Environmental Protection Agency
Ref. Ares(2013)214817 - 19/02/2013
National Inspection Plan 2013
Domestic Waste Water Treatment Systems
Environmental Protection Agency
The Environmental Protection Agency (EPA) is
REGULATING IRELAND’S GREENHOUSE GAS EMISSIONS
a statutory body responsible for protecting
Quantifying Ireland’s emissions of greenhouse gases
the environment in Ireland. We regulate and
in the context of our Kyoto commitments.
police activities that might otherwise cause
Implementing the Emissions Trading Directive,
pollution. We ensure there is solid
involving over 100 companies who are major
information on environmental trends so that
generators of carbon dioxide in Ireland.
necessary actions are taken. Our priorities are
protecting the Irish environment and
ENVIRONMENTAL RESEARCH AND DEVELOPMENT
ensuring that development is sustainable.
Co-ordinating research on environmental issues
(including air and water quality, climate change,
The EPA is an independent public body
biodiversity, environmental technologies).
established in July 1993 under the
Environmental Protection Agency Act, 1992.
STRATEGIC ENVIRONMENTAL ASSESSMENT
Its sponsor in Government is the Department
Assessing the impact of plans and programmes on
of the Environment, Community and Local
the Irish environment (such as waste management
Government.
and development plans).
ENVIRONMENTAL PLANNING, EDUCATION AND
OUR RESPONSIBILITIES
GUIDANCE
Providing guidance to the public and to industry on
LICENSING
various environmental topics (including licence
We license the following to ensure that their emissions
applications, waste prevention and environmental
regulations).
do not endanger human health or harm the environment:
Generating greater environmental awareness
waste facilities (e.g., landfills, incinerators,
(through environmental television programmes and
waste transfer stations);
primary and secondary schools’ resource packs).
large scale industrial activities (e.g., pharmaceutical
manufacturing, cement manufacturing, power
PROACTIVE WASTE MANAGEMENT
plants);
intensive agriculture;
Promoting waste prevention and minimisation
projects through the co-ordination of the National
the contained use and controlled release of
Waste Prevention Programme, including input into
Genetically Modified Organisms (GMOs);
the implementation of Producer Responsibility
large petrol storage facilities;
Initiatives.
waste water discharges.
Enforcing Regulations such as Waste Electrical and
Electronic Equipment (WEEE) and Restriction of
NATIONAL ENVIRONMENTAL ENFORCEMENT
Hazardous Substances (RoHS) and substances that
deplete the ozone layer.
Conducting over 2,000 audits and inspections of
EPA licensed facilities every year.
Developing a National Hazardous Waste Management
Plan to prevent and manage hazardous waste.
Overseeing local authorities’ environmental
protection responsibilities in the areas of - air,
noise, waste, waste-water and water quality.
MANAGEMENT AND STRUCTURE OF THE EPA
Working with local authorities and the Gardaí to
The organisation is managed by a full time Board,
stamp out illegal waste activity by co-ordinating a
consisting of a Director General and four Directors.
national enforcement network, targeting offenders,
conducting investigations and overseeing
The work of the EPA is carried out across four offices:
remediation.
Office of Climate, Licensing and Resource Use
Prosecuting those who flout environmental law and
damage the environment as a result of their actions.
Office of Environmental Enforcement
Office of Environmental Assessment
MONITORING, ANALYSING AND REPORTING ON THE
Office of Communications and Corporate Services
ENVIRONMENT
Monitoring air quality and the quality of rivers,
The EPA is assisted by an Advisory Committee of twelve
lakes, tidal waters and ground waters; measuring
members who meet several times a year to discuss
water levels and river flows.
issues of concern and offer advice to the Board.
Independent reporting to inform decision making by
national and local government.
Protecting Our Water and Our Health
National Inspection Plan
Domestic Waste Water Treatment Systems
2013
Environmental Protection Agency
An Ghníomhaireacht um Chaomhnú Comhshaoil
Johnstown Castle Estate
Wexford
Ireland
www.epa.ie
National Inspection Plan
© Environmental Protection Agency 2013
DISCLAIMER
Although every effort has been made to ensure the accuracy of the material contained in this
publication, complete accuracy cannot be guaranteed. Neither the Environmental Protection
Agency nor the author(s) accept any responsibility whatsoever for loss or damage occasioned or
claimed to have been occasioned, in part or in full, as a consequence of any person acting, or
refraining from acting, as a result of a matter contained in this publication. All or part of this
publication may be reproduced without further permission, provided the source is acknowledged.
NATIONAL INSPECTION PLAN
Domestic Waste Water Treatment Systems
2013
Published by the Environmental Protection Agency, Ireland
ISBN 978-1-84095-479-1
V.1.0
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National Inspection Plan
Important Notice for Householders
Householders will be notified in advance by their Local Authority if their domestic waste
water treatment system is to be inspected and inspectors will be required to carry
identification and to present this on request to householders.
Never enter a waste water tank, even when empty of waste, as dangerous gases may be
present – seek specialist assistance from a trained professional.
Visit the EPA website for more information on domestic waste water
www.epa.ie/whatwedo/advice/wastewater
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National Inspection Plan
Acknowledgements
Developing the National Inspection Plan has involved drawing on the expertise and experience of
national and international experts. The Environmental Protection Agency (EPA) gratefully
acknowledges their work in providing ideas, information, comments and otherwise contributing to
preparing the National Inspection Plan for domestic waste water treatment systems. The EPA in
particular wishes to acknowledge the international experts who peer-reviewed the risk methodology
that underpins this plan.
As part of the development of the Plan the EPA, with Trinity College Dublin, held an international
symposium on domestic waste water treatment systems. This event was attended by over 250
researchers, policy makers, local authority staff and practitioners. The symposium provided a forum
for debate and discussion between national and international delegates. The EPA gratefully
acknowledges the participation and contributions of all of the 15 Irish based and 13 international
speakers at the event. A full list of the speakers, along with videos and copies of the papers, is
available on
www.epa.ie.
The EPA also wishes to acknowledge those people and organisations who took time to make
submissions during the consultation on the ‘
Proposals for a National Inspection Plan for Domestic
Waste Water Treatment Systems’.
Strategic Environmental Assessment
The EPA has undertaken a review to ascertain if the National Inspection Plan falls within the scope
of the Strategic Environmental Assessment (SEA) Directive (2001/42/EC). It is the view of the EPA
that this Plan does not require an SEA to be carried out.
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National Inspection Plan
Foreword
Clean, healthy and well-protected water is essential to maintain viable and
Clean, healthy
vibrant communities in unsewered areas across Ireland. These communities,
and well
which are predominantly in rural areas, need to have dependable, clean
protected
sources of water and sustainable and safe ways to manage their waste waters.
water is
According to the Central Statistics Office (CSO, 2012), on-site domestic waste
essential to
water treatment systems collect, treat and discharge waste water from almost
maintain
500,000 households in Ireland. At a large catchment scale, domestic systems
viable and
pose much less of a risk to watercourses than urban waste water discharges
vibrant
and diffuse agricultural pollution. However, if not managed and treated
communities
appropriately, domestic waste water may contaminate private and public
across Ireland.
water supplies, groundwater, and surface water, causing harm to human
health and the environment.
The European Court of Justice found that Ireland had not met the legal
obligation required by the 1975 Waste Framework Directive to regulate the
waste water generated in our unsewered areas. This National Inspection Plan
for Domestic Waste Water Treatment Systems responds to Ireland’s failure to
implement the 1975 Waste Directive.
Increasing pollution pressures and the rightful expectation of the public for
clean water led to laws such as the EU Water Framework Directive. This
Directive established a framework for the protection of all waters including
rivers, lakes, estuaries, coastal waters and groundwater, including dependent
wildlife and habitats, under one piece of environmental legislation. This
National Inspection Plan will also form part of the ‘programme of measures’
under the EU Water Framework Directive. Ireland needs to make a more
determined effort to protect and enhance all waters so that they achieve at
least ‘good’ status. This inspection plan is one part of this effort to improve
and protect our waters.
The success of this plan depends on a number of elements including
commitments from government, local authorities and, not least, rural
communities. Human and financial resources will be required for many years to
come. This investment in clean, healthy and protected water will be of benefit
not only to the health and wellbeing of our people but also to farming, industry
and rural tourism.
Laura Burke,
Director General
Wexford, January 2013
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National Inspection Plan
Table of Contents
Acknowledgements ................................................................................................................................ iii
Foreword ................................................................................................................................................ iv
Table of Contents .................................................................................................................................... v
Chapter 1 – An impetus for action on domestic waste water ................................................................ 1
Chapter 2 – Risks to health and water from domestic waste water ...................................................... 3
Chapter 3 – Identifying areas at risk ....................................................................................................... 6
Chapter 4 – Strategy behind the National Inspection Plan ................................................................... 12
Chapter 5 – Citizen engagement ........................................................................................................... 15
Chapter 6 – Inspections ........................................................................................................................ 17
Chapter 7 – Implementing and reviewing the plan .............................................................................. 26
References ............................................................................................................................................ 29
Glossary ................................................................................................................................................. 31
Appendix A:
Tables for allocation of risk based inspections
Appendix B:
Example of an advisory notice
Appendix C:
Legislation
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National Inspection Plan
Chapter 1 – An impetus for action on domestic waste water
Achieving good status water
This National Inspection Plan for Domestic Waste Water Treatment Systems (DWWTSs) sets out part
of the actions being taken to respond to the judgment (C-188/08) against Ireland under the Waste
Framework Directive 1975/442/EC on the regulation of domestic waste water. It will also form part
of the actions by Ireland to protect water and the environment from domestic waste water
discharges and will form part of Ireland’s programme of measures under the Water Framework
Directive.
