Western Brand, EPA records on LEMA and EDEN

Nutrient Management Plan 2023

Western Brand operate under IED licence from the Agency at Ballyhaunis, County
Mayo under Ref: P0831-02.

For the period 1 January 2023 to date, I wish to request all records on the EPA
LEMA and EDEN systems in respect of Licence P0831-02

Nutrient Management Plan 2023

Western Brand expect to generate the following quantities of organic wastes during 2023:

4,500MT of WWTP Sludge

Waste Council Directive 86/278/EEC on the protection of soil, when sewage sludge is used in agriculture

Reporting frequency: Annually

First report due: 31/08/2023

86/278/EEC 86/278/EEC Report on the use of sludge in agriculture: the quantities used, the criteria followed and any difficulties encountered 

Proposals for Reporting on the use of sludge

1) Names and addresses of the recipients of the sludge

2) Place where the sludge is to be used

3) Agricultural facilities receiving sludge

Note: dataset may include personal data and require secure data exchange

Reported Member State / Country Dataset

https://rod.eionet.europa.eu/instruments/514 Questionnaire on the implementation of Sewage sludge directive        

Reporting is based on questionnaire: https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:31994D0741

Initial Feedback from Member States:

Data is reported in a descriptive form (report)

Maybe Directive is under revision

We don’t have data

How is the data identified?  

Very difficult to find the data in the NL

How is the geodata reported?  

AF – Agricultural and aquaculture facilities     

Sewage Sludge and Biosolids

The treatment of the wastewater generated in greater Dublin by homes, schools, businesses and industry produces wastewater sludge.

Wastewater sludge is made up mainly of organic matter that has been removed from the wastewater during the treatment process. Further treatment of this sludge is required to enable its safe and efficient re‐use or disposal.

The further processing of the sludge results in ‘biosolids’. Biosolids are a biologically stable product free of harmful pathogens (viruses, bacteria etc.) and containing high levels of plant nutrients (nitrogen, phosphorus etc.). The treatment of sludge happens at the wastewater treatment plant.

Biosolids are then transported to a biosolids storage facility prior to being outputted for use in agriculture and forestry.

Most of the biosolids produced in Ireland (98%) are currently reused on agricultural lands as a soil conditioner and as a replacement for chemical fertilisers.

The use of biosolids on agriculture lands is strictly regulated under European and National law.

One of the conditions of use is a strict prohibition on spreading biosolids on land over the winter period (October to January).

This restriction means that biosolids reused in agriculture need to be stored for certain periods over each calendar year.

Note from 5th Nitrates Action Plan on Sewage/Industrial Sludges


The use of sewage sludge is managed by Irish Water through its National Wastewater Sludge Management Plan.

The application of sewage sludge to agricultural land is controlled by local authorities through the maintenance of sludge registers and inspection/enforcement programmes.

The EPA regulates industries (including dairy processing and animal slaughtering) that generate industrial sludges through IED licences.

The application of industrial sludges as an organic fertiliser to agricultural land is controlled under the Good Agricultural Practice regulations.

However currently there is not an integrated approach or data system available that identifies the loads and spreadlands where sludges are applied.

A comprehensive understanding of the movement of sludges and the application of sludges to agricultural land is required to ensure the existing controls are fit for purpose.


A review of the management and oversight of sludges being applied to land will be carried out by a working group established under the National Technical Implementation Group (NTIG), which is part of the River Basin Management Planning and Water Framework Directive governance structures.

Recommendations arising will be brought back to the WFD governance structures for consideration.

Sewage/Industrial Sludges

The use of sewage sludge is managed by Irish Water through its National Wastewater Sludge Management Plan.

The application of sewage sludge to agricultural land is controlled by local authorities through the maintenance of sludge registers and inspection/enforcement programmes.

The EPA regulates industries (including dairy processing and animal slaughtering) that generate industrial sludges through IED licences.

The application of industrial sludges as an organic fertiliser to agricultural land is controlled under the Good Agricultural Practice regulations.

However currently there is not an integrated approach or data system available that identifies the loads and spreadlands where sludges are applied. A comprehensive understanding of the movement of sludges and the application of sludges to agricultural land is required to ensure the existing controls are fit for purpose.


A review of the management and oversight of sludges being applied to land will be carried out by a working group established under the National Technical Implementation Group (NTIG), which is part of the River Basin Management Planning and Water Framework Directive governance structures.

Recommendations arising will be brought back to the WFD governance structures for consideration.

Regional Biosolids Storage Facility: EIA Report

Volume 4 – Regional Biosolids Storage Facility

Part A: Report

Part B: Appendices

Part B: Regional Biosolids Storage Facility

Ringsend Wastewater Treatment Plant Upgrade Project – Environmental Impact Assessment Report

Volume 4 – Regional Biosolids Storage Facility
Part A: Report (June 2018)

Sewage sludge: EU Regulation

EU rules promote the use of sewage sludge in agriculture, but regulate its use to prevent harmful effects on soil, vegetation, animals and people.

