< T. J. O'Conno 0 Con's; king Engineers

Administration,

FacGmile : 2954541 E-mail : tjoc@iol.ie

Environmental Licensing Pr Office of Climate Licensing Environmental Protection A Headquarters, PO Box 3000 Johnstown Castle Estate, Co. Wexford.

For the attention of Dr. Karen Creed

25 August 2008

Dear Sirs,

TULLAMORE WASTEWATER TREATMENT WORKS - DISCHARGE LICENCE - APPLICATION REGISTER NO. D0039-01

We refer to your letter of June 10 to Offaly County Council in connection with the above application and also to a telephone conversation with Mr. Frank Clinton of the EPA on August 21". We have been authorised by Offaly County Council to prepare a response to the letter on their behalf.

In accordance the letter we have prepared the additional information requested as described below. The italics shown below give the text of the Agency's original queryhequest from the letter referred to above while the answers provided are given in normally formatted text.

1.

2.

Provide the name of the agglomeration to which this Wastewater Discharge Licence application relates

TULLAMORE.

Where planning approval has been granted for development(s), but said development has not been commenced or completed to date, within the boundary of the agglomeration and this development is being or is to be served by the waste water works provide the following;

information on the calculated- population equivalent @.e.) to be I contributed to the waste water works as a result of those planning permissions granted,

the percentage of the projected p.e. to be contributed by the non-domestic activities, and

Patrick J.Cawidy. BE, DAL. Eurlng. CEng. FIEI; MCIWEM, MCIArb. RCons.El. Edward FitzGerald, BE. CEng. MIEI. MICE, MCIWEM. RCons.El. Declan Kernan. BE. DipManEng. Eurlng. CEng. MIEI. M C I A ~ . RCons.El.

Michael Moriarty. BE. MEngSc. CEng, MIEI. RCons.El. .. Charles P.OFarrel1, BE. Eurlng, CEng. FIEI. FlSt~ctE. MCIAtb. RCons.El.

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Associate: Diarmuid Cahalane, BE, M E ~ ~ s ~ , C E ~ ~ . MIEN, MCIWEM. I

1 Established 1937

Registered Company TJ O'Connor and Associates Ltd Registered in Ireland No 2'34159

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the ability of the waste water works to accommodate this extra hydraulic and organic loading without posing an environmental risk to the receiving water habitat.

Apartments Houses Retail Tndustrial and other

Tullamore Town Council and Offaly County -Council have granted planning approvals for some 93 residential, commercial and industrial developments within the boundary of the agglomeration which have not yet been completed. The table below provides a summary of these approvals broken down by type and the associated load at the wastewater treatment works expressed as Population Equivalent (P.E) The P.E load is calculated for residential development (houses and apartments) at an average occupancy of 2.9 per unit.

182 528' 667 1,934 22 48

Population I Number I Eauivalent

It is expected that many of the larger approved developments will take place in phases over several years. As noted in sections (9) and (1 0) below, the council has obtained approval to expand the capacity of the wastewater treatment works to 45,000 P.E via an EIS which was certified by An Bord Pleanala in May of 2008. Since then the council has issued tender documents to prospective contractors and expects to award a contract for the expansion of the plant early in 2009. Further details of the works proposed are provided in response to the Agency's questions (9) and (10) below. The expansion of the plant will provide ample treatment capacity to treat discharges arising from the eventual occupancy of the permitted developments noted above. As part of the response to these questions, we have included a copy of the latest approved EIS which demonstrates that the discharge will not have an adverse impact on the aquatic environment.

3. Provide details of any correspondence engaged in with the National Parks and Wildlife Service in relation to a determination as to the likelihood of discharges

ji-om the waste water works having a signficant effect on a European site. If the discharges are deemed likely to have a significant effect an appropriate assessment of the implications for the designated site in view of the sites conservation objectives must be carried out. Any assessment, should it be deemed necessary, shall be submitted aspart of the response to this notice.

NONE.

4. Re-submit Drawing Bl-01 showing only the agglomeration clearly marked in red ink,

Original plus one copy enclosed (at A3) plus digital copy on enclosed CD-ROM.