The Water Framework Directive (WFD) (Directive 2000/60/EC) aims to improve water quality
throughout the European Union. The objective of the Directive is to bring waters to good status and
to protect existing good and high status waters. It applies to rivers, lakes, groundwater, estuarine
and coastal waters. Ireland has an estimated 160,000 (CSO, 2012) drinking water wells and springs,
and protecting these from contamination by domestic waste water is of high importance.
The role of domestic waste water treatment systems
About one-third of all houses (500,000 households) in Ireland rely on an individual ‘domestic waste
water treatment system’ to collect, treat and discharge their household waste water. These systems
are typically located on or adjacent to the property and include systems such as septic tanks,
packaged plants, tertiary treatment units and associated discharge or infiltration areas. These
systems, when designed and operated properly, are cost-effective means of protecting public health
and water quality in low-density communities (USEPA, 2002). The houses with these systems are
generally rural based dwellings built in areas without a municipal sewer and treatment plant.
However, there are also households in urban and suburban areas that rely on septic tanks to treat
their waste water.
Treatment systems are designed to protect humans from contact with waste water; treat waste
water to minimise contamination of soils, lakes, rivers and groundwater; keep animals, insects, and
vermin from contact with waste water; and minimise the generation of foul odours. The most
common treatment is settlement of solid materials followed by soil infiltration. Solid material
accumulates in the settlement tank and is removed on a periodic basis for recovery or disposal off-
site.
Where DWWTSs are not properly located, designed, installed, operated and managed they pose a
threat to human health through possible contamination of drinking water wells or from effluent
ponding in gardens (Photo A), exposing people and pets to untreated waste water (Photo B). One of
the biggest challenges for households relying on these systems is inadequate percolation of
treatment system effluent.
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Photo A: Vegetation growth signalling that effluent
Photo B: A dog drinking from an exposed waste water
from a domestic waste water treatment system is
distribution pipe
ponding in this garden
Figure 1: Examples of health risks from domestic waste water treatment systems
In addition to the risk posed to human health, malfunctioning DWWTSs also pose a risk to our
watercourses and may impact on fishing, bathing waters and other amenities. In order to reduce
such risks it is essential that adequate treatment of this effluent occurs before safe disposal by
percolation.
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Chapter 2 – Risks to health and water from domestic waste water
Discharges from domestic waste water treatment systems result in a higher risk where percolation is
inadequate and where the groundwater vulnerability is high. The EPA has constructed a risk
assessment methodology using data on
density of systems,
attenuation and
infiltration to establish
zones of risk across the entire country. This has then been used in conjunction with the location of
sensitive receptors to allocate inspections based on risk and sensitivity. This chapter sets out the
background to identifying the waters at risk from domestic waste water treatment system
discharges.
Waste water effluent
Domestic waste water treatment systems accept waste water from toilets, showers, sinks, wash
hand basins, washing machines and dishwashers. The greater the population of the dwelling, the
greater the volume of waste water produced. For the purpose of this plan, a DWWTS is assumed to
have a daily hydraulic loading for each person of 150 litres and typical household occupancy of 2.8
people. On a national scale, this equates to a liquid discharge of 210,000 m3 per day or 46 million
gallons (equivalent to 84 Olympic swimming pools). There are a number of different pollutants in
domestic waste water, each of which can cause problems for health and the environment.
The quality of domestic waste water will vary with the nature of the system; the volume of waste
water being produced; the design of the system; the number of people in the house; the chemicals
(e.g. detergents) being used; and the nature of the domestic activities carried out in the household.
Typical ranges of the main pollutants found by Ó Súilleabháin (2004) and Gill
et al. (2005) are shown
in Table 1.
Table 1: Typical pollutant concentrations from DWWTSs (Ó Súilleabháin, 2004 and Gill
et al., 2005)
Pollutant
Conventional Septic Tank
Secondary Treatment Tank
Faecal Coliforms
> 1 million/100ml
> 5-10,000/100ml
Nitrogen (mg/l N)
30-80
20-35
Phosphorus (mg/l P)
5-20
1-5
BOD (mg/l)
150-500
20-50
Microbial pathogens
Domestic waste water contains human waste products and the discharge from the DWWTS may
contain disease-causing bacteria, viruses and/or parasites arising from the population using the
system. The chief recognised illness associated with exposure to inadequately treated domestic
waste water is acute gastrointestinal illness causing fever, nausea and diarrhoea (Macler and Merkle,
2000). Most cases are of short duration, but vulnerable people such as infants, pregnant women, the
elderly or those with pre-existing health conditions are particularly at risk of serious health
consequences if exposed to these pathogens. When testing water, faecal coliforms are most
commonly used as an indicator of contamination with human or animal wastes.
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Microbial pathogens arising from DWWTSs pose a threat in three circumstances:
Where percolation into the ground is inadequate and ponding and/or direct discharge to
ditches and streams occurs, with the potential for direct contact with pathogens by, in
particular, children and domestic animals.
Where the percolation area (or soak pit) is in the zone of contribution of a water supply
well or spring and there is inadequate treatment of the effluent in the subsoil and/or
bedrock, resulting in pathogens reaching the drinking water source.
Where the site is suitable for a DWWTS but the system has not been designed and/or
installed and/or maintained properly.
Usually there are around 1 million
E. coli bacteria in one litre of effluent from a septic tank serving a
typical household. The drinking water standard for
E. coli and coliform bacteria is zero.
Disease causing microbes are particularly a problem for private schemes reliant on groundwater for
drinking water. Many of these wells have poor well-head protection with little or no source-
catchment protection and often do not have any form of treatment to prevent microbial pathogens
reaching the consumer of the drinking water.
Phosphorus
Domestic sources of phosphorus are human waste, laundry detergents and cleaning products.
Phosphorus is the principal growth-limiting nutrient for macroplankton and phytoplankton growth in
freshwater rivers and lakes and is the main cause of eutrophication in rivers and lakes in Ireland.
Additional phosphorus encourages algal growth beyond the natural levels. This growth depletes the
dissolved oxygen in the water, causes algal blooms in lakes and fish kills in rivers. Molybdate-
reactive phosphorus (MRP) is commonly used as a measure of the biologically available phosphorus
in water. MRP is the dominant form of phosphorus pollutant arising from DWWTS discharges.
Nitrogen
Domestic sources of nitrogen are human waste, food preparation, hygiene washings, cleaning
products and, to a lesser extent, laundry sources. As waste water percolates through the subsoil, it
converts firstly to ammonia and then to nitrate. Ammonia can have a detrimental effect on
freshwater aquatic life. Nitrate is highly mobile in the ground and therefore can readily enter
groundwater and, if a well is located nearby, drinking water. The consumption of nitrate-rich water
by young children may give rise to a condition known as methaemoglobinaemia or blue baby
syndrome. In addition, nitrate in surface water can impact on aquatic ecosystems, particularly in
estuarine and coastal waters.
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National Inspection Plan
Waste water sludge
Solid material settles and builds up within the DWWTS settlement tanks. Sludge from a DWWTS
contains a significant number of pathogens and nutrients and so its management is critical to ensure
that the sludge doesn’t pose a risk to human health and the environment. Domestic waste water
sludge is considered a waste and therefore its recovery or disposal is controlled. Sludge must be
removed from the tank periodically (the frequency will depend on the system’s size and use) by a
permitted waste collector. Further information on waste water sludge is available to the homeowner
on www.epa.ie. A list of permitted waste collectors is available at www.nwcpo.ie.
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National Inspection Plan
Chapter 3 – Identifying areas at risk
Ranking areas by risk
The EPA, in conjunction with the Geological Survey of Ireland and other external expertise, has
developed a
specifically designed method to rank areas by the risk posed by domestic waste water
to both human health and the environment across the hydrological and geological settings in
Ireland. This methodology has been peer-reviewed internationally and full details are available in the
EPA report ‘A Risk-Based Methodology to Assist in the Regulation of Domestic Waste Water
Treatment Systems’ (2013) (available on www.epa.ie).
The risk assessment method uses the source-pathway-receptor (S-P-R) model, currently used for
groundwater protection schemes in Ireland. The S-P-R model is based on the concept that for a risk
to exist there must be a
source of potential pollution (e.g. a discharge from a DWWTS), a
receptor that may be impacted by that pollution (e.g. humans or the environment), and a
pathway by which
the pollution can get from the source to the receptor (e.g. through bedrock or soils).
Figures 2 and 3 show how a
source (a discharge from a DWWTS), is linked to receptors (an
abstraction well, a river, and an aquifer used for drinking water) via different pathways. In Figure 2
the discharge moves through thin subsoil and fractures in rock to reach an abstraction well where it
can contaminate drinking water.
