Request for access to information held by Clare County Council relating to the Wastewater Treatment Plant / discharge licence at Cliffs of Moher Visitor Experience
The influent results for October 4th showed that the Incoming wastewater was not in compliance with the plant design specification for BOD, Suspended Solids, Ammonia and Total Phosphorus which was in excess of design criteria.
The final effluent results from the 4th of October show that Total Phosphorus was not in compliance as per contract conditions.
The influent results for January 3rd showed that the Incoming wastewater was not in compliance with the plant design specification for BOD, Suspended Solids, Ammonia and Total Phosphorus which was in excess of design criteria.
The final effluent results from the 3 rd of January show that Total Phosphorus was not in compliance as per contract conditions.
The influent results for January 31st showed that the Incoming wastewater was not in compliance with the plant design specification for BOD, Suspended Solids and Total Phosphorus which was in excess of design criteria.
The final effluent results from the 31 st of January show that Total Phosphorus was not in compliance as per contract conditions.
The influent results for March 1 st showed that the Incoming wastewater was not in compliance with the plant design specification for BOD, Suspended Solids and Total Phosphorus which was in excess of design criteria.
The final effluent results from the 1 st of March show that Total Phosphorus was not in compliance as per contract conditions.
The influent results for April 12th showed that the Incoming wastewater was not in compliance with the plant design specification for BOD, Ammonia and Total Phosphorus which was in excess of design criteria.
The final effluent results from the 12 th of April show that Total Phosphorus and Ammonia was not in compliance as per contract conditions.
The influent results for May 25th showed that the Incoming wastewater was not in compliance with the plant design specification for BOD, Suspended Solids, Ammonia and Total Phosphorus which was in excess of design criteria.
The final effluent results from the 25 th of April show that Total Phosphorus and Ammonia was not in compliance as per contract condition
Standards for several parameters are set under Condition 2.3 of your discharge licence W 294/94R1. The results show non-compliances with the conditions of your licence.
Glan Agua have taken the time to review this for Kylemore quite thoroughly with the attached being their output which suggests Ferric can be used and should result in a vast improvement in the levels of Phosphorous being measured from the outlet of the system. The proposal to also redirect existing septic tanks to the system also being beneficial.
The NIS is actually viewable on the planning file 11/1003. I don’t believe we actually carried out an AA as would be done now but the NIS was assessed and the council was satisfied with it’s contents.
Review of Kylemore Abbey Wastewater Treatment Plant Report
Glan Agua
The current Emission Limit Values (ELVs) are as follows; • Biological Oxygen Demand (BOD): 5mg/l • Chemical Oxygen Demand (COD): 25mg/l • Total Suspended Solids (TSS): 10mg/l • Fats, Oils and Greases (FOG): 5mg/l • Total Phosphorous (TP): 2mg/l • Orthophosphate (OrthoP): 1mg/l • Ammonia: 0.2mg/l • Nitrate: 10mg/l • pH: 6-9 pH units
The current treatment process consists in the following: • Multiple septic tanks on the network • Inlet pump station (directly to primary settlement) • 2no. precast primary settlement tanks (36,000 L ea.) directly upstream of the RBCs operating in series at the main plant. • RBC • Final Settlement Tank (FST) • Sludge Return • Phosphorous Reduction • Polishing Lagoons (Reed Beds)
Whilst the current treatment process capacity cannot be accurately evaluated without additional information, it is fairly unlikely to be able to comply with the extremely stringent ELVs currently in place for the following reasons:
• There are numerous septic tanks on the network, which could lead to excessive retention time, septicity issues and ultimately detrimental impact on the process performances. Rationalisation of the network should be considered so that the remaining septic tanks operate within typical design parameters. This can be seen from the particularly low concentrations of solids and low BOD/TSS ratio in the influent, as well as anecdotal evidence (smell in the 2no. precast septic tanks).
• The storm water network looks to be amalgamated with the sewer network allowing introduction of high volumes of rain/storm water into the treatment system.
• BOD/COD/TSS ELVs o The BOD/COD/TSS ELVs are extremely stringent. Typical ELVs for an RBC treatment process based on the current influent sample results would be 25mg/l BOD, 125mg/L COD and 35mg/l TSS.
• OrthoP, TP and residual aluminium ELVs o For the OrthoP and TP ELVs, a chemical removal stage would be required to guarantee the ELVs. Based on the jar tests carried out which have shown the ELVs are readily achievable using chemical phosphorus removal, the system was designed assuming a Fe mole ratio of 3.5mol Fe/mol P. Assuming 29.9d storage, this would mean a coagulant storage tank of around 1000l would be required. 2no. chemical dosing pumps of 10l/h each (based on the estimated peak wastewater flow of 52.7m3/d plus 50% safety factor, i.e., daily peak flow of 79.1m3/d and assumed peak flow of 9.9m3/h) would be required. o Optimisation of the chemical mole ratio through regular sampling and adjustment of the pumps will allow the process to minimise the risk of residual metal carryover. This would be further strengthened if a tertiary filtration stage was also provided as suggested above based on the BOD/COD/TSS ELVs. An iron probe could be provided; however, it should be noted that the licence does not include for an iron limit either. o Due to the scale of the plant, and to the high costs associated with an OrthoP online monitor, the provision of this equipment to control the chemical dosing pumps would not be considered as viable.
