IPPC Application Form V2/12

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ATTACHMENT E.2

EMISSIONS TO SURFACE WATERS

SITE SERVICES LAYOUT SHEET 1 OF 2 (IE0310818-30-DR-0021)

SITE SERVICES LAYOUT SHEET 2 OF 2 (IE0310818-30-DR-0022)

LOCATION OF EMISSION TO SURFACE WATER (IE0310818-22-DR-0002)

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Attachment E.2 Emissions to Surface Waters

Uncontaminated stormwater from the facility will be discharged to the IDA’s stormwater

drain located at the road to the east of the site (access road to the IDA Belview Science

and Technology Park). Detail of the surface water emission point is outlined in Table

E.2(i) and Table E.2(ii) of this application.

Contaminated or non-compliant Stormwater will be sent to the Waterford City Council

WWTP at Belview for treatment or to the site firewater collection pond for interim

storage pending a decision on fate, as appropriate.

Process trade effluent (mainly from CIP processes) and effluent will be discharged to the

trade effluent sewer and treated at the Waterford City Council WWTP at Belview.

Condensate from the evaporation plant will be treated onsite by reverse osmosis and may

be either re-used onsite for a variety of uses or sent for treatment at the WCC WWTP

along with the process effluent.

See Drawings IE0310818-30-DR-0021 and IE0310818-30-DR-0022 for a site plan

showing the site services layout (existing and proposed). The location of the surface water

emission point is shown on Drawing No. IE0310818-22-DR-0002 also included in this

section of the IPPC licence application.

As the discharge will be of water normally entering the hydrological system at the site

environs, without any contamination arising due to site activities, there will be no impact

on the quality or volume of the receiving stream as a result.

Proposed Stormwater Collection System

There will be a single surface water discharge point from the facility, to the existing

450mm IDA storm drain at the access road east of the site.

Stormwater from road and parking areas on site will be collected and passed through an

oil/petrol interceptor and then combined with stormwater from other areas on site (mainly

roofed areas). This will pass through a chamber where it will be monitored for pH,

temperature and Total Organic Carbon content (TOC). Should the stormwater be outside

of the parameters for discharge licensed by the EPA in the facility’s IPPC licence, it will

be automatically diverted to the firewater retention pond (see below) for interim storage

and investigation prior to onward discharge / disposal.

Should the storm water comply with the discharge conditions of the IPPC licence, it will

be discharged to the IDA storm drain at a rate of 37.5 L/s. A hydrobrake system will be

provided in the drain to divert flow greater than this to the stormwater attenuation pond. A

2,000 m3 stormwater attenuation pond will be provided to attenuate large volumes of

rainfall during a storm event so that the stream and other areas around do not flood. The

stormwater attenuation pond will be lined in order to ensure that the pond does not

interfere with the groundwater in the area.

There will be no direct discharge of surface water from the facility directly to the artificial

wetland and lagoon area at the northeast of the site.

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The existing drainage ditches around the site footprint will be replaced by land drains to

take any overland flow of surface water and prevent flooding of the site itself from

overground flows from upgradient lands to the west and northwest. These drains will

discharge into the lagoons and onward to the stream.

Some of the roadways at the rear of the site (north/western end) which will only have

occasional traffic may be constructed of ‘grasscrete’, a material that allows percolation of

rainwater back into the soil.

In the event that discharge from the stormwater attenuation pond is outside of the licensed

parameters for discharge, the valve will close automatically. The non-compliant

stormwater may be sent to the Waterford City Council WWTP at Belview for treatment or

to the site firewater collection pond for interim storage pending a decision on fate, as

appropriate.

• There will be no substances listed in the Schedule of EPA

(Licensing)(Amendment) Regulations 2004 S.I. No. 394 of 2004 held or used

at the facility, so there will be no emissions thereof to surface water.

• There will be no substances listed in List I and List II substances listed in the

Annex to EU Directive 2006/11/EC (as amended), held or used at the facility,

so there will be no emissions thereof to surface water.

• There will be no substances listed in the European Communities

Environmental Objectives (Surface Waters) Regulations held or used at the

facility, so there will be no emissions thereof to surface water.

Emission levels for discharges to surface water

The EPA’s BAT Guidance Note on Best Available Techniques for the Dairy Processing

Sector (2008), Section 6.2, sets out emission level values that are achievable for

wastewater treatment. Those emission levels apply to effluent prior to dilution by

uncontaminated streams, e.g. storm water, cooling water, etc, and are not intended as

emission limits for discharges of uncontaminated stormwater. Section 7.2 of the BAT

Guidance Note proposes the following monitoring of aqueous emissions:

Daily monitoring of flow, volume, pH, temperature and any other relevant parameters

deemed necessary by the Agency, taking account of the nature, magnitude and variability

of the emissions and the reliability of the control technique.

It is proposed that the following be conducted on the discharge to the IDA stormwater

drain from the stormwater attenuation pond:

Parameter Frequency of monitoring

pH Continuous

Flow Continuous

Temperature Continuous

TOC Continuous

Note that at the time of this application, the EPA was in the process of inviting

consultation on guidance for the setting of trigger values for discharges to surface water,

which recommended that 12 months of continuous monitoring be collected after

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commencement of operation of a licensed activity, to enable realistic trigger values to be

set for the individual site.

A summary report of emissions to surface water shall be submitted to the EPA each year

as part of the Annual Environmental Report (AER) for the facility. The information

contained in the AER shall be prepared in accordance with any relevant guidelines issued

by the EPA.