Figure 2: S-P-R model for domestic waste water treatment system with subsurface pathways (permeable
subsoil)
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National Inspection Plan
In Figure 3 thick subsoil prevents the discharge taking an underground route but if the permeability
of the subsoil is too low, adequate percolation cannot occur and ponding of DWWTS discharge at the
surface is likely, with a consequent threat to human health. In such a situation, effluent can also flow
‘downhill’ in the more permeable topsoil and enter the well down the outside of the well casing if
not properly installed.
Water table
Figure 3: S-P-R model for domestic waste water treatment system with surface pathways (impermeable
subsoil)
Every DWWTS carries a degree of risk of impacting on water quality and receptors. In many cases,
the risk may be low or manageable through well sited, designed and managed systems. In other
cases, the discharge can pose a significant threat to human health, groundwater or surface water
quality and related receptors. The risk assessment is based on the following information:
Source characterisation: How significant is the DWWTS discharge - the volume of waste
water, the pollutants of concern (MRP, nitrate, pathogens), the nature and condition of the
system, the number of systems in the area;
Pathways analysis: How and where the pollutants flow, to what extent the pollutants are
expected to attenuate, whether there is a hydrogeological or hydrological link that can
deliver a pollutant source to a nearby receptor;
Receptor identification: Who or what potentially could be affected, taking account of
appropriate environmental quality standards.
The risk assessment methodology was used to determine the potential risk posed by DWWTSs
all over Ireland. The result, shown on Map 1, is that each 1 km2 of the country has been
assigned a risk category, which corresponds to the likelihood of DWWTSs in that area
presenting a risk to human health or the environment. The categories are low, moderate, high,
and very high.
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National Inspection Plan
Map 1: Risk Ranking Map
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The results of the risk assessment indicate that:
o The risk to human health from pathogens in domestic waste water is significantly higher in
areas with a high
density of DWWTSs and inadequate percolation; and in vulnerable areas
with private wells.
o Phosphorus is the main pollutant posing a threat to the environment, particularly to surface
water, either where there is
inadequate percolation or where there is
inadequate
attenuation prior to entry of waste water into bedrock aquifers. While the cumulative
pollutant load arising from DWWTSs will be insignificant compared to urban waste water
treatment systems and agriculture at river basin scale, it can be significant in certain physical
settings at small catchment scale.
o The threat posed by nitrogen from DWWTSs is low at catchment scale and at the scale of
this assessment due to dilution; however, in exceptional circumstances, at site-scale (a few
hectares), a high
density of DWWTSs can cause localised plumes with elevated nitrate
concentrations in groundwater.
Areas of Special Interest
There are some receptors which are more sensitive to the pollutants present in DWWTS discharges
than other areas. The locations of these sensitive receptors are shown in Map 2.
Groundwater Drinking Water Supplies
DWWTSs may pose a risk to the quality of a groundwater drinking water supply. If the discharge
from a DWWTS comes in contact with a groundwater body used for the abstraction of drinking
water, there is a risk of human exposure to pathogens contained in the discharge and therefore a
risk to human health. This applies to both individual wells and larger abstraction schemes, whether
private or managed by a Water Services Authority.
Bathing Waters
DWWTSs may pose a risk to the quality of water used for bathing. If the discharge from a DWWTS
enters water used for bathing, there is a risk of human exposure to pathogens contained in the
discharge and therefore a risk to human health. Local authorities are responsible for taking
measures where a bathing water site fails to comply with EC bathing water standards (as set out in
Bathing Water Quality Regulations,
2008 (S.I. No. 79 of 2008)). The Regulations also require that all
identified bathing waters are classified as having water quality status not less than ‘sufficient’ (based
on microbiological standards) by September 2015.
High Status Sites
Discharges from DWWTSs contain significant levels of nutrients which can cause eutrophication and
a reduction in river water quality. This can have a negative impact on the diversity of species in the
river body, in particular those species sensitive to nutrient enrichment. High status sites are crucial
to support the survival of such species, which include juvenile salmon (
Salmo salar) and the
freshwater pearl mussel (
Margaritifera margaritifera).
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National Inspection Plan
High ecological quality is an indicator of largely undisturbed conditions and only minor impact from
human activity. The Water Framework Directive requires Member States to protect and maintain
high and good status water bodies.
Freshwater Pearl Mussel
The sub-basin plans and environmental objectives established under the
European Communities
Environmental Objectives (Freshwater Pearl Mussel) Regulations, S.I. 296 of 2009 for those pearl
mussel populations designated under the Habitats Directive form part of the Water Framework
Directive’s river basin programme of measures. They form part of the basic measures and the
objectives for these protected areas must be achieved by 2015.
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National Inspection Plan
Map 2: Areas of Special Interest
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National Inspection Plan
Chapter 4 – Strategy behind the National Inspection Plan
International Practice
The development of the National Inspection Plan is informed by international practice in regulation
and in particular reflects:
the
EU Recommendation on minimum criteria for environmental inspections (2001/331/EC)
(RMCEI);
risk assessment (the S-P-R model); and
the principles of Better Regulation – focus on risk-based inspections and achieving outcomes
such as good water status and protecting human health.
This plan includes a variety of strategies including:
(1) Risk based inspection;
(2) Proxy inspection based on ambient monitoring of water quality;
(3) Engagement and incentive strategies.
National Inspection Plan Overview
The National Inspection Plan uses two main strands (Figure 4) to achieve protection of public health
and the environment. Through the mechanisms of citizen engagement strategies and DWWTS
inspections, the Plan aims to ensure that:
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;
Public awareness is raised;
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 a lower probability of inspections for registered sites.
Overall, the aim is to move to a situation where a majority of homeowners with domestic waste
water treatment systems know what to do to ensure that their systems are well operated and
maintained and act voluntarily to achieve this.
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National Inspection Plan
National
Inspection Plan
Strand 1:
Strand 2:
Engagement
Inspections
Strategies
Clean Water &
Protected Human
Health
Figure 4: The building blocks of the Plan
Who Does What?
The Plan will be implemented by the Water Services Authorities (WSAs) under the supervision of the
EPA. The Plan will commence in 2013, with the initial focus on citizen engagement and inspections
commencing in July 2013. The EPA will review the Plan during 2014: this review will include an
assessment of the information gathered from the inspections and the response to the awareness
raising campaign. Thereafter the EPA will review the Plan at regular intervals not exceeding five
years.
The
EPA’s role in the regulation of DWWTSs includes:
Drafting the National Inspection Plan for DWWTSs;
Developing an inspector appointment and inspection management system;
Developing guidance and directions for use by WSAs;
Overseeing citizen engagement;
Providing workshops to WSAs on risk-based site selection; and
Supervising local authorities’ environmental functions.
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National Inspection Plan
The EPA also has roles in the implementation of the Water Framework Directive; regulation of large
urban waste water treatment plants, industrial and waste sites; and in ensuring that WSAs deliver
safe, clean and well protected drinking water.
The Department of the Environment, Community and Local Government sets national water policy
and strategy. In addition, there are specific roles for owners of DWWTSs and further responsibilities
for WSAs and their inspectors under the
Water Services (Amendment) Act 2012 as set out in Table 2.
Table 2: Roles and Responsibilities under the
Water Services (Amendment) Act 2012.
Owners of DWWTS
WSA, including inspectors
Apply to a WSA to have their system registered
Establish and maintain a public register of
DWWTSs within their functional areas
Pay a registration fee
Issue a certificate of registration to applicants
who register their systems
Renew registration every 5 years
Implement the inspection requirements set out
in the EPA National Inspection Plan
Produce a valid certificate of registration on
WSA (or EPA) to direct an inspector to carry out
request
an inspection having regard to the National
Inspection Plan
Maintain their treatment system so that it does
Inspector to enter and inspect DWWTS as
not constitute a risk to human health or the
directed by a WSA (or EPA)
environment
Comply with relevant Regulations (i.e. 70L)
Inspector to conduct monitoring, sampling,
photographs, survey, excavate etc.
Remediate their treatment system as
Inspector to request information regarding
appropriate
maintenance, servicing and operation of
DWWTS
Provide evidence of the DWWTS registration to
Inspector/WSA to inform the owner of a
the purchaser of the premises on completion of
premises of the findings of the inspection
a sale
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National Inspection Plan
Chapter 5 – Citizen engagement
Engagement Activities
In September 2012, the EPA with Trinity College, Dublin (TCD) convened an International Symposium
on Domestic Wastewater Treatment & Disposal Systems. The Symposium dealt with a number of
themes focusing on best international practices for the regulation of discharges from domestic
waste water treatment systems. Speakers with national and international expertise in the area were
invited to participate.
The EPA also met with representatives from rural, farming and environmental groups to seek
comment and input to the Plan. Public consultation was invited on the EPA document ‘Proposals for
a National Inspection Plan for Domestic Waste Water Treatment Systems’ prior to the publication of
the Plan.
The Plan will initially focus on engagement strategies (e.g. Figure 5 below) aimed at advising,
educating and assisting the public. The EPA will oversee the implementation of the citizen
engagement strategy by the Water Services Authorities.
Figure 5: EPA public information notice
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National Inspection Plan
Awareness and Education Framework
The first strand of the Inspection Plan is a national public awareness campaign to promote best
practice relating to the operation and maintenance of DWWTSs. The campaign will be rolled out by
WSAs prior to the initiation of targeted risk based inspections and could be developed on a shared
services basis. Key messages will be communicated via a series of channels e.g. web based, videos,
animations (Figure 6), FAQs workshops, presentations, TV (e.g. EcoEye), local radio interviews etc.
