Ref. Ares(2013)7675 - 04/01/2013
PROPOSAL for a NATIONAL INSPECTION PLAN for DOMESTIC WASTE WATER
TREATMENT SYSTEMS
EPA Discussion Document
Reasons for a National Inspection Plan
The Environmental Protection Agency (EPA) is developing a National Inspection Plan for
Domestic Waste Water Treatment Systems (to be called the ‘Inspection Plan’ throughout
this document) as required under the
Water Services (Amendment) Act 2012. Domestic
waste water treatment systems can and do cause pollution when they are not properly
sited, installed or maintained. This discussion document sets out the general principles
which the EPA proposes to use in the Inspection Plan, drawing on experience and best
international practice in science and regulation. The EPA invites interested parties and
individuals to submit comments for consideration.
Domestic waste water treatment system use in Ireland
One third of houses in Ireland (i.e. almost half a million properties, as recorded in Census
2011) are connected to a domestic waste water treatment system. Most systems use a
septic tank, though more advanced waste water treatment systems are also used, which
allow for shallower depths of subsoil and a smaller area for distributing discharged effluent
than are needed for septic tanks.
All domestic waste water treatment systems are designed to:
Protect humans from contact with waste water;
Treat wastewater to minimise contamination of soils, lakes, rivers and groundwaters;
Keep animals, insects, and vermin from contact with waste water; and
Minimise the generation of foul odours.
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Risks posed by wastewater to human health and the environment
While domestic systems pose much less of a risk to watercourses than public sewerage
discharges and agricultural effluents, they can cause localised pollution. Where systems are
not properly located, designed, installed, operated or managed they pose a risk to the
health of the homeowner, their children and pets (Figure 1) through contamination of water
in private wells, or ponding of effluent in gardens. Effluent that reaches watercourses
(Figure 2) can result in problems for drinking water, bathing waters, and other amenities.
Figure 1: Example of an exposed waste water distribution pipe and what can happen when a family pet comes in contact
with a poorly constructed system. (photo by A. Goggin, Limerick Co. Co.)
There are a number of pollutants in waste water, each of which can cause human health
and environmental problems. Microbial pathogens in effluent can cause gastroenteritis, eye
infections, polio, hepatitis and meningitis if there is human contact. The presence of
E. coli
bacteria provides evidence of recent faecal contamination from human or animal wastes.
Drinking water is tested for the presence of
E. coli as it is a clear indicator of contamination.
Typically there are approximately one million
E. coli bacteria in one litre of effluent from a
septic tank serving a normal household, while the drinking water standard is zero.
Phosphorus is another pollutant in domestic waste water. Phosphorus encourages the
growth of algae, depletes oxygen, and may cause algal blooms and fish kills in lakes and
rivers.
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Figure 2: Dye test showing effluent in a watercourse from a septic tank. (photo by A. Goggin, Limerick Co. Co.)
What you need to do
Step 1: Registration
In order to protect health and the environment the owners of properties connected to a
domestic waste water treatment system are being asked to register their systems by
1st
February 2013. This is the first step in ensuring that your system does not pose a risk to your
family or the local environment and to comply with the
Water Services (Amendment) Act
2012. You can register online at www.protectourwater.ie or at local authority offices. You
can also complete an application form and post it with the registration fee to Protect Our
Water, PO Box 12204, Dublin 7. In the case of a new build, the domestic waste water
treatment system should be registered upon occupancy of the house.
Step 2: Operation and Maintenance
Operating and managing your domestic wastewater system well will reduce any potential
risk to human health or the environment. Owners of properties that have a domestic waste
water treatment system are also obliged by law to ensure that their systems are operating
and managed properly and are not creating a risk to human health or the environment.
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Inspection Plan – general principles
In developing the Inspection Plan the EPA will adopt a pragmatic, risk-based inspection
regime to maximise the protection of human health and the environment from potential
impacts of treatment systems. It is proposed that the Inspection Plan will incorporate a twin
track approach using citizen engagement strategies as well as the more traditional
inspection strategies.
INSPECTION PLAN
Inspections
Citizen Engagement
Protection of Human Health
and the Environment
The aim of the Inspection Plan is to make sure that:
Engagement takes place with a range of stakeholders to explore effective education
strategies;
Information is available to owners of domestic waste water treatment systems
regarding their responsibilities and how to operate and maintain their systems;
Information is supplied in multiple, easy to understand formats such as leaflets,
video and web-based ‘frequently asked questions’;
Incentives are used such as lower probability of inspections for registered sites;
Adequate treatment of domestic waste water is in place;
Treatment systems are adequately operated and maintained;
Risks to human health and the environment are identified and managed;
Wastewater sludges from domestic wastewater treatment systems are managed
appropriately.
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The Inspection Plan will be carried out for the most part by local authorities (referred to in
the legislation as ‘Water Services Authorities’) under the supervision of the EPA. The plan
will commence in 2013, with the initial focus on engagement and incentive strategies.
These strategies will involve working closely with householders and other stakeholders to
ensure that those who are responsible for domestic waste water treatment systems know
how to comply and are encouraged to do so. Risk-based inspections will also commence in
2013 following the close of the registration period. Information on domestic waste water
treatment systems captured through inspections will be held electronically for analysis and
reporting purposes. We will review our inspection plan periodically and make changes were
necessary.