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5. Complete Section B.2 and B.3 of the application to include labelled monitoring and sampling points associated with the discharge point. These drawings / maps should also be provided as geo-referenced digital drawing Jiles (e.g. ESRI ShapeJle, MapInfo, Tab, AutoCAD or other upon agreement) in Irish National Grid Projection. This data should be provided to the Agency on a separate CD- Rom containing the drawings and tabular data requested in sections B. 1, B.2, B.4, B.5, C.l,D.2,E.3 andF.2

The positions of the monitoring and sampling points (which did not appear on the drawings accompanying the original application) have now been shown on the enclosed drawings in hard copy. Electronic copies of the drawings in AutoCAD format have also been provided on CD-ROM as requested.

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I 6. For the Storm Water Overflows listed in Section B.5 of the application documentation clarifj, the criteria against which the individual overflows were assessed.

All of the available information in relation to the levels of dilution available in the receiving water courses for storm water overflow discharges is provided in attachment D. 1 (iii)(a) of the original application. A description of the overflow structures and of their positions in the agglomeration has been provided in attachment C.2. All of the overflows were constructed prior to the publication of ‘Procedures and Criteria in relation to Storm Water Overflows’ and do not generally conform to the standards described therein either in terms of the standards of constructiodsolids separation or their ability to pass the recommended ‘Formula A’ flow forward. All of the pumping stations are capable of pumping the Formula A flow forward and in some instances are capable of passing several multiples of the formula A value. However levels of dilution in the receiving waters generally exceed the 8: 1 ratio recommended in the ‘Procedures and Criteria’ document referred to above. These deficiencies have been highlighted in a Preliminary Report prepared on behalf of the council in which measures to facilitate the abandonment of many of these overflows were also identified. Funding to facilitate the abandonment of these overflows has been allocated by the Department of Environment, Heritage and Local Government and tender documents for a capital works scheme to address the overflows (and other measures) are currently being prepared by consulting engineers acting on behalf of the council. It is expected that when details of the council’s-proposals for these works become available in the late spring of 2009, these will be forwarded to the Agency to amendheview the terms of the license.

The table below provides a brief summary of the council’s intentions with regard to the abandonment, upgrading or retention of the existing overflows as part of the capital works scheme referred to above. The Agency should note that works to facilitate the abandonment of the Old WwTW and Railway/Kilcruttin Overflows are currently out to tender as part of the upgrading works to the WwTW.

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Accordingly outfalls SW3 aiid SW4 would be cted to cease operation within some 24 months of this letter. The remaining works are to be undertaken as part of a separate contract which is expected to commence in ithe autumn of 2009. Where upgrading works are proposed in the table below! this may taken to infer construction to the standards identified in the ‘ProcedQres and Criteria’ document referred to above.

I

I I Name

Type Discharging Receiving to outfall Water Body Reference Name

Offaly County Council Proposals under upcoming capital works schemes Retention Emergency Overflow Collins Lane P.S t Storm Water Overflow Old WwlW Overflow

s w 2 Tullamore s w 3 . Tullamore Abandonment

I Storm Water Overflow I Charleville View Overflow Tullamore Tullamore Tullamore

Abandonment Abandonment Retention

Storm Water Overflow Railway/Kilcruttin Overflow t Emergency Overflow Town Park Pumping Station I Storm Water Overflow I Marian Place Overflow s w 7 I Tullamore Abandonment

Abandonment* Retention

Storm Water Overflow Water Lane Overflow t Storm Water Overflow Pound Bridqe PS Tullamore

Tullamore I Storm Water Overflow I Bachelor’s Walk SWlO I Tullamore U pg rad ing

Retention Retention

Emergency Overflow Cloncollig PS t IEmerqencv Overflow St. Columba’s Place PS sw11 Tullamore sw12 Tullamore

I Storm Water Overflow I Dainaean Road Overflow SWlO I Tullamore Uoarad ina

* It is proposed to retain a high level relief pipe at this location to allow for drainage of flood water to the combined system which has ponded in this part of the town in the past

7. Reclass& discharge S W l located at inlet works at the Waste Water Treatment Plant (WWTP), Ballydroihid as a Secondary Discharge @om the agglomeration. This discharge does not conform to with the definition of a storm water overflow

- - contained within the Waste Water Authorisation Regulations, 2007. In reclasshing this discharge please provide comprehensive details on the proposed Programme of Improvements to ensure that all waste water is forwarded to the WWTP. Furthermore, provide monitoring data on the discharge and the receiving water environment as per Tables D. 1 (ii) (a), (3) & (c), F. 1 (ii)(a) & (3).