Key messages of the framework
Clean water is an essential resource – one we take for granted, but can’t any longer
Clean water is vital for the health and well-being of you and your family
The quality of our water contributes to economic growth – to food exports, fisheries, tourism
Our clean water resource is under threat
We all need to take steps to protect our water
This campaign will inform DWWTS owners of the role they can play to protect their health, that of
their neighbours and the environment. Owners will be made aware of the simple steps they can take
to properly operate and maintain their system as well as raising awareness as to the health
implications where a DWWTS isn’t working properly. The campaign should ensure that those who
are responsible for DWWTSs are provided with authoritative and accessible advice so that they can
protect their health and that of their family, neighbours and the environment.
Figure 6: Screenshot of the DWWTS animation on the EPA website.
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National Inspection Plan
Chapter 6 – Inspections
Inspection activities
The second strand of the plan involves carrying out risk based inspections in addition to undertaking
the monitoring (i.e. proxy inspections) of water quality set out in local enforcement plans and in the
river basin management plans. Inspections will identify problem DWWTSs and trigger measures to
eliminate the health and pollution risk. A greater number of inspections will be targeted in high risk
areas as compared to low risk areas, and unregistered sites will be the initial target. Where a
sensitive receptor is present, a DWWTS will be twice as likely to be inspected as in areas without a
sensitive receptor. The objective of the inspections is to reduce the risk posed to human health and
effect improvements in water quality.
The risk based methodology discussed earlier is used as the basis for the selection of sites for risk
based inspections. The methodology highlights the areas of the country at risk and explains why
some receptors are more sensitive than others, and therefore why they are given a higher priority in
terms of inspection.
Proxy inspections involve the use of monitoring or other tools such as GIS to complement individual
site inspections. As part of the Water Framework Directive the EPA and local authorities carry out a
significant amount of surface water and groundwater sampling. Measuring proxy outcomes, such as
downstream water quality as an indicator of impact from DWWTSs, may be useful in determining
performance; targeting future DWWTS inspections; or triggering immediate remedial actions
without the necessity for a site inspection.
Other types of inspections are outlined in Table 3.
Table 3: Other types of DWWTS inspections
Inspection Type
Details
Registration
Owners of DWWTSs who fail to register within the specified time period
inspection
will become a higher enforcement priority and are more likely to be
inspected.
Re-inspection
Following an initial inspection of a DWWTS an owner may request a re-
inspection further to receipt of an Advisory Notice. The WSA authority
arranges for the re-inspection and the Advisory Notice is confirmed,
modified or cancelled.
Verification
The WSA may carry out a verification inspection to verify that remedial
inspection
works are completed prior to the closure of an Advisory Notice. These
inspections will be recorded as part of the Plan.
Reactive inspection
To date, WSAs have undertaken reactive inspections in certain
circumstances such as following complaints, incidents or accidents where
the operation of DWWTSs may give rise to an impact on human health or
the environment. These inspections are undertaken under the
Local
Government (Water Pollution) Acts 1977-1990. Complaints relating to
DWWTSs are dealt with under the national environmental complaints
procedure.
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National Inspection Plan
Allocation of risk-based inspections
The potential risk posed by DWWTSs all over Ireland was shown in Map 1 where each 1 km2 segment
of the country is assigned a risk category, which corresponds to the likelihood of DWWTSs in that
area presenting a risk to human health or the environment. The risk categories are low, moderate,
high, and very high. Additional sensitive receptors that are considered at potential risk from DWWTS
discharges are shown in Map 2. Overlaying the two maps results in eight risk zones, based on the
four risk ranking categories that are derived from the Risk Assessment which are each then sub-
divided, based on the presence or absence of catchment areas of sensitive receptors. These eight
zones are illustrated in Table 4 and Map 3.
Table 4: Division of the risk categories
Risk Zones
Risk Ranking category
Outside catchment area of
Inside catchment area of sensitive
sensitive receptors
receptors
Low – Zone 1
Zone 1A
Zone 1B
Moderate – Zone 2
Zone 2A
Zone 2B
High – Zone 3
Zone 3A
Zone 3B
Very High – Zone 4
Zone 4A
Zone 4B
These eight zones can now be used to determine the appropriate allocation of inspections of
DWWTSs on the basis of risk to human health and the environment, i.e. more inspections will be
done where the risk is higher and fewer where the risk is lower. In order to reflect this, weightings
are chosen for each risk category, i.e. low 5%; moderate 15%; high 30%; very high 50%. This means
that if the area of a county is divided equally among the four risk categories, 5% of the inspections
would be carried out in low risk areas (Zone 1), 15% in the moderate risk areas (Zone 2), 30% in the
high risk areas (Zone 3) and 50% in the very high risk areas (Zone 4). Within the catchments of
sensitive receptors (Zones 1B, 2B, 3B, 4B) an additional weighting is applied which is to double the
rate of inspections in these areas relative to the surrounding areas. The weightings enable a uniform
approach country-wide to the allocation of inspections and are consistent with the risk-based
philosophy being followed.
In practice, the area of a county will be unequally distributed among some or all of the different risk
categories. Table A.1 in Appendix A shows the areas in each category for each county. Applying the
relevant weighting factors to the areas in each risk category takes the risk into account and gives a
distribution for the county of the inspections to be done in the areas covered by each risk category.
Table A.2 in Appendix A shows this distribution, based on a national allocation of 1,000 inspections.
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National Inspection Plan
Map 3: Risk ranking map combined with Areas of Special Interest Map giving eight risk zones
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National Inspection Plan
Number of inspections
Risk-based site inspections by registered and trained inspectors will begin from July 2013. The Plan
requires that a minimum of 1,000 inspections are carried out by WSAs over a twelve-month period
starting in July 2013 (Table 5). Following a review of the plan in 2014, it is anticipated that this
minimum number will change. The success of the Plan will be reviewed by the EPA at intervals not
exceeding every 5 years and numbers of inspections adjusted accordingly to ensure that the desired
environmental outcomes are being achieved.
In addition to risk based inspections, WSAs will undertake inspections of DWWTSs based on local
priorities arising from incidents; water quality information; WFD; Good Agricultural Practice;
catchment protection; water protection; other routine inspections and proxy inspections as
appropriate. Having regard to the multiplicity of inspection types, the WSA should keep in mind that
a single inspection may satisfy multiple environmental quality objectives, e.g. the impact of a
DWWTS on freshwater pearl mussel catchments and high status river catchment. It is anticipated
that these inspections will significantly add to the overall number of inspections relating to the
impact of DWWTSs.
Table 5: Minimum national allocation of risk-based domestic waste water system inspections per
county
County
Minimum number of inspections
Carlow
12
Cavan
48
Clare
55
Cork
99
Donegal
80
Dublin
15
Galway
98
Kerry
57
Kildare
25
Kilkenny
31
Laois
26
Leitrim
29
Limerick
50
Longford
17
Louth
18
Mayo
47
Meath
40
Monaghan
33
Offaly
16
Roscommon
33
Sligo
26
Tipperary
39
Waterford
16
Westmeath
14
Wexford
53
Wicklow
25
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National Inspection Plan
A comparison between counties
There is huge variation in the distribution of the risk categories on a national and county level. As
such it does not automatically follow that the number of inspections to be carried out in each county
will be in direct proportion to its size. A county with large areas of poor percolation, high
groundwater vulnerability, and a high density of DWWTSs will require more inspections than a
similar-sized county dominated by good percolation, low groundwater vulnerability and a low
density of DWWTSs. These and other factors were taken into account during the risk assessment and
a summary is given in Table A.3 in Appendix A.
A comparison between Counties Cavan and Waterford is shown here to illustrate the allocation of
risk-based inspections. These two counties are approximately the same size, but Cavan has been
allocated three times more risk-based inspections than Waterford.
Maps 4 and 5 below show the ‘Risk ranking map combined with Areas of Special Interest Map’ for
Counties Cavan and Waterford. Waterford has 36 times more area in sensitive receptor catchments
than Cavan, so it might be expected that Waterford would be allocated more inspections. However,
most of this area (89%) is in the low risk category. Cavan has six times more area in high and very
high risk categories than Waterford.
The comparison demonstrates that the major factor determining the number of inspections is the
area of the county in high and very high risk categories. Sensitive receptors in high and very high risk
areas require the most focus and therefore have the greatest weighting applied. Sensitive receptors
in low risk areas remain at low risk, despite their designation, due to the combination of factors (e.g.
good percolation, low groundwater vulnerability, low density of DWWTSs) that determined that the
risk to any receptor in that area from DWWTSs is low.
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National Inspection Plan
Map 4: Risk ranking map combined with Areas of Special Interest Map for County Cavan
Map 5: Risk ranking map combined with Areas of Special Interest Map for County Waterford
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National Inspection Plan
Selection of Inspection Sites
The EPA will provide site selection training for WSAs, which will include the allocation of inspection
numbers in line with the risk based approach. Each WSA will be given access via the EPA’s web-
based portal EDEN to relevant GIS datasets. The steps for selecting a site are shown in Figure 7.
Examine risk zone map
and check the number of •The EPA will provide
access to maps and
inspections required in
GIS datasets
each zone.
