 887 887 OPEX pa 342,328 342,328 66,230 66,230 32,552 32,552 8,204 8,204 4,868 4,868 NPV 30 years @ 5% discount rate 5,262,419 5,262,419 1,018,115 1,018,115 500,409 500,409 126,117 126,117 74,834 74,834 Whole Life Costs over 30 years 5,319,524 1,070,651 542,503 158,748 107,465 Cost per kg removed (Cap+Op over 30yrs) 2.40 2.61 4.98 5.97 12.12 Ammonia Removal aeration tank 729,000 729,000 162,000 162,000 121,500 121,500 72,900 72,900 40,500 40,500 aeration blowers (duty/duty/stanby) 101,250 101,250 56,700 56,700 20,250 20,250 16,200 16,200 12,150 12,150 fine bubble diffused air system (duty/duty) 148,500 148,500 110,700 110,700 67,500 67,500 40,500 40,500 27,000 27,000 DO probe/monitor 16,200 16,200 10,949 10,949 10,949 10,949 10,949 10,949 8,100 8,100 flow splitters, pumps, pipework 40,500 40,500 27,000 27,000 27,000 27,000 27,000 27,000 27,000 27,000 Capital Cost 1,035,450 1,035,450 367,349 367,349 247,199 247,199 167,549 167,549 114,750 114,750 electricity costs 187,902 187,902 38,719 38,719 33,215 33,215 11,388 11,388 6,833 6,833 maintenance 21,850 21,850 9,706 9,706 6,156 6,156 4,286 4,286 3,050 3,050 OPEX pa 209,752 209,752 48,425 48,425 39,371 39,371 15,674 15,674 9,883 9,883 NPV 30 years @ 5% discount rate 3,224,402 3,224,402 744,406 744,406 605,221 605,221 240,940 240,940 151,923 151,923 Whole Life Cost over 30 years 4,259,852 1,111,755 852,420 408,489 266,673 Cost per kg removed 0.64 0.90 1.74 5.12 10.02

Table 1.2 Ammonia Removal

PE range >50,000 10,000- 50,000 2,000-10,000 500-2,000 300-500 TOTAL PE (design plant) 100,000 20,000 6,650 1,200 400 - m3/day 22,500 4,164 1,657 270 90 -kg/d - one plant 608 112 45 7 2 -kg pa - one plant 221,738 41,036 16,330 2,661 887 -kg pa - all plants 1,330,425 1,395,231 1,975,898 689,160 73,617 -€/kg 0.64 0.90 1.74 5.12 10.02 -€ pa 851,970 1,259,989 3,438,092 3,526,618 737,795 9,814,465

Table 1.3 Phosphorous Removal

PE range >50,000 10,000- 50,000 2,000-10,000 500-2,000 300-500 TOTAL PE (design plant) 100,000 20,000 6,650 1,200 400 -m3/day 22,500 4,164 1,657 270 90 -kg/d - one plant 203 37 15 2 1 -kg pa - one plant 73,913 13,679 5,443 887 296 -kg pa - all plants 443,475 465,077 658,633 229,720 24,539 -€/kg 2.39 2.61 3.32 5.97 12.12 -€ pa 1,061,284 1,213,404 2,188,097 1,370,527 297,319 6,130,632

Table 1.4 Treatment Costs for Priority, Priority Hazardous and Relevant Specific Pollutants

>50,000 10,000- 50,000 2,000-10,000 500-2,000 300-500 Chemical Precipitation 506,700 206,700 146,700 101,700 101,700Sand Filtration System 379,500 187,500 97,059 29,412 29,412Granular Activated Carbon Unit 379,500 117,500 72,750 44,700 44,700Other (Installation Costs, preliminaries etc.) 713,855 288,599 161,591 99,158 99,158TOTAL COST 1,979,555 800,299 448,100 274,970 274,970

J2 ASSUMPTIONS FOR IPC/IPPC INDUSTRIES

1) Load of Priority Substance and Specific Relevant Pollutant to be removed was identified from SERBD data (1 industry per nace code)

2) The maximum load per industry type was identified and this multiplied against the upper bound cost (€/kg) to determine a range of costs for IPC/IPCC industries discharging to sewer or water