Proposed Effluent Collection System

There will be no discharges of treated or untreated effluent to surface water arising at the

facility. Trade effluent will be collected in a balancing tank and neutralised prior to

discharge to the sewer, which will carry it for treatment at the Waterford City Council

WWTP at Belview. Foul effluent will similarly be sent for treatment by sewer at the

Waterford City Council WWTP at Belview.

Water Quality in the Downstream Surface Water Courses

Stream

Uncontaminated stormwater from the site will be discharged in a controlled fashion to the

IDA stormwater drain at location SW1.

In 2007, Scott Cawley Ltd. performed biological water quality sampling (Q-sampling) in

the stream. The results indicated that the stream had a Q-rating of 3-4 and 3, i.e. slightly

to moderately polluted in terms of its biological water quality.

In 2009, AWN conducted a hydraulic capacity assessment of the stream east of the site as

part of the Environmental Impact Assessment for the Supram facility (planning ref. KK

PR/09/194). For that proposed site, using the rainfall data for Waterford city from Met

Eireann, the receiving stream has sufficient hydraulic capacity to cater for the stormwater

discharge from the proposed Supram development, during a 1 in 100 year flood over a 1

hour period, even considering the possible impacts from climate change.

River Suir

The Lower River Suir, which is located approximately 330m south of the site, covers a

stretch of 6.5 Km of the Suir Estuary, that extends from Ballynakill on the outskirts of

Waterford city, to Cheekpoint, where the Suir meets the River Barrow. The Lower Suir

Estuary is considered a transitional water body, i.e. a surface water body in the vicinity of

a river mouth, which is partly saline in character as a result of its vicinity to coastal

waters, but which is substantially influenced by freshwater flows.

The Lower Suir Estuary is not a Water Framework Directive (WFD) protected area.

Approximately 1.7Km downstream of the confluence of the stream and the Suir estuary is

a New Shellfish Area at the meeting of the River Suir and the River Barrow. The section

of the Lower Suir Estuary from Little Island to Cheekpoint has Good WFD status. The

EPA’s online maps show the estuarine water quality of the Lower Suir Estuary to be

Intermediate (2007-2009).

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The subject site falls within the catchment areas of both the Barrow and the Suir rivers,

which are salmonid water bodies. The surface water environment surrounding the site is

considered ecologically sensitive as:

• The Lower River Suir is a designated proposed NHA and candidate SAC (site

code 2137)

• The River Barrow/River Nore is a candidate SAC

• The River Barrow estuary is a proposed NHA; and

• King’s Channel is a proposed NHA (site code 001702).

In 2009, AWN conducted a baseline water quality survey at the streams located east and

west of the site as part of the Environmental Impact Assessment for the Supram facility

(planning ref. KK PR/09/194). Water samples were collected by AWN from both streams

and analysed for a range of parameters. This was collated with Q-sampling also conducted

by the ecologists, Scott Cawley Ltd., in 2007, and desktop data taken from the South

Eastern River Basin District (SEBRD) reports 2005-2007 and from Waterford City

Council (2007).

AWN concluded that the River Suir and River Barrow in the vicinity of the Supram site

were at risk of not achieving “good status” by 2015, according to the SEBRD. The

Barrow, Nore, Suir Estuary was possibly at risk of not achieving “good status” by 2015.

This was due to the presence of elevated levels of contaminants, presumably due to

untreated effluent outfalls into the rivers.

Since the time of AWN’s study, the Waterford city WWTP at Belview has come online.

This has the capacity to treat 190,000 p.e., of which 60% is reserved for industrial use. It

is assumed that the operation of the WWTP will have led to a significant improvement in

water quality in the Suir and downstream.

Flood Risk

The site is not in a flood risk area. According to the OPW flood maps, no flood events

have been recorded at the subject site or in the immediate surrounding area: the nearest

flood locations is the northern bank of the Suir, located ca. 300m south of the subject site.

Kilkenny County Council does not have any records of flooding in the vicinity of the site.

Waterford City Council records show the highest recorded flood level at Rice Bridge to be

2.87 m O.D. (Malin).

The lowest point of the site is 15.5 m O.D.(Malin). The bank of the River Suir, which is

located south of the site, is 1.45 to 1.62 m O.D. (Malin). The subject site, situated

approximately 13 m higher than the banks of the River Suir, thus has a very low risk of

flooding.

The Ferrybank-Belview Local Area Plan (March 2009, Section 2.11.3) states that there

are no flooding problems in the area except in the Newrath area adjacent to the River Suir,

which suffers from tidal flooding on the local road.

AWN conducted a desktop hydraulic capacity assessment in February 2009 of the

receiving stream (to the east of the subject site) for surface water runoff from the Supram

development (planning ref. KK 09/194). It concluded that the receiving stream has

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sufficient hydraulic capacity to cater for the surface water discharge from the proposed

Supram development, during a 1 in 100 year flood over a 1 hour period, even taking

climate change effects into account.

The LAP seeks to protect all stream and river corridors from development, with

opportunities for storm water attenuation ponds in the proposed areas of open space, so as

to ensure the water quality of rivers and streams is maintained. The stormwater

attenuation pond (capacity 2,200m3) is sized to take the runoff from the roofed and

hardstanding areas of the site during a 1 in 100 storm event. The receiving IDA pipe is of

450mm dia. at 1:447 gradient with a capacity of 150 L/s. A hydrobrake system will be

installed to ensure that excessive runoff from the site during a storm event is contained in

the stormwater attenuation pond to minimise the possibility of flooding the stream and

downstream lands. The collected stormwater will be released in a controlled fashion to the

stream post-storm event.

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