We confirm that discharge SWl has been reclassified as a secondary discharge in accordance with your instructions and that the associated changes to various tables and maps in section B.5 of the application have been made and included on the attached CD ROM. We have also provided the relevant details required in Tables D. 1 and F. 1 where available.

With regard to the programme of improvements, a contract for upgrading of the wastewater treatment works is currently out to tender. As part of the works

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1 proposed in the tender documents, a new inlet pumping station is to be constructed to the Agency in the lifted into the main

discharge) in

with a capacity of not less than 1.75 m3/s. This was original application. Incoming flows up to this rate treatment works so that operation of the overflow times of wet weather will be greatly reduced. This 18 multiples of the calculated (average) dry at the design load of 45,000 P.E. This rate pass flows arising from all but the most extreme storm kvents to the plant and compares with an existing inlet pumping station capacity 04 some 252 l/s (0.252 m3/s). In the WwTW the flow will undergo prelimin treatment before the excess flow (> 3 multiples of the DWF) will be ove ed to a storm water holding tank. This tank will have a capacity of not less than 3,600 m3 and when full will overflow to the works outfall pipe for discharge to the Tullamore River at the existing outfall location. As the works proposed will be undertaken as part of a Design, Build and Operate contract, the council does not currently have construction details for these improvement works. However such details may be expected to be provided to the Agency at a later date as part of an application to amend the terms of the license to reflect the works proposed.

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8. Outline the criteria against which you determined that SW2, SW6, SWl l , SW12 and SW13 are emergency overflows and reclassijj them as secondary discharges. Furthermore, provide monitoring data on the discharge and the receiving water environment as per Tables D. 1 (ii)(a), (b), & (c), F. 1 (ii) (a) & (b).

All of the above outfall references represent discharge locations for overflow pipes from or immediately upstream of pumping stations. In each instance the upstream catchments served by the pumping station are drained by separate sewerage systems in which surface water is drained by aseparated system with its own outfall to a watercourse. The foul sewerage system which drains to the pumping station would therefore generally only carry foul flows. In all foul sewerage systems, some small surface water flows can be present in wet weather which are associated with misconnected - rainwater outlets in private houses/driveways. However these are generally rare and the storm water flows associated with these connections are low relative to the foul flows. It follows that the overflows only operate when the associated pumping stations suffer from mechanical or electrical failure but not in response to incoming flows exceeding the capacity of the pumps. When these pumping stations have to be disabled for maintenance purposes, Offaly County Council, as a matter of course, arrange for tankers to be present to evacuate the contents of the wetwell. Operation of the overflows from the pumping stations generally only occurs in exceptional circumstances. Their description as emergency overflows conforms to the manner in which this term is normally used. However all of the information required for a Storm Water Overflow has been provided in the application for these structures to assist the Agency in considering their significance.

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There are 2 No. pumping statibns overflows on the Tullamore sewerage system which have been classified as storm water overflows in the license application. One of these, the Pound Bridge pumping station, serves part of the town centre which has a combined sewerage system. As the overflow, which discharges to outfall location SW9, can operate in response to wet weather, this overflow has been classified as a storm water overflow in accordance with definition provided by the Agency in the ‘Application Guidance Notes’. The second pumping station is on Daingean Road and its overflow is on the sewerage system immediately upstream of the pumping station. This pumping station does not have the normal 6 x DWF /Formula A capacity and the catchment served contains a significant number of cross connected surface water discharges to the foul system. Offaly County Council has chosen to classify this overflow as a Storm Water Overflow (rather than an emergency overflow) on this basis.

All information available in relation to the emission details of the various overflows has been provided in section D. 1 of the original application.

9. Provide a copy of the most recent planning permission.

A copy of an EIS which was prepared in 2004 and of the terms and conditions of its approval by An Bord Pleanala was provided with the application which was submitted in December 2007 (attachment B.6). This represented the most recent planning approval which had been obtained up to that time. However since the original application was lodged a further EIS has been prepared to provide for expansion of the plant to a capacity of 45,000 P.E. This EIS was approved by An Bord Pleanala in May of 2008. The EIS and the terms and conditions attaching to its approval are enclosed herewith.

IO. Provide Details of the Capital Investment Programme and on the extent and type of work to be undertaken and the likely timefiames for this work to be completed.