3) The cost rates (€/kg) were sourced from Source: Draft partial regulatory impact assessment of environmental quality standards for implementation of the Water Framework Directive in the UK (DEFRA, 2007)

4) Cost rate (€/kg) is inclusive of capital and operating costs (for an additional treatment unit it is assumed that there is already an existing treatment plant) annualised over 15 years at 3.5%

5) Costs of €40,000 to €4.2M (per plant per annum) was identified for IPC/IPPC discharging to water

6) Costs of €90,000 to €4.2M (per plant per annum) was identified for IPC/IPPC discharging to sewer

Table 2.1 Costs of removing pollutants by sector and type of industry in Euro (1.5 x £

sterling/kg removed, secondary treatment) (annualised, 15 years @ 3.5%)

Cost of removing Metals Cost of removing Organics (€/kg) (€/kg) Sector Lower Bound Upper Bound Lower Bound Upper Bound Chemicals & Pharmaceutical

800.03 2105.66 3.54 7.52

Paper and Pulp 8.75 42.93 0.12 1.74 Metal Finishing 1.14 7.93 8.73 15.96 Textiles 157.94 - 2.46 9.24 Table 2.2 below is a comparison of some typical EPA emission limit values assigned to IPC/IPPC facilities discharging to surface waters, against the proposed EQS for that parameter. By simply dividing the ELV by the EQS you can get an indication of the level of dilution which will be required in the surface water body to ensure compliance with the EQS.

Table 2.2 Comparison of IPC/IPPC Emission Limit Values (ELV) for discharges to Surface Waters and proposed EQS

Parameter Cu As Hg NH4 as N Zn Cr ELV 0.5 mg/l 0.15 mg/l 0.03 mg/l 10 mg/l 1.5 mg/l 0.5 mg/l EQS 5 µg/l 25 µg/l 0.05 µg/l 0.035 mg/l 8 – 100 µg/l 5 -30 µg/l Dilution 100 6 600 285 190 - 15 500 - 16


1

J3 ASSUMPTIONS FOR SEPTIC TANKS

1) Cost of €7,000 from Presentation by Matt Short (Tipperary County Council)

OSWTS Conference in Mullingar in September 2007 2) Cost is capital cost only, and is based on the assumption of good ground

conditions an engineered site may cost upwards on €20,000 3) Assumption 1: septic tanks - one third of all systems will require upgrading,

proprietary treatment systems - 99% of systems will require upgrading 4) Assumption 2: septic tanks - all systems will require upgrading, proprietary

treatment systems - 75% of systems will require upgrading 5) (1% - 25% of proprietary system owners maintain a service record)

Table 3.1 Capital Costs for Upgrading Septic Tanks/Proprietary Treatment Systems

Assumption 1 Assumption 2

Total No.

Cost per unit

No units Cost

No units Cost

No. Septic Tank units 418,033 7,000 139,344 975,410,333 418,033 2,926,231,000 No. of Proprietary Systems 29,685 7,000 22,634 158,438,000 29,388 205,716,000


2

J4 ASSUMPTIONS FOR DISUSED MINES

Costs for disused mines sites based on treatment costs for Avoca Mines from Unipure Europe Ltd., Avoca Mines Pilot Plant Treatment Trials A Report to Celtic Copper Heritage, European Union Interreg IIIA Project February 2007. Costs included for capital cost of €3,568,000 and an annual operating cost of €502,000 for a high density hydroxide plant.


3

Annex K

Pesticides

K1 PESTICIDES

Below is a summary of the information identified in relation to the status, use, effects and substitutes for each of the pesticides within the 59 substances proposed to have EQS.

