Glanbia, Belview

Sanitary and process effluent lines are combined within the site and discharge through one discharge point SE2 (264630E, 113104N) to sewer. Stormwater is discharged from the stormwater/firewater retention pond to the 450mm IDA storm drain at SW1 which runs to the Gorteens Stream and then to the River Suir at a maximum rate of 37.5 Us. There are no discharges to groundwater.

https://www.agriland.ie/farming-news/1000l-of-milk-overflows-from-silo-at-glanbia-plant/

A raw milk silo overflowed on 22/7/2021 and milk entered the stormwater drains and stormwater retention pond. This was notified to the Agency at the time (Ref INCI021390). During the site visit the stormwater retention pond was empty following cleaning after the incident. A pipe was observed entering the pond downgradient of SW2. Licence condition 6.4.13 requires that no stormwater be discharged to the pond downgradient of SW2.

The impermeable hardstand beneath the sludge storage area is not sufficiently extensive areally to capture all potential run-off from this area for diversion to the onsite wastewater treatment plant. This was raised during the last site visit on 25/10/2019. Additionally a gap in the bund which surrounds the wastewater treatment system was observed during this visit. The licensee indicated that upgrade works to the WWTP are planned in the coming months

Q: site drainage / discharge maps not on EPA website ?

Forestry pressures on the Graney sub catchment

Graney_SC_010 Sub Catchment

Of the eight water bodies in the Graney_010 sub catchment only three have a high status objective and only one is currently meeting its objective. The other two have fallen to good status and are considered to be failing to meet their objective under the River Basin Management Plan.

Blanket peat mainly overlies the sedimentary geology in this catchment. It is these peatlands that help regulate climate, control and purify water flows as well as supporting terrestrial and aquatic biodiversity. However, protection and in some instances, restoration is required to maintain the quality of these services.

The significant pressures in the catchment are forestry and agriculture. This catchment was chosen in consultation with Coillte and the Forest Service as there is likely to be significant forestry activity in the area during the life of the project. This will allow appropriate management strategies for high status areas to be developed.

https://catchments.ie/wp-content/files/subcatchmentassessments/25C_8%20Graney[Shannon]_SC_020%20Subcatchment%20Assessment%20WFD%20Cycle%202.pdf

https://catchments.ie/wp-content/files/areaforactionreports/AFA0024%20Bleach%20and%20Lough%20Graney%20AFA%20Report.pdf

Lyreacrompane Public Water Supply (PWS), Kerry

The Lyreacrompane Public Water Supply (PWS) serves a population of 2,575 and the supply volume is 2,248 m3/day

Managed by Kerry County Council (acting under service level agreement to Irish Water).

The source of the supply is the River Smearlagh. The river has a lot of forestry, wind-farms and bogland in the catchment. Kerry County Council said that the river quality is variable with very high organic loadings at certain times of the year and corresponding very low UVT levels (Ultraviolet transmittance or transmission (UVT) is a water quality measurement that is often used for UV disinfection applications)

The raw water is treated at the plant as follows: pH correction using caustic soda, coagulation using aluminium sulphate and poly, clarification, rapid gravity filtration, chlorination using sodium hypochlorite and final water pH correction using soda ash.

Exceedances of the THM (trihalomethanes)

The EPA will consider adding this supply to the Remedial Action List (RAL) under the category of elevated THMs above the Drinking Water Regulations if there are persistent THM exceedances

The THM formation may be caused by the source, which contains very high dissolved organics, and low flows and long retention times in the network

The sodium hydroxide tank fill point is not locked and the fill point should be enclosed so that any spillages are directed into the bund.

There are no high or low pH alarms for the final water.