• Ammonia and TN o The existing RBCs is unlikely to be able to comply with the extremely stringent current ammonia ELV. With RBCs, the oxygen used for the nitrification reaction is only provided through diffusion from the ambient air to the wastewater when the disc is above the water, and it is therefore difficult to guarantee full nitrification. Available effluent results provided to Glan Agua for 2021 showed that the effluent from the RBCs was nonetheless generally compliant with the ammonia limit. o For the nitrate ELV, a denitrification zone with nitrate recirculation (so that nitrates generated in the aerobic zone can be returned where BOD availability is greater) would be required – the existing process does not have such a zone and the existing ELV therefore cannot be guaranteed. An anoxic zone would need to be provided to guarantee compliance with the ELV. o It should be noted that, due to alkalinity consumption by nitrification and coagulant dosing, alkalinity boosting using NaOH may be required depending on the outcome of the stormwater separation process and operational results when resuming ferric sulphate dosing. ▪ Assuming no denitrification, the max. storage volume required for 27.2d storage would be around 2000l, and 2no. 9.2l/h chemical dosing pumps would be required. ▪ If there was an anoxic zone provided upstream of the aeration stage with internal recirculation of nitrates, the denitrification reaction would allow for some alkalinity recovery and drop the requirement to 1500l (29.3d storage) storage and 6.4l/h chemical dosing. o Finally, it should be noted that the existing polishing lagoons can actually have a detrimental impact on the effluent quality, due to the risk of algae or other organic matter growing in the lagoons, decomposition of vegetation, animal contamination etc. This was not seen for “Kylemore Remote WQ Baseline Data- 01.11.2021” apart from the 19/10/21 sample where the COD concentration at the outlet of the RBC (SW7) was 29mg/l, against 47mg/l at the outlet of the lagoon.
However, it is a risk that should be considered if a larger upgrade of the WwTP besides the provision of chemical dosing was considered
No application form would have been submitted for the review. An application form is only submitted if it’s an application for a new licence. The council issued a notice of review and the licencee submits info based on this. The info submitted by the licencee is what makes up most of volume 2. The NIS is actually viewable on the planning file 11/1003. I don’t believe we actually carried out an AA as would be done now but the NIS was assessed and the council was satisfied with it’s contents.
This is the EPA Form used for the purpose of making an application for a Waste Water Discharge Authorisation under the European Union (Waste Water Discharge) Regulations 2007 to 2020, or for the review of an existing Waste Water Discharge authorisation
It’s useful as it outlines what data the EPA collect on waste water discharges
e.g.
is it on the EPA Waste Water Priority List?
is it on the EU infringement list?
where is the primary discharge point?
what is the current plant capacity, and the remaining capacity?
is the plant overloaded?
what is are the additional waste inputs eg domestic septic tanks, industrial waste water, leachate, bypass inputs?
is there an accident prevention procedure / emergency response plan?
are there alarms / telemetry on the plant?
is there groundwater monitoring in place?
what measures are in place to prevent unintended discharges?
is the plant identified as a significant pressure on the receiving waters?
have discharges contributed to a deterioration in the quality of the receiving waters?
is there drinking water abstraction downstream of the plant?
The main pressure in this waterbody is hydromorphology from channelisation, which changing the hydrological and morphological dynamics of the river.
In terms of hydro morphology, there are historic OPW arterial drainage schemes, liaising with the OPW will be required to determine how to restore the waterbodies affected in the Owenriff PAA to their natural habitat. There are also historic land drains leading into the four river waterbodies in the PAA that maybe transporting volumes of sediment to the waterbodies, drain blocking will be required in these cases.
The number of registered domestic waste water treatment systems increased by 0.9% in 2020 to 475,990. There was an increase in every local authority in 2020 with Donegal recording the highest annual increase of 1.2% (see Figure 1 and Table 1).
In 2020 Cork had the highest proportion of domestic waste water treatment systems at 11.4% followed by Galway (8.8%), Kerry (7.1%), Donegal (6.4%), Mayo (6.1%), Tipperary (5.5%) and Wexford (5.3%). These seven counties accounted for 50.6% of all individual waste water treatment systems (see Table A and Figure 2).
Cork accounted for 14.3% of all new registrations in 2020 followed by Donegal at 8.9% (see Table 2).
Household owners accounted for 97.1% of all registered waste water treatment systems in 2020. Public authorities accounted for 1.5% and Other non-domestic owners accounted for the remaining 1.4% (see Table 3). In Longford public authorities accounted for 4.3% of all owners in 2020 whereas in Kildare they only accounted for 0.1%.
Twenty one additional wastewater treatment plants have been selected for upgrade as part of the Small Towns and Villages Growth Programme.
This follows the announcement of 15 projects earlier in 2021.
Additional 21 projects selected
County
Area
Further details:
Carlow
Ballinabrannagh
Upgrade of the Ballinabrannagh WWTP at the existing site to provide additional capacity for growth.