•This selection should
be based on local
Select the priority areas
knowledge such as
for inspection within
information on
each zone.
locations with
known pollution and
density of housing
Select the sites for
•When choosing sites
inspection within the
to inspect, priority
should be given to
priority area.
unregistered sites.
Figure 7: Site selection
Conducting a site inspection
The
Water Services Act 2007 (Registration and Inspections) Regulations 2012 (S.I. No. 384) sets out
the content of an inspection and the requirements for the appointment of inspectors. The EPA is
assigned the responsibility of appointing inspectors for the purposes of inspection of DWWTSs under
the Act.
The WSA will notify the owner 10 days in advance of the inspection. Specially trained local authority
inspectors will carry identification and will check that the treatment system, as constructed, is fit for
purpose and is not giving rise to a risk to public health or the environment.
The inspections will determine compliance with the
Water Services (Amendment) Act 2012 and
associated regulations and in particular the
Water Services Acts 2007 and 2012 (Domestic Waste
Water Treatment Systems) Regulations 2012 (S.I. 223 of 2012). The inspector will check:
whether the system is registered;
if it is leaking;
if the system components are in working order;
if effluent is ponding on the surface of the ground;
if it is discharging direct to surface water without a licence;
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National Inspection Plan
if rainwater or clean surface water is entering the system;
whether the system is being properly operated and maintained;
if the system has been de-sludged; and
if the system is being managed in a manner that does not adversely affect the
environment.
General information relating to the site conditions will be gathered to inform the inspector’s
decision relating to compliance with Regulation S.I. No. 223. In addition, information on private wells
will be gathered to inform guidance that will be provided to the owner on the proper construction,
protection and operation of these wells.
Figure 8: Screenshot of the ‘What to expect from an inspection’ animation on the EPA website
Inspection Form
The DWWTS Inspection form is made up of three distinct sections:
1.
General details relating to the DWWTS site and attached properties;
2.
Site assessment details; and
3.
Compliance questions which are based upon Regulation S.I. No. 223 and will
determine whether or not there is evidence to indicate that the DWWTS is posing a
risk to human health or the environment.
As part of completing the inspection form, the inspector may capture photographic evidence
illustrating issues or problems with the site. A copy of the pro-forma inspection template report will
be made available to the public on the EPA website.
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National Inspection Plan
During the inspection, water services staff will provide the owner with some basic information on
managing septic tank-type systems and why it is important to manage their system in order to
prevent contamination and protect human health. Further information is also available on
www.epa.ie.
After the Inspection
The owner will be notified about the findings of the inspection within 21 days. If the system is
deemed to pose a risk to either public health or the environment the WSA will issue an Advisory
Notice within 21 days. Examples of sites likely to require remediation are shown in Figure 9.
Figure 9: Sites liable to require remediation
The WSA must issue an Advisory Notice (see example in Appendix B) where the inspection identifies
that the treatment system has contravened the
Water Services Acts 2007 and 2012 (Domestic Waste
Water Treatment Systems) Regulations 2012 (S.I. No. 223 of 2012). The main provisions of the
Advisory Notice will:
State that the owner of the premises has contravened regulations;
State that the domestic waste water treatment system constitutes a risk to human
health or the environment;
State the reasons for that opinion; and
Direct the owner to remedy the matters specified in the notice by a specified date.
The Advisory Notice will not specify the exact remedial works to be undertaken. As each case is site
specific the owner of the DWWTS may be required to seek expert technical advice. The owner of the
DWWTS in receipt of an Advisory Notice may seek to have their system re-inspected for a fee of €20.
The Advisory Notice may be confirmed, amended or cancelled as a result of the re-inspection.
Where a time extension is required by the owner for valid reasons they may apply to the WSA for
such an extension. In exceptional circumstances where an Advisory Notice has been issued it may be
appealed to the District Court on the grounds that the appellant is not the person on whom the
notice should have been served or any substantive or procedural illegality.
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National Inspection Plan
Chapter 7 – Implementing and reviewing the plan
Implementation of the plan
The implementation of this plan will be carried out by Water Services Authorities. Each authority
will be responsible for ensuring that inspections and the engagement strategies for their functional
areas are carried out, as previously discussed.
The public awareness campaign is underway and will continue after site inspections commence.
Inspections will begin in July 2013. Water Service Authorities should develop a schedule for carrying
out the risk based inspections.
Domestic Waste Water Application (DWWA) System
An Information Technology system (DWWA) has been developed by the EPA for use by Water
Services Authorities and the EPA (Figure 10). The system will capture all information relating to
DWWTS inspections for the dual purpose of ensuring a consistent approach to inspections
throughout the country and reducing the administrative overhead of reporting to the EU under
Water Framework Directive Programme of Measures and Recommended Minimum Criteria for
Environmental Inspections.
Figure 10: Screenshot of the DWWA system
The system is made up of a number of elements, each related to a distinct part of the legislation:
1. Register of Inspectors
The system will enable the appointment of inspectors and the maintenance of a register of
inspectors, which will be available to the public.
2. DWWTS Inspections
Inspectors appointed to the Register will be able to submit information gathered as part of
the DWWTS inspections. The system will produce a report detailing the findings of the
inspection which can be issued to the owner by the WSA.
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National Inspection Plan
Where the inspection has found evidence to show that the DWWTS contravenes the
relevant regulations, the system will allow the WSA to compile and issue an Advisory Notice.
This Advisory Notice, along with the inspection report, will be issued to the owner.
3. WebGIS
A WebGIS and WebGIS functionality will be made available to users of the system: to assist
WSAs in the planning and scheduling of the DWWTS inspections; and to log the location of
inspected DWWTS and link it to associated properties.
The WSA can use the WebGIS to view all of the layers showing the geographical distribution
of risk from pollutants to surface waters and groundwater alongside layers showing the
locations of sensitive receptors. As inspections are completed, the location of the inspected
DWWTS along with whether or not it is compliant will also be indicated in this WebGIS.
4. Reporting
As inspections are submitted by inspectors, the system will log the numbers and outcomes
of each inspection, which will be used by the EPA for EU reporting requirements under WFD
and RMCEI.
Progress and Quality Reporting
The data collated within the DWWA will allow individual WSAs to track the progress of their own
inspection schedules against what is expected in the National Inspection Plan. At a national level,
the EPA will also be able to produce progress reports detailing the number of inspections that have
been carried out nationally, by each WSA and the progress made against the Plan. Data collected
may also be used to identify priority issues for enforcement in addition to refining the risk
assessment methodology, as appropriate. Data on the quality of inspections will allow monitoring of
the consistency of DWWTS inspections. The implementation of the plan will be subject to regulatory
oversight by the EPA.
Review of the Plan
Section 70K. (3) of the
Water Services (Amendment) Act 2012 sets out the legislative requirements
for reviewing the Plan. In particular it provides that:
‘
The Agency shall from time to time as it thinks appropriate, and at least once in each period of 5
years after the date of making the national inspection plan, review the plan and make such revisions
thereto as it thinks fit and reference in this Part to such a plan, shall unless the context otherwise
requires, be construed as including references to such a plan as so revised’.
The EPA proposes to undertake a review of the National Inspection Plan, i.e. a review of the
awareness campaign and first series of inspections, in 2014. The primary purpose of the review will
be to ensure that the strategies implemented are successful and effective in protecting human
health and the environment and allow for any modifications where these are deemed necessary.
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National Inspection Plan
Section 70I of the 2012 Act provides for the supervision by the EPA of the performance of Water
Services Authorities. In evaluating the performance of the WSA, the EPA may review:
The quality, quantity and proper recording of inspections;
The quality of the awareness campaign (i.e. citizen engagement);
Progress on achieving compliance with targets set in the Water Framework Directive;
Adequacy of sludge infrastructure and its management;
Enforcement of functions assigned under the Sanitary Services Acts, 2007 & 2012, Waste
Management Acts and related legislation.
Where the EPA is of the opinion that a Water Services Authority has failed to perform its functions, it
may issue a direction to the Water Services Authority. Failure to comply with such a direction is an
offence. Each WSA should on an annual basis review its performance with respect to the number of
inspections allocated to it in the Plan and the number of additional inspections carried out. Where
inspections targets are not achieved the reasons for this should be documented as part of this
review of performance.
This National Inspection Plan relies on changing behaviour and recognition by home owners that
water and domestic waste water treatment systems are a health and environment issue. The Plan
envisages periodic checks to reinforce this message and target inspections in areas in need of
greatest protection. The Plan is integrated into the Water Framework Directive River Basin
Management Planning to maintain and where necessary improve water quality with the
consequential benefit to public health. The review will ensure that the objectives of the Plan are
being met.
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National Inspection Plan
References
CEC (1975)
Council Directive of 15 July 1975 on waste (75/442/EEC). Council of the European
Communities. OJ L 194.
CEC (2000)
Council Directive 2000/60/EC of the European Parliament and of the Council of 23
October 2000 establishing a framework for Community action in the field of water policy.
Council of the European Communities. OJ L 327.
CEC (2001)
Recommendation of the European Parliament and of the Council of 4 April 2001 providing
for minimum criteria for environmental inspections in the Member States. Council of the
European Communities. OJ L 118.
CEC (2012): River Basin Management Plans report on the Implementation of the Water Framework
Directive (2000/60/
EC) COM(2012)670 of 14.11.2012.