EPA audit report

Tender: EPA – Provision of Expert Assistance to Support the Regulation of Drinking Water Treatment Plants

Drinking Water Treatment Plant Inspections: initial contract will be for completion of 20 inspections of drinking water treatment plants and assciated site inspection reports and submission of final project summary report to the EPA by the 1st December 2022

An inspection of a drinking water treatment plant generally involves inspecting some or all aspects of a water supply including but not limited to:
• Source protection;
• Treatment capacity;
• Treatment processes including coagulation, flocculation, clarification, filtration, disinfection (chlorination/UV);
• Assessment of associated technical data and information.
• Review of Alarm Response Procedures.

https://irl.eu-supply.com/app/rfq/rwlproposal_s.asp?PID=211067

Brownfield Lands

Strategic Environmental Assessment (SEA) Environmental Report prepared in support of the
National Planning Framework states:

Ireland has no hazardous waste landfill, and limited capacity in other available infrastructure. Just one landfill has the ability to take and process some contaminated land. This has implications for the levels of contaminated waste generated and whether excess waste would need to be exported.

“Whilst development on brownfield land is broadly positive insofar as it reduces the need for greenfield development which may be an important community/ social assets in such cities, there is potential to encounter contaminated material that could indirectly impact on Biodiversity, Flora and Fauna, Soils and Water through the remediation process. The volume and nature of the contamination will be an important factor to consider given the limited end-of-life solutions for some contaminated material.”

Challenges highlighted by the Ireland Brownfield Network:

• The absence from the Irish planning process of a formal brownfield land assessment and management regime for the majority of brownfield sites. Only sites licensed by the EPA are subject to appropriate assessment and management.
• A complex and lengthy waste licensing and permitting system applicable to the remediation and reuse of contaminated soils and groundwater and construction and demolition (C&D) waste.
• A lack of suitable waste infrastructure for managing contaminated soils and C&D waste and an over-reliance on the export of wastes out of Ireland.
• Limited application of recovery and reuse options for low-level contaminated soils and treated soils, compounded by the complex consenting process and limited application of End-of-Waste status to soils as defined in the Waste Framework Directive 2008/98/EC.

The Northern Ireland Environment Agency (NIEA) has recorded approximately 14,000 brownfield sites (former industrial use)

https://www.daera-ni.gov.uk/publications/historical-landuse

Q: is there a similar ROI map ?

Local authority reporting on brownfield sites:

Cork, commissioned major analysis of sites

https://www.irishexaminer.com/news/munster/arid-40063388.html

Dublin, assessed 82 sites

https://www.irishtimes.com/life-and-style/homes-and-property/housing-crisis-a-brownfield-strategy-for-dublin-1.4150080

AIE: Notes from Regional Waste Management Planning Offices (RWMPOs) meetings with EPA Licensing Section re Closed Landfills CoAs

Notes:

Definition

Definition of a “closed landfill” i.e. a landfill site operated by a local authority for the recovery or disposal of waste without a waste licence on any date between 15th July 1977 and 27th March 1997.

EDEN System

The closed landfills details are not currently on the EDEN system, and are unlikely to be included in the medium term

Financial provision condition
The more recently issued CoAs do not include the requirement for a dedicated financial provision instrument to be put in place. With respect to older CoAs that do contain a condition around financial provision, the OEE will not be looking for a financial provision instrument to be put in place.

Location and use of Groundwater wells
In order to assess the impact of the closed landfill, groundwater wells need to be designed and located appropriately and in accordance with the guidance in the EPA Landfill Monitoring Manual. For example, where a closed landfill is located in a disused sand & gravel quarry, the sand and gravel overburden deposits are likely to be the aquifer at greatest risk of contamination, and monitoring groundwater wells should generally be installed to a depth which samples the overburden, not the underlying bedrock. Site specific circumstances may necessitate wells to sample other aquifers, but the environmental risk assessment should identify the principal receptors. At minimum, there must be three groundwater boreholes, one up-gradient and two down-gradient. As groundwater flows don’t always match ground levels this needs to be taken into account when determining the hydraulic gradient and siting boreholes. The hydraulic gradient can only be properly established by monitoring piezometric levels in established boreholes. The location of any required additional wells need to be agreed with the OEE, prior to installation

Woodland development on closed landfills
OEE are generally in favour of woodland development on closed landfills provide it does not affect the risk assessments findings & recommendations. The principal consideration is whether any development (e.g. woodland, solar farm, built infrastructure) or its associated activities (e.g. digging, drainage, use of heavy equipment) is likely to damage the capping system on a closed landfill, if having a low permeability cap is a key aspect of the remediation strategy.