K1.1 PRIORITY SUBSTANCES

1,2-Dichloroethane (CAS 107-06-2) Status: The use of 1,2-dichloroethane as a pesticide has been banned in Ireland since 1988 and banned in the EU since 1979 under Council Directive 79/117/EEC of 21 December 1978 prohibiting the placing on the market and use of plant protection products containing certain active substances. Its industrial use is still permitted for the production of vinyl chloride monomer for PVC production. Use: According to Central Statistics Office figures received, 276 tonnes of 1,2-dichloroethane was imported in 2004, 3458 tonnes in 2005, and 3258 in 2006. Other sources include leaded petrol, some cleaning agents (used on rugs and upholstery), in resin and rubber adhesives, and some paint, varnish and finish removers. Effects: It can possibly affect human health, can increase the need for water treatment and is not expected to concentrate in fish. Substitute: There is no known substitute of this substance for the manufacture of PVC. However, for other industrial uses it is possible to substitute 1,2-dichloroethane partially or completely with other chlorinated hydrocarbons, such as carbon tetrachloride or chloroform. Alachlor (CAS 15972-60-8) Status: The decision not to authorise the use of alachlor as a pesticide was taken in April 2006 by the Standing Committee on Food Chain and Animal health (SCFA). Its use as a pesticide has been banned in all Member States since June 2007. Use: It was used in agriculture as a herbicide to control annual grasses and broadleaf weeds. It can be effectively mixed in formulations with atrazine, glyphosate and trifluralin. Effects: Alachlor can have direct negative effects on aquatic organisms and can cause an increase in the need for drinking water treatment. Substitute: According to the United States Environmental Protection Agency acetochlor can be a direct substitute for many herbicides of known concern, including alachlor (United States Environmental Protection Agency (2007) Regulating Pesticides, www.epa.gov/oppefed1/aceto/). The substance acetochlor is not registered with the Pesticide Control Service as being used as a herbicide. In 2004, the most commonly used herbicides on arable crops were: sulphuric acid; glyphosate; mecoprop p; isoproturon; diflufenican isoproturon; metamitron (DAFF, 2004). Possible substitutes may include these substances or other herbicides authorised to be used under Annex I of Council Directive 91/414/EEC of 15 July 1991 concerning the placing of plant protection products on the market. This is reproduced at the end of this Annex. Atrazine (CAS 1912-24-9) Status: The use of atrazine as a pesticide has been prohibited under Directive 91/414/EEC since 2004. Ireland had an exemption to use atrazine as weed control in maize and forestry until June 2007. Use: It was used in agriculture as a herbicide to control annual grasses and broadleaf weeds. In 2003 Atrazine was the fourth most commonly used active substance and represented 4% of the total weight of active substances applied to grassland and

fodder crops. It accounted for 51% of the herbicide treated maize area and 66% of the quantity of herbicides applied. In total 24,152 kg of Atrazine was applied to an area of 14,166 ha in 2003 (DAFF, 2003). Effects: Atrazine is moderately toxic for aquatic organisms and has direct negative effects on aquatic organisms. It causes an increase in the need to treat drinking water. Substitute: According to the United States Environmental Protection Agency acetochlor can be a direct substitute for atrazine. The substance acetochlor is not registered with the Pesticide Control Service as being used as a herbicide. In 2004, the most commonly used herbicides on arable crops were: sulphuric acid; glyphosate; mecoprop p; isoproturon; diflufenican isoproturon; metamitron(DAFF, 2004). Possible substitutes may include these substances or other herbicides authorised to be used under Annex I of Directive 91/414/EEC. Chlorfenvinphos (CAS 470-90-6) Status: In 2003 the use of chlorfenvinphos as a pesticide was prohibited under Directive 91/414/EEC. Ireland had an exemption to use chlorfenvinphos for insect control on certain market garden crops e.g. carrot, parsnip, swede, etc. until June 2007. Use: It was used as an insecticide, domestically and in agriculture, to control flies and fleas, and could be used to control rodent populations. Effects: It has direct negative effects on aquatic environments and causes increased needs to drinking water treatment. Substitute: There is no information available indicating the most successful substitute for chlorfenvinphos. In 2004, the most commonly used insecticides on arable crops were: dimethoate; chlorpyrifos; cypermethrin; oxydemeton-methyl; and carbofuran isofenphos (DAFF, 2004). Possible substitutes may include these substances or other insecticides included in Annex I of Directive 91/414/EEC. Chlorpyifos (CAS 2921-88-2) Status: The use of chlorpyifos as a pesticide is authorised under Directive 91/414/EEC. Use: It is used in agriculture as an insecticide to control insects in maize and orchards. In 2003, 235 kg was applied to 327 ha of grass, 52 kg applied to 77 ha of Swedes,turnips, and 49 kg applied to 49 ha of kale and rape (DAFF, 2003). In 2004, 2,984 kg was applied to 5,819 ha of spring barley, 109 kg applied to 907 ha of spring wheat, 446 kg applied to 2,256 ha of winter wheat and 311 kg applied to 462 ha of sugar beet (DAFF, 2004). There are currently 11 approved plant protection products in Ireland containing the active ingredient (Pesticide Control Service (PCS) (2007) Pesticides 2007 www.pcs.agriculture.gov.ie/Docs/Pesticides2007.pdf). Effects: Chlorpyifos is moderately to highly toxic to fish and aquatic organisms. It has direct negative effects on aquatic organisms and increases the need for drinking water treatment. Substitute: There is no information available indicating the most successful substitute for chlorpyifos. In 2004, the most commonly used herbicides on arable crops were: dimethoate; chlorpyrifos (it was the second most commonly applied herbicide); cypermethrin; oxydemeton-methyl; and carbofuran isofenphos (DAFF, 2004). Possible substitutes may include these substances or other insecticides included in Annex 1 of Directive 91/414/EEC. Diuron (CAS 330-54-1) Status: Diuron is to be phased out in the EU under the authorisation of Directive 91/414/EEC. It has been granted a limited extension of use until the end of 2007. Use: It is used in agriculture as a herbicide to control a wide variety of annual and perennial broadleaf and grassy weeds on both crop and non-crop sites. Diuron is registered for use on numerous crop sites such as forage crops, field crops, fruits,