CSO (2012)
Census 2011 Profile 4 The Roof over our Heads - Housing in Ireland, Central Statistics
Office, Skehard Road, Cork, Ireland.
DoELG Department of Environment and Local Government (1977).
Local Government (Water
Pollution) Act, 1977. Government Publications Office, Dublin, Ireland.
DoELG Department of Environment and Local Government (1990).
Local Government (Water
Pollution) (Amendment) Act, 1990. Government Publications Office, Dublin, Ireland.
DoEHLG Department of Environment, Heritage and Local Government (2007)
Water Services Act, No.
30 of 2007. Government Publications Office, Dublin 2, Ireland.
DoEHLG Department of Environment, Heritage and Local Government (2008)
Bathing Water Quality
Regulations, Statutory Instrument No. 79 of 2008. Government Publications Office, Dublin 2,
Ireland.
DoEHLG Department of Environment, Heritage and Local Government (2009).
European
Communities Environmental Objectives (Fresh Water Pearl Mussel) Regulations, Statutory
Instrument No. 296 of 2009. Department of Environment, Heritage and Local Government.
DoECLG Department of Environment, Community and Local Government (2012).
Water Services
(Amendment) Act, No. 2 of 2012. Government Publications Office, Dublin 2, Ireland.
DoECLG Department of Environment, Community and Local Government (2012).
Water Services Acts
2007 and 2012 (Domestic Waste Water Treatment Systems) Regulations 2012. Statutory
Instrument No. 223 of 2012. Government Publications Office, Dublin 2, Ireland.
EPA (2009)
Code of Practice: Wastewater Treatment and Disposal Systems Serving Single Houses
(p.e. ≤ 10). Environmental Protection Agency, Wexford.
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National Inspection Plan
EPA (2013)
An Environmental Risk Based Methodology to assist in the prioritisation of the inspection
of Domestic Waste Water Treatment Systems.
Environmental Protection Agency, Wexford.
Gill, L., Ó Súilleabháin, C., Johnston, P. and Misstear, B. (2005).
An investigation into the performance
of subsoils and stratified sand filters for the treatment of waste water from on-site systems.
(2001-MS-15-M1) Synthesis Report. Prepared for EPA by The Environmental Engineering
Group, TCD.
Macler, B.A., Merkle, J.C. (2000).
Current knowledge on groundwater microbial pathogens and their
control. Hydrogeology Journal, 8(1), 29-40.
Ó Súilleabháin, C. (2004).
The Attenuation Capacity of Subsoils Receiving Domestic Wastewater
Effluent. PhD Dissertation, Department of Civil, Structural and Environmental Engineering,
Trinity College Dublin.
USEPA (2002).
Onsite Wastewater Treatement Systems Manual. US Environmental Protection
Agency, Office of Water: Washington.
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National Inspection Plan
Glossary
Advanced Waste Water Treatment System: It is a term that encompasses secondary and/or tertiary
treatment systems.
Aquifer: Any stratum or combination of strata that stores or transmits groundwater.
Aquifer Category: Based on the hydrogeological characteristics and on the value of the groundwater
resource, all of the Republic of Ireland’s land surface is divided into nine aquifer categories (also
described as resource protection areas).
Attenuation: Reduction in mass or concentration of a compound in groundwater over time or
distance from the source due to naturally occurring physical, chemical, and biological processes.
Biochemical Oxygen Demand (BOD): BOD is a measure of the rate at which micro-organisms use
dissolved oxygen in the biochemical breakdown of organic matter in waste waters under aerobic
conditions. The BOD5 test indicates the organic strength of a waste water and is determined by
measuring the dissolved oxygen concentration before and after the incubation of a sample at 20°C
for 5 days in the dark. An inhibitor may be added to prevent nitrification from occurring.
Chemical Oxygen Demand (COD): COD is a measure of the amount of oxygen consumed from a
chemical oxidising agent under controlled conditions. The COD is greater than the BOD as the
chemical oxidising agent will often oxidise more compounds than micro-organisms.
Domestic Waste Water: The
Water Services Act 2007 defines domestic waste water as
waste water
of a composition and concentration (biological and chemical) normally discharged by a household,
and which originates predominantly from the human metabolism or from day to day domestic type
human activities, including washing and sanitation, but does not include fats, oils, grease or food
particles discharged from a premises in the course of, or in preparation for, providing a related
service or carrying on a related trade.
Domestic Waste Water Treatment System (DWWTS): Water Services (Amendment) Act defines a
domestic waste water treatment system as:
‘
a system involving physical, chemical, biological or thermal processes, or a combination of such
processes, utilised for the treatment or disposal of domestic waste water, or the sludge derived from
domestic waste water, and includes –
(a) all septic tanks and waste water tanks and systems receiving, storing, treating or disposing
of domestic waste water and all drains associated with such tanks or systems, and
(b) all drains associated with the discharge of domestic waste water, whether or not they
discharge to a septic tank or waste water tank’.
Environmental Data Exchange Network (EDEN): An EPA web-portal used by local authority Water Services
Authorities (WSAs) for reporting and managing compliance.
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National Inspection Plan
Eutrophication: The enrichment of water by nutrients, especially compounds of nitrogen and/or
phosphorus, causing an accelerated growth of algae and higher forms of plant life to produce an
undesirable disturbance to the balance of organisms present in the water and to the quality of the
water concerned.
Geographical Information System (GIS): A GIS is a system designed to capture, store, manipulate,
analyse, manage, and present all types of geographical data.
Infiltration: The process by which water on the ground surface enters soil.
Infiltration system: Comprises percolation areas and polishing filters that discharge partially treated
and treated effluent into the ground.
Organic Matter: Mainly composed of proteins, carbohydrates and fats. Most of the organic matter in
domestic waste water is biodegradable. A measure of the biodegradable organic matter can be
obtained using the BOD test.
Ortho-phosphorus: Ortho-phosphorus is soluble reactive phosphorus and is readily available for
biological uptake.
Pathogenic Organisms: Those potential disease-producing micro-organisms which can be found in
domestic waste waters. Organisms, such as Escherichia coli and faecal streptococci, with the same
enteric origin as the pathogens are used to indicate whether pathogens may be present or not in the
waste water.
Percolation: The slow passage of liquid through a filtering medium.
Percolation area: A system consisting of trenches with pipes and gravel aggregates, installed for the
purpose of receiving waste water from a septic tank or other treatment device and transmitting it
into soil for final treatment and disposal.
Programmes of Measures (POMs): The Water Framework Directive requires that a programme of
measures for improving water quality be developed and implemented.
Septage: Liquid, solid, or semi-solid material removed from a septic tank.
Septic Tank System: A waste water treatment system that includes a septic tank mainly for primary
treatment, followed by a percolation system in the soil providing secondary and tertiary treatment.
Source Protection Zone: A source protection zone is generated by integrating the two elements of
land surface zoning (SPA and vulnerability) – a possible total of eight source protection zones can be
generated.
Strategic Environmental Assessment (SEA): SEA is the process by which environmental
considerations are required to be fully integrated into the preparation of Plans and Programmes and
prior to their final adoption. The requirement for SEA derives from the SEA Directive (2001/42/EC).
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National Inspection Plan
Subsoil Permeability: The permeability of subsoil is largely a function of (a) the grain size
distribution, (b) the amount (and sometimes type) of clay size particles present, and (c) how the
grains are packed together.
Suspended Solids (SS): Includes all suspended matter, both organic and inorganic. Along with the
BOD concentration, SS is commonly used to quantify the quality of waste water.
Tertiary Treatment: Additional treatment processes which result in further purification than that
obtained by applying primary and secondary treatment.
Total Nitrogen: Mass concentration of the sum of Kjeldahl (organic and ammonium nitrogen),
nitrate and nitrite nitrogen.
Total Phosphorus: Mass concentration of the sum of organic and inorganic phosphorus.
Waste Water: The discharge from sanitary appliances, e.g. toilets, bathroom fittings, kitchen sinks,
washing machines, dishwashers, showers.
Waste Water Sludge: The solids that settle in the bottom of the primary/secondary settlement tank.
Water Services Authority: a County Council or a City Council: subject to such exceptions as may be
prescribed, and where the context permits, any reference to a sanitary authority or local authority in
any legislation, in so far as it relates to functions of that authority in relation to water services, shall
be regarded as a reference to a water services authority.