OEE recommend:
– Looking at the woodland option at as early stage as possible, preferably at the CoA application stage
– Where CoA is already granted any proposal will have to look at the site risk assessment
– Targeting closed landfills where there is a low risk in terms of leachate (i.e. cap unlikely to be required)
– Taking into consideration – types of trees, maintenance required and its impact, public access, risk of fires etc.

OEE also look favourably on proposed use of closed landfill sites for solar farms. Wind turbines are unlikely to be suitable.

Lands held in private ownership
Undertaking remediation works on private property is potentially a sensitive issue, and LAs may face difficulties in agreeing the specific location or details of remediation works with the landowner. To avoid any issues after a CoA has issued, OEE suggested that engagement between the LA and the landowner should take place as soon as possible, and ideally before the CoA issues. OEE have recommended to their Licensing Section that the LA should clarify the relationship with private landowners as part of the CoA application process. The LA should provide evidence that the landowner is aware of and agreeable to the proposed remediation works (no need to provide details of the landowner).

Closed landfill planning requirements & impact on remediation
RWMPOs provided details of the closed landfill planning requirements i.e. need to obtain AA screening and/or planning consent from ABP prior to commencing remediation works. The impacts on the commencement of remediation works were highlighted. RWMPOs agreed to keep OEE updated regarding further developments in relation to the issue.

Communications

The OEE suggested that a generic document/leaflet could be prepared for circulation to adjacent proprieties and/or landowners. The document/leaflet should outline that the site exists, the risk assessments undertaken, authorisation obtained, proposed remediation works and where further information can be obtained. RWMPOs will work with the OEE on suggested wording for document/leaflet

Annual reports (AR)
OEE highlighted that Historic Landfill CoAs do not require the submission of an Annual Environmental Report, which Local Authorities may be familiar with from holding an EPA waste licence. Instead, CoAs require the submission of an annual update, and a condition in the Cert lists specific information that should be provided. Essentially the AR should give a summary of the monitoring data gathered during the relevant period (with an interpretation), the findings of a visual assessment, and a status update on remediation works. Where remediation works have not been completed yet, the annual update should provide an indicative timeframe for the next stage in progressing the works. The annual report should be submitted to the EPA by email to historiclandfills@epa.ie

EPA Audits

OEE are intending to commence on-site audits of authorised closed landfills. LAs will be notified prior to any inspections.

Specific Hydromorphology Issues, eg Morrell_020

HYMO issues

LAWPRO have identified PAAs where chemistry may be within the EQS, but there are issues with the ecology.

An example of this is the Morrell_020.


Specific measures for these types of settings would need to be identified and implemented for these areas if there is to be an improvement in status

Pre AIE question: list of catchments where HYMO is dominant issue, where OPW works are current/in planning stages, or where improvements have been identified

Physical habitat modifications as a result of flood alleviation works are additional significant pressures on Morrell_020, Morrell_030

Combined Storm Overflows

Combined storm overflows are designed to release excess storm water into rivers and seas when a prolonged rainfall occurs.

This helps prevent the risk of sewage backing up, preventing homes and public spaces being flooded by allowing a controlled release.

Storm Water Overflows from sewerage systems are regulated by the EPA’s discharge authorisation regime

Irish Water are required to report on storm water overflow performance to the EPA

Over half (54%) of the combined sewage loading that arises in large urban areas in Ireland is discharged from plants that are not meeting the mandatory European Union standards.

“In practice, many combined sewers are now carrying considerably more load than they were designed for and overflow in relatively minor rainfall events. The overflow of, admittedly dilute, foul sewage to a watercourse has obvious pollution implications

Not much on EPA or IW websites in relation to CSOs

https://www.water.ie/search/?query=Combined+Storm+Overflows