vegetables, nuts and ornamental crops. There are currently 19 approved plant protection products in Ireland containing the active ingredient (PCS, 2007). Effects: Diuron is moderately to highly toxic with direct negative effects on aquatic organisms and an increase in the need to treat drinking water. Diuron is accumulated within sediments when released into waters, where it is slowly broken down by natural biological processes. Substitute: There is no information available indicating the most successful substitute for diuron. In 2004, the most commonly used herbicides on arable crops were: sulphuric acid; glyphosate; mecoprop p; isoproturon; diflufenican isoproturon; metamitron (DAFF, 2004). Possible substitutes may include these substances or other herbicides included in Annex 1 of Directive 91/414/EEC. Endosulfan (CAS 115-29-7) Status: The decision was taken in 2005 not to authorise the use of endosulfan as a pesticide under Directive 91/414/EEC. Its use has been banned since June 2006. Use: Endosulfan is an insecticide and is used to control insects on food and non-food crops and also as a wood preservative. Effects: If released into an aquatic environment it will have direct negative effects on aquatic organisms and will increase the need to treat the drinking water. Substitute: There is no information available indicating the most successful substitute for endosulfan. In 2004, the most commonly used insecticides on arable crops were: dimethoate; chlorpyrifos; cypermethrin; oxydemeton-methyl; and carbofuran isofenphos (DAFF, 2004). Possible substitutes may include these substances or other insecticides included in Annex 1 of Directive 91/414/EEC. Hexachlorocylohexane (Lindane) (CAS 608-73-1) Status: The use of hexachlorocylohexane as a pesticide was banned under Directive 91/414/EEC in 2003. Its use in industry has also been restricted since 2004 under Regulation (EC) 850/2004 of the European Parliament and of the Council of 29 April 2004 on persistent organic pollutants and amending Directive 79/117/EC. Use: Hexachlorocylohexane is an insecticide and is formed as an unwanted by-product in various organic chemicals. Although it was primarily used as a pesticide it was also used in the chemical industry, for PVC production, and for wood treatment. Effects: It has direct negative effects on aquatic environments and increases the need to treat drinking water. Substitute: There is no information available indicating the most successful substitute for hexachlorocylohexane. In 2004, the most commonly used insecticides on arable crops were: dimethoate; chlorpyrifos; cypermethrin, oxydemeton-methyl; and carbofuran (DAFF, 2004). Possible substitutes may include these substances or insecticides included in Annex I of Directive 91/414/EEC. Isoproturon (CAS 34123-59-6) Status: The use of Isoproturon as a herbicide is allowed under Directive 91/414/EEC but is subject to stringent use restrictions. Use: It is a herbicide used in the agricultural sector to control annual grasses and many annual broadleaved weeds in spring and winter wheat, spring and winter barley and winter rye. In 2003, 174 kg of isoproturon was applied to 349 ha of arable silage (DAFF, 2003). In 2004, isoproturon was the most extensively used herbicidal active substance for both winter barley (8,051 kg over 12874 ha) and winter wheat (39,455 kg over 50,244 ha). It was also used on Spring barley (2,689 kg over 3,222 ha), Spring wheat (2,733 kg over 3,256 ha), and beans (143 kg over 202 ha) and wheat and oilseed for industrial purposes (145 kg over 248 ha) (DAFF, 2003). There are currently 12 approved plant protection products in Ireland containing the active ingredient (PCS, 2007).