Details of the funding allocated by the DoEHLG in the Water Services Capital Investment Programme were provided in the original application (attachment B.lO). In terms of the works to be undertaken, 2 separate capital works contracts are to be undertaken as outlined below.

A contract to provide for upgrading of the wastewater treatment works in Tullamore is currently out to tender. The works proposed in the tender documents for this contract are based on upgrading of the wastewater treatment works to 45,000 P.E. as more fully described in the most recent EIS and its approval as in (9) above. This EIS was copied to the Environmental Protection Agency for commentlobservations regarding the impact of the proposal on the environment, as one of the bodies (statutory consultees) which are required to be sent a copy of the EIS as part of the approval process under the planning and development regulations. The works are to be constructed under a Design, Build and Operate type of contract in which tenderers, selected under the EU restricted procedure,

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I are invited to put forward their o h design tii et a performance specification which is provided in the tender documents. In accordance with the EIS, the contract provides for discharge of part of the treated effluent from the plant to a new outfall on the River Clodiagh some 3 km tdoivlfstream of the works. The decision to split the treated effluent in this manner arose from a limitation placed on the approval of the earlier (2004) EIS which capped the discharge to the Tullamore river at 30,000 PE pending further monitoring of the impact of the discharge in the years following commissioning of the plant. The quality of the treated effluent from the plant, the hydraulic capacity of the various treatment stages, the capacities of the inlet pumping station, stormwater storage tanks etc are also as described in the EIS. The contract also includes for the design, construction and operation of a sludge treatment works but this has no special relevance to the current wastewater discharge license application.

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As described in item (6) above, the works proposed (under the DBO contract) include sewerage works to facilitate the abandonment of two overflows which are located in close proximity to the wastewater treatment plant. The new inlet pumping station (with a capacity of 1.75 m3/s) will also substantially alter the frequency and volumes discharged via the works overflow. As the works are to be undertaken as a Design Build and Operate contract, the layout of the treatment plant which is ultimately to be constructed will only be known when the contractor/ successfbl tenderer has been appointed identified. The completed tenderers are due to be returned at the end of,October of this year and it is expected that the Contractor will be appointed by February with work commencing on site in late March or early April. The time for completion in the tender documents is 78 weeks (approx. 36 months or 1 ‘/2 years). It is expected that when detailed construction drawings of the proposed works become available (after the appointment of the Contractor), Offaly County Council will submit the details to the Agency with a view to having the terms of its discharge license amended to reflect the new situation. However the Agency should note, that as a condition of the appointment of the Contractor, the designs accepted must meet the environmental standards described in the EIS, including final effluent quality, stormwater storage, odour and noise limits etc.

The second contract proposed entails works which are exclusively to the collection system in Tullamore This contract will be for works to the collection system to a design prepared on behalf of Offaly County Council. The works proposed will provide for the abandonment of all of the unsatisfactory stormwater overflows in the agglomeration and upgrading of the remaining overflows to a satisfactory standard, as described in ‘Procedures and Criteria in Relation to Storm Water Overflows’. The works proposed (as they affect stormwater overflows) have already been described in (6) above. The works will also entail the construction of 3 new (foul only) pumping stations to serve separately drained sewerage catchments and it is expected- that these pumping stations will be provided with emergency overflows to protect properties from flooding in the event of mechanical or electrical failure. The-detailed design of these works are

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11.

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currently being -prepared by consulting engineers acting on behalf of Offaly County Council. It is expected that when these design are completed, details of the works proposed will be provided to the Agency as part of an application to amend the terms of the discharge license for the Tullamore agglomeration. In terms of time scales, it is expected that a contractor for the collection-system contract will be appointed by the summer of next year with work progressing over a contract duration of 18 months to 2 years. It is further expected that the contract will provide for sectional completion of parts of the works, with works to unsatisfactory overflows being prioritised and advanced for completion at the earliest possible date.

Complete Section C. 1 of application documentation to provide a description of the plant, process and design capacity for the areas of the waste water works where discharges occur, to include a copy of such plans, drawing or maps, (site plans and location maps, process $‘ow diagrams), and such other particulars reports and supporting documentation as are necessary to describe all aspects of the area of the waste water works discharging to the aquatic environment. Maps and drawings must be no larger than A3 size.