A risk-based approach
Risk-based means putting our resources where the risks are highest to human health and
the environment. The Inspection Plan will focus particularly on areas where the potential
risk to public health and valuable water resources are higher. Properties connected to
systems in these areas which have not been registered by the due date of 1st February 2013
will be more likely to be inspected than those that have been registered.
Our assessment of risk follows a pollution Source–Pathway–Receptor Model and reflects
international best practice. In assessing risk, the S_P_R model is used to examine the
potential ‘Source’ of pollution – the septic tank or treatment system; the potential
‘Pathway’ of pollution – typically the subsoil; and the potential ‘Receptor’ – the area where
any potential impact might happen; for example, a river (Figure 3).
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Figure 3: Source–Pathway–Receptor Model for domestic wastewater treatment systems with impermeable subsoil.
(graphic sourced from the Water Framework Directive Visual website, SNIFFER, 2007)
The potential risk will be determined by combining data from a number of GIS layers
following the S-P-R model. These include details of housing density, the prevailing ground
conditions e.g. subsoil permeability, and aquifer classification. Proximity to sensitive
receptors such as rivers, lakes, drinking waste abstraction point and bathing water areas will
also be taken into account.
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Citizen engagement
Raising awareness and working with interested parties
The EPA and local authorities will talk to interested parties and particularly groups that
represent the rural community, such as Irish Farmers’ Association, Irish Creamery Milk
Suppliers Association, Irish Country Women’s Association, the National Federation of Group
Water Schemes, as well as Non-Governmental Organisations such as Irish Environmental
Network, SWAN, An Taisce and others. The EPA will seek ideas for citizen engagement
strategies from the individual groups to raise awareness and encourage best practice among
their members and the wider community.
The Department of Environment, Community and Local Government, in conjunction with
the EPA and local authorities, will also undertake a series of activities to create awareness in
order to increase compliance related to the registration, operation and maintenance of
domestic waste water treatment systems.
Assistance will include dissemination of information for householders through leaflets,
newspaper articles, videos and dynamic website pages. Technical guidance will also be
made available on the EPA website.
Inspection
A broad range of
inspection types will be employed such as proxy inspections monitoring
the local environment, assessment of sewage schemes, analysis of sludge management,
inspections resulting from complaints, and on-site inspections of domestic waste water
systems (DWWTS).
What to expect from an inspection of a DWWTS
Trained local authority staff will conduct inspections in the following manner.
1. The homeowner will be notified in writing at least 10 days before an inspection will
take place.
2. The Inspector will carry identification and will check that the treatment system, as
constructed, is fit for purpose.
3. The Inspector will check that untreated waste water, which contains high levels of
coliforms, is not escaping into the environment.
4. The inspector will check for the indications of a defective system, for example:
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- A smell of sewage from the general area of the system or percolation area;
- Sewage which is backed up at the inlet to the treatment system;
- Ponding of sewage or effluent on the ground near the system or the percolation
area;
- Any excess of sludge in the tank;
- Signs that rainwater is entering the system;
- A discharge from the system directly to a drainage channel, ditch or other water
body.
5. The owner will be notified about the findings of the inspection within 21 days. If the
system poses a risk to either public health or the environment the local authority will
issue an Advisory Notice within 21 days which will instruct the homeowner to
remedy the problems. The notice will include reason(s) for the failure and may
specify measures to be taken. In cases where the homeowner disagrees with the
Advisory Notice a follow up inspection can be arranged with the local authority for a
fee of €20.
Steps to help you comply with an inspection
The EPA has prepared a series of ‘frequently asked questions’ (FAQs) about domestic waste
water treatment systems and these can be found at
www.epa.ie/whatwedo/advice/wastewater/guidance
It is recommended that homeowners should:
- Visually check the system at least every six months.
- Investigate any ponding of effluent, bad smells or discolouration of nearby
drains.
- Have the distribution box checked by an appropriate person for blockages and to
ensure an even distribution of effluent. (The distribution box is beneath the
manhole cover between the wastewater treatment system and the percolation
area).
- Have the system desludged at the appropriate intervals by a permitted waste
collection contractor.
- For advanced waste water treatment systems, it is recommended to have an on-
going maintenance agreement in place with an appropriately qualified person.
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- Check to ensure that the electrical components (pump, blower, etc.) are
operating correctly. Without a constant air supply such a system cannot treat
waste water;
Following these steps will help to protect your health, and that of your neighbour as
well as protecting the environment.
Your comments are welcome
Interested parties and individuals are invited to submit comments in writing by emailing the
EPA at xxxxx@xxx.xx, to be received by 31st October 2012. The EPA will take into account
comments received in finalising the Inspection Plan.
The EPA will provide a copy of the final Inspection Plan to the Minister for the Environment,
Community and Local Government and to each local authority by the end of 2012. It will
also be published on the EPA website. The EPA will review the Inspection Plan from time to
time to ensure that it is practical and meets the objectives of protecting human health and
the environment.
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