Effects: It has direct negative effects on aquatic organisms and increases the need to treat drinking water. Substitute: There is no information available indicating the most successful substitutes for Isoproturon. In 2004, excluding isoprotuon, the most commonly used herbicides on arable crops were: sulphuric acid; glyphosate; mecoprop p; metamitron (DAFF, 2004). Possible substitutes may include these substances or other herbicides included in Annex I of Directive 91/414/EEC. Pentachlorphenol (CAS 87-86-5) Status: Council Directive 91/173/EEC of 21 March 1991 amending for the ninth time Directive 76/769/EEC on the approximation of the laws, regulations and administrative provisions of the Member States relating to restrictions on the marketing and use of certain dangerous substances and preparations bans the use of pentachlorophenol and its compounds in concentrations equal to or greater than 0.1% by mass, except in substances and preparations intended for use in industrial installations: in the treatment of wood. Use: It is primarily used for wood treatment, textiles, and to control fungal growth in timber. In the past, it has been used as a herbicide, insecticide, fungicide, algaecide, disinfectant and as an ingredient in antifouling paint. Some applications were in agricultural seeds (for non-food uses), leather, masonry, wood, cooling tower water, rope and paper mill system. Effects: It has direct negative effects on aquatic organisms. Substitute: There is no information available indicating the most successful substitute for pentachlorphenol. Possible substitutes include Copper Naphthenate or Copper-8-Quinolinolate (Oxine Copper) and other biocides included in Annex 1 of Directive 91/414/EEC. Simazine (CAS122-34-9) Status: The EU decision not to authorize the use of this substance as a pesticide was taken in March 2004. Ireland has an exemption to use simazine for essential uses (on beans, rhubarb, asparagus, potatoes, soft fruits, ornamental nursery stock and hops) until December 31st 2007, subject to stringent use restrictions. Use: It was widely used in agriculture as a residual non-selective herbicide. In 2003, 269 kg of Simazine was applied to grassland and fodder crops (DAFF, 2003). In 2004, 1,949 kg was used on 1,932 ha of beans and 3,628 kg was used on 33,320 ha of potatoes (DAFF, 2004). Effects: It has direct negative effects on aquatic organisms and increases the need to treat water. Substitute: There is no information available indicating the most successful substitute for simazine. In 2004, the most commonly used herbicides on arable crops were: sulphuric acid; glyphosate; mecoprop p; isoproturon; diflufenican isoproturon; metamitron (DAFF, 2004). Possible substitutes may include these substances or other herbicides included in Annex I of Directive 91/414/EEC. Tributyltin (CAS 688-73-3) Status: The main sources of tributyltin, anti-fouling biocidal and fungicidal paints, have been banned. The use of organotin anti-fouling compounds has been restricted in the State under by-law 657 of 1987. Use: Tributyltin is found as impurities within other organotins and in antifouling agents on ships. It was used as a wood preservative and as an antifungal in textiles and water systems, such as cooling tower and refrigeration water systems, wood pulp, paper mills and breweries. Effects: Tributyltin contaminates aquatic organisms and accumulates in the food chain and sediments. It causes disruption to the hormone systems of aquatic organisms.