Section C.l of the original application provided a detailed (3 page) description of the design of the existing wastewater treatment plant at Tullamore. Details of the location of the plant are provided in attachment B.8 while a plant layout drawing was provided in attachment C.I. We now enclose a further 38 drawings in hard copy and electronic form of the wastewater treatment works showing the positions and dimensions of the various tanks and buildings on the site. Further details of the existing plant are also provided in section 3 of the 2007 EIS which is enclosed. This section includes aerial photographs, drawings, estimated design loadings, population estimates etc and ground level photographs of the plant as well as a 15 page description of the various stages of -the treatment process. This includes detailed dimensional and process information in relation to the plant design.

Complete Section C.2 of the application documentation to list all dischargesJFom the agglomeration. Update this section to provide information on all present and proposed discharges, to include reference design criteria and location for each current and proposed discharge point.

Further information in relation to the diameter and construction of the outfall pipes has been provided below where available.

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Outfall Reference

Name/Description Diameter Material

(mm) I SW1 I Treatment works Primarv and secondarv I 1.800 I Concrete

All other information available in relation to the outfall design and construction was provided to the Agency in the original application in section C.2 and elsewhere. Details in relation to proposed new overflow discharge locations have been described above (insofar as they are known) and also in the Environmental Impact Statement which has been enclosed with the response. However the Agency should note (as described above) that much of the work proposed actually provides for the abando-nment of existing outfalls rather than the construction of new outfalls. Detailed construction details of new outfalls (where these are proposed) and of their precise location are not currently available pending completion of the detailed designs for the various contracts described in section 10 above. As described above it is the council’s intention to forward these drawings to the Agency when available, as part of an application to amend the terms of the license.

13. Clarifi if SW9 is a storm water- overflow as per section B.5 or an emergency overflow as per Table D. 2

As described in section 8, the pumping station overflow which discharges to the Tullamore River at location- SW9 has been classified a storm water overflow. The basis for this classification is the combined nature of sewerage system which drains to the pumping station and the fact that the overflow from the pumping station can operate in response to wet weather.

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14. Complete table D. 1 (i)(b) to provide information on temperature and fully complete Tables D. 1 (iii) (a), (b) & (c) for a1 discharges.

Offaly County Council commissioned the sampling and analysis of treated effluent from the plant to provide information on the expansive list of chemical parameters required by the Agency in the discharge license application. This sampling took place over a three week period in November 2007. Temperature was not measured as part of the analyses of these samples as the analyses were undertaken at a laboratory several hours after sampling. However Offaly County Council undertakes routine sampling of the final effluent from the plant in Tullamore and this has included temperature measurements. The average of a number of such measurements from samples taken in 2004 and 2005 was 14.4 'C. However maximum daily averages ranged up to 22 'C. In general, the final effluent temperature will be the ambient water temperature as the wastewater treatment processes do not involve raising or lowering of water temperatures.

We have re-compiled table D. 1 (i)(b) with this information. We have also amended the discharge characteristics with regard to BOD, Suspended solids, ammonia, total phosphorus and Orthophosphate to reflect the discharge standards and the current load to the plant of around 24,000 PE. The Council's intentions with regard to the application for the primary discharge (for the existing plant) is to achieve compliance with the Urban Wastewater Treatment Regulations. Under the terms of this legislation there are no maximum daily average values. The regulations are instead predicated on a maximum number of permitted failures of samples of treated effluent to achieve defined upper limit values for a small number of parameters. It follows that a certain number of exceedances of the upper limit values are permitted and that (in theory) there is no maximum set on the concentration of the parameters listed in the regulations (BOD, COD, Suspended Solids and Phosphorus only in the case of Tullamore). Table D.l(i)(b) should be interpreted in this context. We would also note that the Council will propose to amend the discharge limits in line with the approved EIS as per (9) and (1 0) above.

In accordance with the application form (page 15 of 24) only tables D.l(iii)(a) need be completed for Storm Water Overflows as per the original application. No pro-formas have been provided in the application form for D. 1 (iii)(b) or (c).

15. Provide particulars of the source, location, nature, composition, quantity, level and rate of discharges arising Jiom the agglomeration and, where relevant, the period or periods during which such emissions are made or are to be made.