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National Inspection Plan
Appendix A: Tables for allocation of risk based inspections
Table A.1: Area of each county in each risk category
Total Area (km2)
Catchment Areas of Sensitive Receptors (km2)
Total
Zone 1
Zone 2
Zone 3
Zone 4
Total
Zone 1B
Zone 2B
Zone 3B
Zone 4B
Low
Moderate
High
Very High
Low
Moderate
High
Very High
National
66976
42214
7568
4633
12560
14534
10374
1486
873
1801
Carlow
880
545
144
67
125
265
175
43
21
25
Cavan
1852
440
215
229
968
14
8
1
1
5
Clare
3106
2010
423
253
419
1874
1295
245
133
201
Cork
7279
5227
858
426
768
2718
1894
323
191
311
Donegal
4707
2842
463
334
1068
1218
821
108
74
216
Dublin
531
166
35
28
303
66
31
9
3
23
Galway
5808
3866
588
350
1004
2613
1822
255
161
375
Kerry
4623
3173
481
271
698
939
827
37
32
42
Kildare
1629
916
195
110
408
87
65
8
4
10
Kilkenny
2033
1088
363
189
392
222
150
36
16
21
Laois
1700
1145
216
122
218
879
659
101
48
71
Leitrim
1494
630
199
192
473
135
69
16
18
31
Limerick
2631
1213
357
297
764
186
100
24
18
45
Longford
1026
511
145
90
281
16
12
1
1
1
Louth
772
259
108
62
343
62
10
5
4
43
Mayo
5254
4201
488
232
333
988
830
77
39
42
Meath
2246
1163
228
154
700
22
4
3
1
14
Monaghan
1252
281
174
176
622
83
25
17
8
32
Offaly
1977
1559
176
90
152
68
54
7
3
4
Roscommon
2424
1501
314
207
402
366
272
38
16
39
Sligo
1772
1066
193
152
361
206
128
19
16
43
Tipperary
4200
3246
436
207
310
279
221
33
11
14
Waterford
1809
1475
133
58
144
499
444
21
10
24
Westmeath
1714
1356
163
76
118
11
8
2
1
0
Wexford
2301
932
283
163
923
263
100
25
24
114
Wicklow
1956
1406
190
100
261
456
349
33
20
54
Table A.2: Number of Inspections per risk area based on national allocation of 1,000 inspections
Outside catchment areas of sensitive receptors
Inside catchment areas of sensitive receptors
Overall
Zone 1A
Zone 2A
Zone 3A
Zone 4A
Zone 1B
Zone 2B
Zone 3B
Zone 4B
Total
Low
Moderate
High
Very High
Low
Moderate
High
Very High
Carlow
12
1
1
1
4
1
1
1
2
Cavan
48
2
3
5
38
0
0
0
0
Clare
55
3
2
3
9
10
6
6
16
Cork
99
13
6
6
18
15
8
9
24
Donegal
80
8
4
6
33
6
3
3
17
Dublin
15
1
0
1
11
0
0
0
2
Galway
98
8
4
4
25
14
6
8
29
Kerry
57
9
5
6
26
6
1
1
3
Kildare
25
3
2
2
16
1
0
0
1
Kilkenny
31
4
4
4
14
1
1
1
2
Laois
26
2
1
2
6
5
2
2
6
Leitrim
29
2
2
4
17
1
0
1
2
Limerick
50
4
4
7
28
1
1
1
4
Longford
17
2
2
2
11
0
0
0
0
Louth
18
1
1
1
12
0
0
0
3
Mayo
47
13
5
5
11
6
2
2
3
Meath
40
5
3
4
27
0
0
0
1
Monaghan
33
1
2
4
23
0
0
0
3
Offaly
16
6
2
2
6
0
0
0
0
Roscommon
33
5
3
4
14
2
1
1
3
Sligo
26
4
2
3
12
1
0
1
3
Tipperary
39
12
5
5
12
2
1
1
1
Waterford
16
4
1
1
5
3
0
0
2
Westmeath
14
5
2
2
5
0
0
0
0
Wexford
53
3
3
3
32
1
1
1
9
Wicklow
25
4
2
2
8
3
1
1
4
Table A.3: Characteristics considered during risk assessment
Overall area
Minimum number of
% of county at
% of county with
% of county with
% of county with
DWWTS density
(km2)
inspections per
Very High Risk
Extreme
Very High
catchment areas
(number of
county (based on
Groundwater
Likelihood of
of Sensitive
systems per km2)
national total of
Vulnerability
Inadequate
Receptors
1,000*)
Percolation
Carlow
880
12
14
33
6
30
8
Cavan
1852
48
52
30
62
1
8
Clare
3106
55
13
54
26
60
6
Cork
7279
99
11
52
13
37
8
Donegal
4707
80
23
74
15
26
7
Dublin
531
15
57
28
40
12
24
Galway
5808
98
17
41
38
45
7
Kerry
4623
57
15
50
25
20
6
Kildare
1629
25
25
7
22
5
10
Kilkenny
2033
31
19
57
19
11
8
Laois
1700
26
13
29
10
52
7
Leitrim
1494
29
32
25
75
9
5
Limerick
2631
50
29
29
36
7
9
Longford
1026
17
27
13
40
2
7
Louth
772
18
44
23
30
8
15
Mayo
5254
47
6
29
19
19
5
Meath
2246
40
31
12
31
1
10
Monaghan
1252
33
50
32
46
7
10
Offaly
1977
16
8
4
22
3
6
Roscommon
2424
33
17
35
35
15
6
Sligo
1772
26
20
31
47
12
6
Tipperary
4200
39
7
32
5
7
6
Waterford
1809
16
8
32
7
28
7
Westmeath
1714
14
7
6
15
1
7
Wexford
2301
53
40
28
37
11
11
Wicklow
1956
25
13
63
10
23
6
*
Inspections numbers rounded to whole numbers for allocation purposes
National Inspection Plan
Appendix B: Example of Advisory Notice
Ref: DWPR00000xx
ADVISORY NOTICE
WATER SERVICES ACTS 2007 and 2012
NOTICE PURSUANT TO SECTION 70(H) OF THE WATER SERVICES ACT 2007 OF
FAILURE TO COMPLY WITH THE DUTIES OF OWNERS OF PREMISES CONNECTED TO
A DOMESTIC WASTE WATER TREATMENT SYSTEM AS SPECIFIED IN SECTION 70C(1)
OF THE ACT.
To:
[Name]
From:
[County Council]
County:
[County Name]
Address:
[Property Address]
WHEREAS the water services authority is of the opinion that the person to whom this notice is
addressed has failed to comply with a duty specified under section 70C(1) of the Water
Services Act 2007, namely:
1. The owner has contravened regulations made under section 70L of the Water Services
Act 2007, or
2. The domestic waste water treatment system constitutes, or is likely to constitute, a risk
to human health or the environment, and in particular - (i) creates a risk to water, or
soil, or to plants and animals, (ii) creates a nuisance through noise or odours, or (iii)
adversely affects the countryside or places of special interest.
CONNECTED PROPERTY
Address
[Property Address]
[Property Address]Multiple addresses if required
Townland
County
REASON FOR OPINION
#
Legislation Section Advisory Notice Reason
MEASURES REQUIRED
#
Measures
Details
Ref: DWPR00000xx
NOTICE IS HERE BY GIVEN that the matters specified above must be remedied by you by
[dd/mm/yyyy]
WATER SERVICES
AUTHORITY STAMP
Signed By:
Print Name:
Dated this day of 20
Ref: DWPR00000xx
IMPORTANT NOTES FOR THE PERSON ON WHOM THIS NOTICE IS SERVED
• It is an offence to fail to rectify matters specified in this advisory notice within the
specified timeframe.
• Inspections carried out, and advisory notices issued, under the Water Services Act
2007 do not provide exemption from prosecution for public health or environmental
offences under other legislation.
• You may, within 21 days of the issue of this notice, apply to the issuing water services
authority to have a re-inspection carried out by an authorised officer of the water
services authority. Your application must be (a) in writing and (b) accompanied by the
re-inspection fee of €20. The fee will be refunded if this advisory notice is cancelled as
a result of the re-inspection.
National Inspection Plan
Appendix C: Legislation
National Inspection Plan
Domestic Waste Water Legal Context
There are several pieces of European and national legislation which apply to domestic waste water
treatment systems. The principal ones are summarised in this section.
Waste Framework Directive (75/442/EC)
In October 2009, the European Court of Justice (ECJ) ruled that Ireland had not adopted legislation
to comply with Articles 4 and 8 of the
Council Directive on Waste 75/442/EEC (C-188/08). The Court
concluded that Ireland had failed to comply with its legal obligations relating to the regulation of
domestic waste water treatment systems and lacked, in particular, systematic periodic checks and
inspections of DWWTSs.
Article 4 of the Directive requires that: ‘
waste is recovered or disposed of without endangering
human health and without using processes or methods which could harm the environment and in
particular:
(a) without risk to water, air, soil and plants and animals,
(b) without causing a nuisance through noise or odours,
(c) without adversely affecting the countryside or places of special interest.’
Article 8 of the Directive provides that Member States:
‘shall take the necessary measures to ensure
that any holder of waste:
(a) has it handled by a private or public waste collector or by an undertaking which carries
out the operations listed in Annex II A or B, or
(b) recovers or disposes of it himself in accordance with the provisions of this Directive.’
Water Framework Directive (2000/60/EC)
The Water Framework Directive aims to improve water quality throughout the EU. It applies to
rivers, lakes, groundwater, and coastal waters. The Directive requires the preparation of
management plans on a river basin basis and it then requires a programme of measures for
improving water quality.
Water Services Act, 2007
The Water Services Act 2007 (No. 30 of 2007) places a ‘duty of care’ on the owner of a waste water
treatment system (Section 70) to ensure that ‘it is kept so as not to cause or be likely to cause a risk
to human health or the environment’. It also gives powers to a person authorised by the WSA to
direct the owner to take such measures as are considered necessary to deal with the risk.
Inspections other than the risk-based inspections set out in this Plan may be undertaken by
authorised persons under the Water Pollution Acts.