Substitute: There is no information available indicating the most successful substitutes for tributyltin. Trifluralin (CAS 1528-09-08) Status: Directive 91/414/EEC prohibits the use of trifluralin as a pesticide after March 2009. Use: Trifluralin is a herbicide used on winter wheat and barley, set-aside (arable land temporarily taken out of cultivation), oil-seed rape, brassicas, carrots, lettuce, sugar beet, and beans. It is also applied to outdoor bulbs and flowers, fodder crops, glasshouse crops, Christmas trees, herbaceous plants, soft fruit and vegetables. In 2003, Trifluralin was used on 609 kg of Swedes/Turnips over 715 ha and 44 kg of Kale/Rape over 40 ha (DAFF, 2003). There are currently 7 approved plant protection products in Ireland containing the active ingredient (PCS, 2007). Effects: It has direct negative effects on aquatic organisms and increases the need to treat drinking water. Substitute: There is no information available indicating the most successful substitute for trifluralin. In 2004, the most commonly used herbicides on arable crops were: sulphuric acid; glyphosate; mecorpop p; isoproturon; diflufenican isoproturon; and metamitron (DAFF, 2004). Possible substitutes may include these substances of other herbicides included in Annex I of Directive 91/414/EEC.

K1.2 OTHER DANGEROUS SUBSTANCES

Aldrin (CAS 309-00-2) Status: The use of aldrin as a pesticide in Ireland was banned in 1988. Use: It was formerly used to kill soil insects such as mites and grasshoppers and to protect corn and potatoes. Effects: It has direct negative effects on aquatic organisms and increases the need to treat drinking water. Substitute: There is no information available indicating the most successful substitute for aldrin. In 2004, the most commonly used insecticides on arable crops were: dimethoate; chlorpyrifos; cypermethrin; oxydemeton-methyl; and carbofuran (DAFF, 2004). Possible substitutes may include these substances or other insecticides included in Annex I of Directive 91/414/EEC. Dieldrin (CAS 60-57-1) Status: The use of dieldrin as a pesticide has been banned in Ireland since 1981. Use: It was an insecticide used principally to control textile pests and insects living in the soil. Effects: It has direct negative effects on aquatic organisms and increases the need to treat drinking water. Substitute: There is no information available indicating the most successful substitute for dieldrin. In 2004, the most commonly used insecticides on arable crops were: dimethoate; chlorpyrifos; cypermethrin; oxydemeton-methyl; and carbofuran (DAFF, 2004). Possible substitutes may include these substances or other insecticides included in Annex I of Directive 91/414/EEC. Endrin (CAS 72-20-8) Status: The use of endrin as a pesticide has been prohibited in Ireland since 1981. Use: Endrin is a cyclodiene insecticide used on maize. It also kills birds. As a rodenticide, it is used to control mice and voles. Effects: It does not dissolve very well in water. It tends to bind to sediment and can easily accumulate in animal tissue. Substitute: There is no information available indicating the most successful substitute for dieldrin. In 2004, the most commonly used insecticides on arable crops

were: dimethoate; chlorpyrifos; cypermethrin; oxydemeton-methyl; and carbofuran (DAFF, 2004). Possible substitutes may include these substances or other insecticides included in Annex I of Directive 91/414/EEC. Isodrin (CAS 465-73-6) Status: Isodrin is no longer produced or used commercially. It is not registered as being used as a pesticide with the Pesticide Control Service. It has been designated the obsolete/discontinued status by the World Health Organisation (World Health Organisation (1999) The WHO Recommended Classification of Pesticides by Hazard and Guidelines to Classification 1998-1999). Use: Isodrin is an insecticide. Effects: If released to water, isodrin may concentrate in aquatic organisms and adsorb to suspended solids and sediments. Substitute: There is no information available indicating the most successful substitute for isodrin. In 2004, the most commonly used insecticides on arable crops were: dimethoate; chlorpyrifos; cypermethrin; oxydemeton-methyl; and carbofuran (DAFF, 2004). Possible substitutes may include these substances or other insecticides included in Annex I of Directive 91/414/EEC. Par-par DDT (CAS 50-29-3) Status: The use of para-para DDT as an insecticide was banned in Ireland in 1985. Use: Para-para DDT was used as an insecticide. Effects: The concentration of Para-para DDT grows as you move higher in the food chain in aquatic environments. It is persistent and carcinogenic. Substitute: There is no information available indicating the most successful substitute for para-para ddt. In 2004, the most commonly used insecticides on arable crops were: dimethoate; chlorpyrifos; cypermethrin; oxydemeton-methyl; and carbofuran (DAFF, 2004). Possible substitutes may include these substances or other insecticides included in Annex I of Directive 91/414/EEC.