We enclose an A3 drawing in-hard copy and electronic format showing the positions of the existing storm overflow structures and pumping stations in the Tullamore agglomeration. Descriptions of these structures have already been provided in section C.2 of the original application. All of the information available

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I1 to the council in relation to the rate of discharge, the period of discharge and the composition of the discharges from these overflows has been provided to the Agency. As noted in (6), (7), (9) and (10) above the council is in the process of appointing contractors to undertake capital works which will see most of these overflows abandoned. The council expects to provide further details to the Agency when the drawings/ plans for these works are more advanced. Two of these overflows are scheduled for abandonment as part of the works proposed to expand the wastewater treatment works which are currently out to tender.

16. Fully Complete Section E ofthe application

We have included additional information in relation to the reclassification of the treatment works overflow as a secondary discharge.

In relation to the information required in section E.2, Offaly County Council undertakes routine monitoring of the receiving waters downstream of the agglomeration on a bi-monthly basis at the sampling points shown and elsewhere. The sampling points used have been shown on a drawing E201. The sampling, analytical and quality control measures implemented by the Council comply with all relevant guidelines and standards for the tests which are undertaken and are subject to audit testing in accordance with these standards.

Otherwise, insofar as the council are aware, all of the information required in section E has been provided where it has been available.

I 7. Complete Tables F. I (i) (a) and F. I (i) (3) to provide information on temperature.

No information in relation to temperature is available.

18. Confirm that you have corresponded with the relevant downstream local authorities to confirm that there are no surface or groundwater drinking water abstractions (local authority or group water scheme) impacted by discharges @om the works.

As noted in the original application, the Banagher water supply scheme is sourced from surface water (River Shannon) downstream of the works. This scheme is operated by -Offaly County Council (the applicant). The Nenagh water supply scheme is sourced from Lough Derg on the River Shannon. North Tipperary County Council were sent a copy of the EIS proposing expansion of the plant as part of the approval process and were (thereby) afforded -an opportunity to comment on the possible impact of the discharge on their abstraction. Insofar as Offaly County Council are aware, North Tipperary County Council did not submit any observations to An Bord Pleanhla as part of the approval process and it may be presumed that North Tipperary County Council recognised the improvements in water quality proposed and are satisfied that this will (if anything) have a beneficial impact on their abstraction. Given the distances and

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the vast volumes of storage in Lough Derg; the council are satisfied that the drinking water sources will not be adversely impacted by the discharge.

19. In circumstances where water abstraction points exist downstream of any

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discharge describe measures to be undertaken to ensure that discharges @om the waste water works will not have a signficant effect on faecal coliform, salmonella and protozoan pathogen numbers, e.g., Cryptosporidium and Giardia in the receiving water environment.

In the first instance the council notes that the treatment provided at the Tullamore wastewater treatment plant greatly reduces- the numbers of bacteria, including pathogens, present in the final effluent from the numbers present in the incoming raw sewage. The plant therefore has a wholly beneficial impact in this regard. The standards of treatment provided at any water treatment plants sourced from a surface water abstraction (whether upstream or downstream of a sewage treatment works) must have regard to the possible/probable presence of pathogens in the raw water. The standards of treatment provided -for such schemes invariably include disinfection and filtration- stages which are highly effective in meeting Irish drinking water standards in respect of bacteriological water quality. For the particular case of water abstractions in the Shannon basin, the abstractions would have regard to discharges from the other sources of wastewater such as the towns of Athlone, Carrick-on-Shannon, Roosky, etc as well as animal slurries and the many other natural sources of bacteria in the environment.

Provide a statement as to whether or not emissions of main polluting substances (as defined in the dangerous substances regulations S.I. No. 12 of 2001) to water are likely to impair the environment.

The Council are satisfied that the discharge from the Tullamore plant will not impair the environment and would refer the Agency to the approved EIS for any further details required in this respect.

Complete section G.

G.l Compliance with Council Directives

Offaly County Council has prepared an Environmental Impact Statement which addresses all of the issues associated with compliance with relevant directives in detail. A copy of this EIS is enclosed with this letter. The Agency is referred to section 5.2 (pages 70 to 78) in this regard as well as attachment B.6 in the original application. Copies of final effluent sampling results are also provided in the EIS. It is noted that the existing plant performance has generally conformed to the standards of the wastewater treatment regulations but that the overloading which has occurred in recent years has begun to adversely impact on the treated effluent standard which has been achieved. As has been previously- noted, the council proposes to expand the capacity of the plant to provide the additional capacity

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required for many years to come (45,000 P;E.). The programme for these improvement works is as previously noted in (9) and (10) above while details of the funding available under the water services investment programme have been provided in attachment B. 10 of the application.