Water Services (Amendment) Act, 2012
The Water Services (Amendment) Act, 2012 (No. 2 of 2012) provides for the registration of domestic
waste water treatment systems, the preparation of a National Inspection Plan and the inspection
and remediation of treatment systems that are impacting on health or the environment.
National Inspection Plan
Section 70K of the
Water Services (Amendment) Act,
2012 requires the EPA to prepare a National
Inspection Plan for domestic waste water treatment systems and sets out the items to be considered
by the EPA when drawing up the Plan. WSAs are required to give effect to the Plan and failure to do
so is an offence. The legislation also makes provision for the revision of the Plan.
The standards that domestic waste water treatment systems shall meet are set out in the
Water
Services Acts 2007 and 2012 (Domestic Waste Water Treatment Systems) Regulations 2012 (S.I. No.
223 of 2012). These regulations were published in June 2012 following a public consultation process
by the DoECLG. The regulations prescribe the actions to be taken by owners of domestic waste
water treatment systems to ensure compliance with their obligations under Section 70(C)(1) of the
Water Services (Amendment) Act 2012.
An Ghníomhaireacht um Chaomhnú Comhshaoil
Is í an Gníomhaireacht um Chaomhnú
RIALÚ ASTUITHE GÁIS CEAPTHA TEASA NA HÉIREANN
Comhshaoil (EPA) comhlachta reachtúil a
Cainníochtú astuithe gáis ceaptha teasa na
chosnaíonn an comhshaol do mhuintir na tíre
hÉireann i gcomhthéacs ár dtiomantas Kyoto.
go léir. Rialaímid agus déanaimid maoirsiú ar
Cur i bhfeidhm na Treorach um Thrádáil Astuithe, a
ghníomhaíochtaí a d'fhéadfadh truailliú a
bhfuil baint aige le hos cionn 100 cuideachta atá
chruthú murach sin. Cinntímid go bhfuil eolas
ina mór-ghineadóirí dé-ocsaíd charbóin in Éirinn.
cruinn ann ar threochtaí comhshaoil ionas go
nglactar aon chéim is gá. Is iad na príomh-
TAIGHDE AGUS FORBAIRT COMHSHAOIL
nithe a bhfuilimid gníomhach leo ná
Taighde ar shaincheisteanna comhshaoil a
comhshaol na hÉireann a chosaint agus
chomhordú (cosúil le caighdéan aeir agus uisce,
cinntiú go bhfuil forbairt inbhuanaithe.
athrú aeráide, bithéagsúlacht, teicneolaíochtaí
Is comhlacht poiblí neamhspleách í an
comhshaoil).
Ghníomhaireacht um Chaomhnú Comhshaoil
(EPA) a bunaíodh i mí Iúil 1993 faoin Acht
MEASÚNÚ STRAITÉISEACH COMHSHAOIL
fán nGníomhaireacht um Chaomhnú
Ag déanamh measúnú ar thionchar phleananna agus
Comhshaoil 1992. Ó thaobh an Rialtais, is í
chláracha ar chomhshaol na hÉireann (cosúil le
an Roinn Comhshaoil, Pobal agus Rialtais
pleananna bainistíochta dramhaíola agus forbartha).
Áitiúil.
PLEANÁIL, OIDEACHAS AGUS TREOIR CHOMHSHAOIL
ÁR bhFREAGRACHTAÍ
Treoir a thabhairt don phobal agus do thionscal ar
cheisteanna comhshaoil éagsúla (m.sh., iarratais ar
CEADÚNÚ
cheadúnais, seachaint dramhaíola agus rialacháin
Bíonn ceadúnais á n-eisiúint againn i gcomhair na nithe
chomhshaoil).
seo a leanas chun a chinntiú nach mbíonn astuithe uathu
Eolas níos fearr ar an gcomhshaol a scaipeadh (trí
ag cur sláinte an phobail ná an comhshaol i mbaol:
cláracha teilifíse comhshaoil agus pacáistí
áiseanna dramhaíola (m.sh., líonadh talún,
acmhainne do bhunscoileanna agus do
loisceoirí, stáisiúin aistrithe dramhaíola);
mheánscoileanna).
gníomhaíochtaí tionsclaíocha ar scála mór (m.sh.,
déantúsaíocht cógaisíochta, déantúsaíocht
BAINISTÍOCHT DRAMHAÍOLA FHORGHNÍOMHACH
stroighne, stáisiúin chumhachta);
Cur chun cinn seachaint agus laghdú dramhaíola trí
diantalmhaíocht;
chomhordú An Chláir Náisiúnta um Chosc
úsáid faoi shrian agus scaoileadh smachtaithe
Dramhaíola, lena n-áirítear cur i bhfeidhm na
Orgánach Géinathraithe (GMO);
dTionscnamh Freagrachta Táirgeoirí.
mór-áiseanna stórais peitreail;
Cur i bhfeidhm Rialachán ar nós na treoracha maidir
scardadh dramhuisce.
le Trealamh Leictreach agus Leictreonach Caite agus
le Srianadh Substaintí Guaiseacha agus substaintí a
dhéanann ídiú ar an gcrios ózóin.
FEIDHMIÚ COMHSHAOIL NÁISIÚNTA
Plean Náisiúnta Bainistíochta um Dramhaíl
Stiúradh os cionn 2,000 iniúchadh agus cigireacht
Ghuaiseach a fhorbairt chun dramhaíl ghuaiseach a
de áiseanna a fuair ceadúnas ón nGníomhaireacht
sheachaint agus a bhainistiú.
gach bliain.
Maoirsiú freagrachtaí cosanta comhshaoil údarás
STRUCHTÚR NA GNÍOMHAIREACHTA
áitiúla thar sé earnáil - aer, fuaim, dramhaíl,
dramhuisce agus caighdeán uisce.
Bunaíodh an Ghníomhaireacht i 1993 chun comhshaol
Obair le húdaráis áitiúla agus leis na Gardaí chun
na hÉireann a chosaint. Tá an eagraíocht á bhainistiú
stop a chur le gníomhaíocht mhídhleathach
ag Bord lánaimseartha, ar a bhfuil Príomhstiúrthóir
dramhaíola trí comhordú a dhéanamh ar líonra
agus ceithre Stiúrthóir.
forfheidhmithe náisiúnta, díriú isteach ar chiontóirí,
Tá obair na Gníomhaireachta ar siúl trí ceithre Oifig:
stiúradh fiosrúcháin agus maoirsiú leigheas na
An Oifig Aeráide, Ceadúnaithe agus Úsáide
bhfadhbanna.
Acmhainní
An dlí a chur orthu siúd a bhriseann dlí comhshaoil
An Oifig um Fhorfheidhmiúchán Comhshaoil
agus a dhéanann dochar don chomhshaol mar
An Oifig um Measúnacht Comhshaoil
thoradh ar a ngníomhaíochtaí.
An Oifig Cumarsáide agus Seirbhísí Corparáide
MONATÓIREACHT, ANAILÍS AGUS TUAIRISCIÚ AR
AN GCOMHSHAOL
Tá Coiste Comhairleach ag an nGníomhaireacht le
Monatóireacht ar chaighdeán aeir agus caighdeáin
cabhrú léi. Tá dáréag ball air agus tagann siad le chéile
aibhneacha, locha, uiscí taoide agus uiscí talaimh;
cúpla uair in aghaidh na bliana le plé a dhéanamh ar
leibhéil agus sruth aibhneacha a thomhas.
cheisteanna ar ábhar imní iad agus le comhairle a
thabhairt don Bhord.
Tuairisciú neamhspleách chun cabhrú le rialtais
náisiúnta agus áitiúla cinntí a dhéanamh.
Headquarters, PO Box 3000
Johnstown Castle Estate
County Wexford, Ireland
Ceanncheathrú, Bosca Poist 3000
Eastát Chaisleán Bhaile Sheáin
Contae Loch Garman, Éire
T:+353 53 916 0600
F:+353 53 916 0699
Regional Inspectorate
McCumiskey House, Richview
Clonskeagh Road, Dublin 14, Ireland
Cigireacht Réigiúnach, Teach Mhic Chumascaigh
Dea-Radharc, Bóthar Cluain Sceach
Baile Átha Cliath 14, Éire
T:+353 1 268 0100
F:+353 1 268 0199
Regional Inspectorate
Inniscarra, County Cork, Ireland
Cigireacht Réigiúnach, Inis Cara
Contae Chorcaí, Éire
T:+353 21 487 5540
F:+353 21 487 5545
Regional Inspectorate
John Moore Road, Castlebar
County Mayo, Ireland
Cigireacht Réigiúnach, Bóthar Sheán de Mórdha
Caisleán an Bharraigh, Contae Mhaigh Eo, Éire
T:+353 94 904 8400
F:+353 94 902 1934
Regional Inspectorate
Seville Lodge, Callan Road,
Kilkenny, Ireland
Cigireacht Réigiúnach, Lóiste Sevilla,
Bóthar Challainn, Cill Chainnigh, Éire
T:+353 56 779 6700
F:+353 56 779 6798
Regional Inspectorate
The Glen, Monaghan, Ireland
Cigireacht Réigiúnach, An Gleann
Muineachán, Éire
T:+353 47 77600
F:+353 47 84987
E: xxxx@xxx.xx
W: www.epa.ie
Lo Call: 1890 33 55 99
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