K1.3 RELEVANT SPECIFIC POLLUTANTS

Dimethoate (CAS 60-51-5) Status: The use of dimethoate as an insecticide is permitted under Directive 91/414/EEC. Use: Dimethoate is a widely used organophosphorus (OP) insecticide applied to kill mites and insects systemically and on contact. It is mostly used against aphids on wheat. Dimethoate is used against a broad range of insects such as thrips, aphids, mites, and whiteflies, and on a number of crops including fruit, potatoes, and vegetables. It is also permitted for the control of the flies in livestock accommodation, home gardens and food storage. In 2003, dimethoate was the most commonly used insecticide used on arable silage, 458 kg applied to 2,009 ha (DAFF, 2003). In 2004, it was the most commonly used insecticide used on arable crops. In total 17,592 kg was applied to 77,853 ha of arable crops of all varieties (DAFF, 2004). There are currently 9 approved plant protection products in Ireland containing the active ingredient (PCS, 2007). Effects: Dimethoate does not persist in the environment, although it can cause health effects on humans and other organisms. Substitute: There is no information available indicating the most successful substitute for dimethoate. In 2004, excluding dimethoate, the most commonly used insecticides on arable crops were: chlorpyrifos; cypermethrin, oxydemeton-methyl; and carbofuran (DAFF, 2004). Possible substitutes may include these substances or other insecticides included in Annex I of Directive 91/414/EEC.

Glyphosate (CAS 1071-83-6) Status: The use of glyphosate as a pesticide is permitted under Directive 91/414/EEC. Use: In Ireland it is widely used to kill weeds, especially perennials. It is the primary herbicide of the forestry sector. In 2003 glyphosate was one of the most extensively used herbicides. In 2003, 85,515 kg of glyphosate was applied to 61,132 ha of all types of grassland and fodder crops. A further 7540 kg was used in combinations as spot treatments (DAFF, 2003). In 2004, 11,4664 kg of glyphosate was applied to 141,011 ha of arable crops. It was the second most commonly applied herbicide (per weight applied), sulphuric acid being the most commonly applied (DAFF, 2004). There are currently 66 approved plant protection products in Ireland containing the active ingredient (PCS, 2007). Effects: Glyphosate rapidly binds to sediment and the toxicity of glyphosate to mammals and birds is generally relatively low. Substitute: There is no information available indicating the most successful substitute for glyphosate. In 2004, excluding glyphosate, the most commonly used herbicides on arable crops were: sulphuric acid; mecoprop p; isoproturon; diflufenican isoproturon; and metamitron (DAFF, 2004). Possible substitutes may include these substances or other herbicides included in Annex I of Directive 91/414/EEC. Mancozeb (CAS 8018-01-7) Status: Mancozeb is a fungicide permitted under Directive 91/414/EEC. Use: Mancozeb is used in agriculture, professional turf management, and horticulture. It is used to protect many fruit, vegetable, nut and field crops against a wide spectrum of fungal diseases, including potato blight, leaf spot, scab (on apples and pears), and rust (on roses). In 2003, 508 kg was applied to 317 ha of swedes and turnips (DAAF, 2003). In 2004 Mancozeb accounted for the greatest quantity of fungicide applied to potatoes. In total 157,295kg of mancozeb was applied to arable crops and overall it was the second most commonly applied fungicide (per weight), chlorothalonil being the most commonly applied (DAFF, 2004). There are currently 25 approved plant protection products in Ireland containing the active ingredient (PCS, 2007). Effects: Mancozeb is moderately to highly toxic to fish and aquatic organisms. It binds to the soil and has carcinogenic by-products. Substitute: There is no information available indicating the most successful substitute for mancozeb. In 2004, excluding mancozeb, the most commonly used fungicides on arable crops were: chlorothalonil; fenpropimorph; cymoxanil mancozeb; and azoxystrobin (DAFF, 2004). Possible substitutes may include these substances or other fungicides included in Annex I of Directive 91/414/EEC. Mecoprop (CAS 7085-19-0) Status: The use of mecoprop is permitted under Directive 91/414/EEC. Use: It is a herbicide used on ornamentals and sports turf, in forest site preparation, and on drainage ditch banks for selective control of surface creeping broadleaf weeds such as clovers, chickweed, ivy, plantain and others. It is also used on wheat, barley, and oats. In 2003 8,572 kg was applied to 5,227 ha of grass and 1,328 kg was applied to 744 ha of arable silage. A further 11,861kg was used in spot treatments. It is one of the most commonly used herbicides on grassland and fodder crops (DAFF, 2003). In 2004 Mecoprop was used on Spring barley (7,759 over 10,863 ha), Spring wheat (1,044 kg over 1,603 ha) and Linseed (97 kg over 330 ha) (DAFF, 2004). There are currently 9 approved plant protection products in Ireland containing the active ingredient (PCS, 2007). Effects: It is virtually non-toxic to fish and has a low tendency to bio-accumulate. Substitute: There is no information available indicating the most successful substitute for mecoprop. In 2004, excluding mecoprop, the most commonly used