The council would also note that it operates a trade discharge licensing system as part of which all discharges of trade effluent to public sewers have to be licensed. Applicants for such licenses -are required to provide details of the discharge including details of substances relevant to the regulations noted in G.l. Licenses are only issued where the council is satisfied that the discharge can be safely treated at the wastewater treatment works and where the composition of the effluent would not adversely impact on the aquatic environment after treatment.

G.2 Compliance with Water Quality Standards for Phosphorus Regulations (S.I. No. 258 of 1998)

A detailed analysis of the impact of the discharge from the Tullamore wastewater treatment works with regard to Phosphorus is provided in the EIS referred to above. The Agency is referred to page 66 to 78 of the EIS in this regard.

As noted in the EIS, the existing wastewater treatment works at Tullamore provides for phosphorus removal to a 2 mg/l standard and this has greatly reduced the total phosphorus load to the receiving waters since it was first introduced in 1998. As further noted in the EIS, Phosphorus enrichment of the Tullamore River has been associated with agricultural practises as evidenced by high orthophosphate and MRP readings at river sampling stations upstream of Tullamore. It follows that phosphorus removal at the WwTW cannot (in isolation) ensure compliance with the phosphorus regulations. Agricultural bye-laws regulating the application of artificial fertilisers and animal slurries via mandatory nutrient management planning are already in force in parts of Tullamore river catchment to address this issue. The regulated areas were identified from the Lough Derg and Lough Ree catchment management study which highlighted the phosphorus enrichment problem affecting the upper reaches of the Tullamore River. However the council proposes to further reduce the phosphorus load from the expanded WwTW by adopting a 0.5 mg/l standard for the-expansion of the plant. This standard has been approved by An Bord Pleanala in its certification of the EIS and has been included in the tender documents for the upgrading works described in (9) and (10) above. A detailed analysis of phosphorus levels in the receiving waters as well as calculations supporting the 0.5 mg/l standard proposed from the expanded plant are given in the EIS

G.3 Impact Mitigation _ .

The proposed effluent discharge standards as certified by An Bord Pleanala in their approval of the recent EIS, has been assessed for potential impact on the chemical and ecological status of the receiving waters. The council engaged

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specialist ecological consultants to advise on the standard of effluent from the plant consistent with the need to maintain and improve the- ecological status of the receiving waters. The standard of treated effluent proposed is consistent with this objective and mitigates against negative ecological impacts even under extreme low flow conditions in the river. The 95'h percentile river flows was determined and used in this respect. The Agency is again referred to the EIS for further details of the assessments which were undertaken.

G.4 Storm Water Overflow The design of improvement works to the storm water overflows in the Tullamore agglomeration is currently being prepared. These works are expected to take place as part of two separate construction contracts as previously noted. As shown in the table below (reproduced from section (6) above) the improvement works will provide for the abandonment of many of the existing overflows and upgrading of those remaining to a satisfactory standards in accordance with regulation 3 of the authorisation regulations.

The likely time scales for the improvement works are as previously noted in (6) and (1 0)above.

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We have amended the non technical summary to advise of the approval of the EIS and of the council's intentions with regard to the improvementworks proposed.

We trust that we have now provided the Agency with all of the information required.

Yours faithfully,

. -

" w - Liam Clear T J 0 'Connor & Associates

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. . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . .

An Bord Pleaniila

PLANNING AND DEVELOPMENT ACTS 2000 TO 2007

Offaly County Council

APPLICATION by Offaly County Council for approval under section 175 of the Planning and Development Act 2000 to 2007 in accordance with plans and particulars, including an environmental impact statement, lodged with the Board on the 30* November, 2007.

PROPOSED DEVELOPMENT: Expansion of the Tullamore Wastewater Treatment Plant, County Offaly.

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DECISION

APPROVE subject to conditions above proposed development based on the reasons and considerations set out under.