Sewage sludge

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:31986L0278

Sewage sludge is a mud-like residue resulting from wastewater treatment. Sewage sludge contains heavy metals and pathogens such as viruses and bacteria.

It also contains valuable organic matter and nutrients such as nitrogen and phosphorus, and can therefore be very useful as a fertilizer or soil improver.

The quantity of sewage sludge requiring disposal in the EU is increasing, mainly due to the progressive implementation of the Directive on the treatment of urban wastewater.

EU rules on sewage sludge consider the nutrient needs of plants and ensure that the quality of soil, the surface and ground water is not impaired. It covers

  • how farmers can use sewage sludge as a fertiliser
  • the sampling and analysis of sludge and soils
  • keeping detailed records for sludge quantities produced and used in agriculture
  • the type of treatment and sites where sludge is used
  • sludge composition and properties

Normally, sludge must be treated to reduce its fermentability and the health risks resulting from its use. In some EU countries, untreated sludge can be used in farming if it is injected or worked into the soil. In certain cases, sludge cannot be used at all. This includes

  • on soil in which fruit and vegetable crops are grown, except for fruit trees
  • on grassland or forage land that will be grazed by animals or harvested in the next three weeks

less than ten months before fruit and vegetable crops are to be harvested, when the crops are in direct contact with the soil and eaten raw

The aims of the Sewage Sludge Directive are 

  • to protect humans, animals, plants and the environment by ensuring that heavy metals in soil and sludge do not exceed set limits
  • to increase the amount of sewage sludge used in agriculture

The Directive also

  • sets limits for the concentration of seven heavy metals in sewage sludge intended for agricultural use and in sludge-treated soils (cadmium, copper, nickel, lead, zinc, mercury, chromium)
  • bans the use of sewage sludge that results in concentrations of these heavy metals in soil exceeding these limit values

EU countries must send reports on the implementation of the Sewage Sludge Directive to the European Commission every three years.

Note: requested previous Irish reports to Commission on Sewage Sludge Directive from

ENV-WASTE-SEWAGE-SLUDGE-DIRECTIVE@ec.europa.eu

Legislation for the Reuse of Biosolids on Agricultural Land in Europe: Overview

The issues concerning the management of sewage sludge produced in wastewater treatment plants are becoming more important in Europe due to:

(i) the modification of sludge quality (biological and chemical sludge are often mixed with negative impacts on sludge management, especially for land application);

(ii) the evolution of legislation (landfill disposal is banned in many European countries); and

(iii) the technologies for energy and material recovery from sludge not being fully applied in all European Member States.

Furthermore, Directive 2018/851/EC introduced the waste hierarchy that involved a new strategy with the prevention in waste production and the minimization of landfill disposal.

In this context, biological sewage sludge can be treated in order to produce more stabilized residues: the biosolids. In some European countries, the reuse of biosolids as soil improver/fertilizer in arable crops represents the most used option.

In order to control the quality of biosolids used for land application, every Member State has issued a national regulation based on
the European directive.

The aim of this work is to compare the dierent approaches provided by European Member States for the reuse of biosolids in agricultural soils.

A focus on the regulation of countries that reuse significant amount of biosolids for land application was performed.

Finally, a detailed study on Italian legislation both at national and regional levels is reported.

Land Application of Biosolids in Europe: Possibilities, Constraints and Future Perspectives

The agricultural use of good quality sludge represents a value-added route to ensure growth sustainability in Europe, where raw material availability, for example, for phosphorus, is insufficient to meet demand.

However, the possible presence of pathogens, pharmaceuticals and heavy metals requires specific regulations to minimize sludge-related health issues and environmental risks.

The current regulation on sludge agricultural use applied by many EU countries is here presented and compared, highlighting scarce harmonization of the legislative framework among Member States.


Actual issues, such as the fate of emerging micropollutants and microplastics in sludge-amended soils, and public health concerns regarding sludge spreading during the COVID-19 epidemic, are considered, too.

Sewage/Industrial Sludges


The use of sewage sludge is managed by Irish Water through its National Wastewater Sludge Management Plan.

The application of sewage sludge to agricultural land is controlled by local authorities through the maintenance of sludge registers and inspection/enforcement programmes.


The control of other industrial sludges (including sludge from dairy processing industry) is managed, where applicable, through IPC licences granted by the EPA.

A comprehensive understanding of the movement of sludges and the application of sludges to agricultural land is required to ensure the existing controls are fit for purpose.

During the NAP review, the Nitrates Expert Group will be working with the various stakeholders to adequately address the risk from this ever-increasing nutrient source.

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