herbicides on arable crops were: sulphuric acid; glyphosate; isoproturon; diflufenican isoproturon; and metamitron. Possible substitutes may include these substances or other herbicides included in Annex I of Directive 91/414/EEC.

Table 1.1 Annex I of Directive 91/414/EEC, i.e. Permitted Substances

List A - Herbicides included in Annex 1 of Directive 91/414/EEC, i.e. permitted use as herbicides

List B - Insecticides included in Annex I of Directive 91/414/EEC. i.e. permitted use as insecticides

List C - Fungicides included in Annex I of Directive 91/414/EEC. i.e. permitted use as fungicides

2,4-D alpha-Cypermethrin (aka alphamethrin)

Ascorbic acid

2,4-DB beta-Cyfluthrin Benalaxyl Amitrole (aminotriazole) Chlorpyrifos Captan Bentazone Chlorpyrifos-methyl Carbendazim (unitl 2009) Bromoxynil Cyfluthrin Chlorothalonil Clodinafop Cypermethrin Cyprodinil Clopyralid Deltamethrin Dimethomorph Chlorpropham Dimethoate Dinocap (until 2009) Clorotoluron Esfenvalerate Fenarimol (until 2008) Desmedipham Etoxazole Folpet Dichlorprop-P Formetanate Fosetyl Diquat (dibromide) Indoxacarb Flusilazole (until 2008) Ethofumesate lambda-Cyhalothrin Imazalil (aka enilconazole) Fluroxypyr Methamidophos (untill 2008) Iprodione Glufosinate ammonium Methiocarb Mancozeb Glyphosate (incl trimesium aka sulfosate)

Methoxyfenozide Maneb

Imazosulfuron Milbemectin Metconazole Ioxynil Oxamyl Metiram Isoproturon Pirimicarb Potassium iodide Linuron Phosmet Potassium thiocynate MCPA Procymidone (until 2008) MCPB Propamocarb Mecoprop Propiconazole Mecoprop-P Propineb Metribuzin Pyrimethanil Metsulfuron Thiabendazole Molinate Thiofanate-methyl Paraquat Thiram Pendimethalin Tolclofos-methyl Phenmedipham Tolyfluanid Propyzamide Triticonazole Pyridate Ziram Rimsulfuron S-metolachlor Tepraloxidim Tetraloxydim Thifensulfuron (aka thiameturon)

Triasulfuron Tribenuron Triclopyr

ERM has over 100 offices across the following countries worldwide Argentina Malaysia Australia Mexico Belgium The Netherlands Brazil New Zealand Canada Peru Chile Poland China Portugal Colombia Puerto Rico Ecuador Russia France Singapore Germany South Africa Hong Kong Spain Hungary Sweden India Taiwan Indonesia Thailand Ireland UK Italy United Arab Emirates Japan US Kazakhstan Vietnam Korea Venezuela ERM Ireland Suite 508, The Capel Building Marys Abbey, Dublin 7 T: +353 (0) 1 814 7700 F: +353 (0) 1 814 7700 NSC Campus, Loughmahon Technology Park Mahon, Cork T: +353 (0)21 230 9323 F: +353 (0)21 230 9362 www.erm.com

ERM consulting services worldwide www.erm.com

Date post:	21-Aug-2020
Category:	Documents
Upload:	others
View:	0 times
Download:	0 times