MATTE3W CONSIDERED

In making its decision, the Board had regard to those matters to which, by virtue of the Planning and Development Acts and Regulations made thereunder, it was required to have regard. Such matters included any submissions and observations received by it in accordance with statutory provisions.

i i ,

Reasons and Considerations

Having regard to the provisions of the current County Offaly Development Plan, the 'hllamore and Environs Development Plan, the Sludge Management Plan for County Offaly, the Wastewater Discharge (Authorisation) Regulations 2007, the European ' Communities (Quality of Salmonid Waters) Regulations 1988, the existing use of the lands where the development is proposed and the mitigation measures proposed in the environmental impact statement, it is considered that, subject to the conditions set out in this order, the proposed development would be in accordance with the proper planning and sustainable development of the area and would not result in significant adverse effects on the environment.

- An Bord Pleanhla Page 1 of 4

9 19*JA0007

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...................... ... .... ... ..... ~

Suspended Solids (SS) Total Nitrogen

CONDh'IONS

15 mg/l 15mgA as N

1.

Total Phosphorus

2.

N 0.5mgfl

3.

4.

5.

Treated wastewater discharge to the Tullamore River shall not exceed 7,400m3 per day. Values in excess of that shall be discharged to the Clodiagh River, up to a maximum value of 3,700m3 per day and shall be at the location indicated' in the environmental impact statement.

Reason: To protect water quality.

The wastewater treatment plant shall be constructed to a standard adequate to ensure compliance with the following treated effluent values:

1 Biochemical OxwenDemand (BOD) I 10 mdl I

I Total Ammonia I 10.5mgllas I

Reason: To protect water quality.

Tertiary treatment shall be included in the treatment plant design.

Reason: To ensure the plant is capable of achieving satisfactory treatment levels under all operating conditions and thereby to protect water quality.

The results of the monitoring of the effluent discharges and all other monitoring to be carried out in accordance with the EIS recommendations shall be made available to the general public and shall be published at least annually on the local authority's website.

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Reason: To ensu.re.that information in relation to the environment is available to the public.

Stormwater storage facilities with a minimum capacity of 3,600m3 shall be provided as part of the development.

Reason: To prevent water pollution.

?

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6. (a) Storage capacity shall be put in place for any leachate to be treated at the plant. A sampling programme to monitor for any toxicity in the leachate shall be implemented.

(b) Arrangements shall be put in place for the temporary diversion of landfill leachate fiom the treatment plant when potential inhibitors (to the operation of the treatment plant) are detected. The diversion route shall be availed of for the duration of any quality problems with the leachate.

Reason: To prevent water pollution.

7. The monitoring and management scheme for the extended treatment plant shall incorporate a long term ecological monitoring programme for both the Tullamore River and Clodiagh Rivers. Monitoring shall be carried out on an annual basis at suitably appropriate locations upstream and downstream of the effluent discharge points. The monitoring programme shall include invertebrate analysis and biological water quality assessment.

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Reason: To protect the aquatic environment.

8. A 10 metre wide strip shall be reserved free of development adjacent to the Tullamore River channel serving the Grand Canal.

Reason: To facilitate river maintenance.

9. A flow gauging station shall be installed at a suitably appropriate location in the vicinity of the proposed discharge location on the River Clodiagh. The applicant shall consult with the EPA in relation to the precise location and design of the sktion.

Reason: To prevent water pcpllution.

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10. Odours emanating fiom the development shall not exceed a level of 3ou/m3 on a 98 percentile basis when measured at the site boundary. A monitoring programme for odour shall be carried out as set out in the EIS.

Reason: To control odour emissions from the development.

11. New and extended buildings shall be visually co-ordinated. Finishes and roof profiles on new and extended or modified buildings shall be compatible.

Reason: In the interest of visual amenity of the area.

- 119. JA0007 An Bord Pleanhla Page 3 of 4

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12. Excavations required for site development works, including pipeline construction, shall be supervised and monitored by a qualified archaeologist. A report on the monitoring shall be prepared by the archaeologist and made available for inspection by the public at the offices o f the local authority within 12 months o f the completion o f site development works, and a copy forwarded to the Department o f the Environment, Heritage and Local Government.

Reason: To ensure that any items of archaeological interest impacted upon by the development are evaluated and recorded.

13. All mitigation measures set out in the EIS in relation to the project construction and operation shall be implemented, including monitoring. Prior to construction a document containing a symmary of all mitigation measures shall be produced.

Reason: In the interests o f orderly development and protection o f the environment and local amenities.

C& 'a

-A

Member of An Bord Pleapila duly authorised to a u t h e h a t e the seal of the Board.

2008. ac

Dated t h h h day of

19. JA0007 An Bord Pleanhla Page 4 of 4

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