Cavan
Mullagh
Upgrade of the Mullagh WWTP at the existing site to provide additional capacity for growth.
Cork
Ballineen/Enniskean
Upgrade of the Ballineen/Enniskean WWTP at the existing site to provide additional capacity for growth.
Cork
Belgooley
The project will amalgamate and consolidate existing wastewater treatment infrastructure in the Belgooley area into a single WWTP with capacity to cater for the existing development and projected growth.
Cork
Ballinspittle
The project will amalgamate and consolidate existing wastewater treatment infrastructure in the Ballinspittle area with capacity to cater for the existing development and projected growth.
Cork
Castlemagnier
The project will amalgamate and consolidate existing wastewater treatment infrastructure in the Castlemagnier areas with capacity to cater for the existing development and projected growth.
Donegal
Mountcharles
The project will cease discharge in Mountcharles, transferring flows to the Donegal Town network.
Kildare
Timolin
Upgrade of the Timolin WWTP at the existing site to provide additional capacity for growth.
Kilkenny
Bennettsbridge
The project will amalgamate and consolidate existing wastewater treatment infrastructure in the Bennettsbridge area to cater for the existing development and projected growth. Water Supply capacity upgrade will also be provided where necessary.
Limerick
Hospital
Upgrade of the Hospital WWTP at the existing site to provide additional capacity for growth.
Longford
Killashee
The project will amalgamate and consolidate existing wastewater treatment infrastructure in the Killashee areas to cater for the existing development and projected growth.
Louth
Castlebellingham
Upgrade of the Castlebellingham WWTP at the existing site to provide additional capacity for growth.
Mayo
Doogort
Provision of a new WWTP at a new site to provide additional capacity for growth
Monaghan
Oram
Upgrade of the Oram WWTP at the existing site to provide additional capacity for growth.
Roscommon
Lecarrow
Upgrade of the Lecarrow WWTP at the existing site to provide additional capacity for growth.
Sligo
Mullaghmore
Provision of a new WWTP at a new site to provide capacity for growth
Tipperary
Kilsheelan
Upgrade of the Kilsheelan WWTP at the existing site to provide additional capacity for growth.
Tipperary
Lisvarrinane
Upgrade of the Lisvarrinane WWTP at the existing site to provide additional capacity for growth.
Waterford
Lemybrien
Upgrade of the Lemybrien WWTP at the existing site to provide additional capacity for growth. Water Supply capacity upgrade will also be provided where necessary.
Wexford
Wellingtonbridge
Upgrade of capacity for Wellingtonbridge to provide for growth
Wexford
Grahormac (Tagoat)
Upgrade of the Tagoat WWTP to provide additional capacity for growth.
Generally Blue Dot waters tend to be in the upper section of river catchments. For this reason, they are affected by some land use activities more than others. In addition to this Blue Dot waters are more commonly found along the Western seaboard and in mountainous areas e.g. Wicklow and Slieve Bloom Mountains. The dominant land uses in these areas are Forestry, Agriculture and Peat extraction and low density one off housing.
The profile of pressures that impact on our Blue Dots is slightly different to the pressures impacting on our Good Status water bodies. While agriculture is the most significant pressure on our good status waters, forestry is the most significant pressure on our Blue Dot waters. Forestry is a pressure on 51 (40%) of our Blue Dot waters, followed by hydromorphology in 43 (34%) water bodies, agriculture in 35 (28%) water bodies, peat extraction or disturbances in 16 (13%) water bodies and domestic waste-water in 13 (10%).
Activities that impact on our Blue Dot waterbodies in order the number of waters that are affected:
Significant pressures have been identified for waterbodies that are At Risk of not meeting their water quality objectives under the Water Framework Directive. While there are a multitude of pressures in every waterbody, the significant pressures are those pressures which need to be addressed in order to improve water quality. Many of our waterbodies have multiple significant pressures. A robust scientific assessment process has been carried out to determine which pressures are the significant pressures. This has incorporated over 140 datasets, a suite of modelling tools, and local knowledge from field and enforcement staff from the Local Authorities, Inland Fisheries Ireland and EPA. Impacts from domestic waste water include nutrient and organic pollution. This assessment synthesises over a decade of field studies on on-site systems in Ireland across many different soils types and combines factors relating to the efficiency of the septic tank systems with attenuation factors for the hydrogeological flow pathway.
Significant pressures have been identified for waterbodies that are At Risk of not meeting their water quality objectives under the Water Framework Directive. While there are a multitude of pressures in every waterbody, the significant pressures are those pressures which need to be addressed in order to improve water quality. Many of our waterbodies have multiple significant pressures. A robust scientific assessment process has been carried out to determine which pressures are the significant pressures. This has incorporated over 140 datasets, a suite of modelling tools, and local knowledge from field and enforcement staff from the Local Authorities, Inland Fisheries Ireland and EPA. Impacts from domestic waste water include nutrient and organic pollution. This assessment synthesises over a decade of field studies on on-site systems in Ireland across many different soil types and combines factors relating to the efficiency of the septic tank systems with attenuation factors for the hydrogeological flow pathway.
