CARLOW COUNTY COUNCIL
COMHAIRLE CHONTAE CHEATHAKLOCHA
19'~November 2009
Ms Ewa Babiarczyk, Inspector, Office of Climate, Licensing and Resource Use, Environmental Protection Agency, Headquarters, PO Box 3000, Johnstown Castle Estate, Countv Wexford
RE: Wastewater Discharrre Licence Application for the Amlomeration ofHacketistown
Dear Ms Babiarczyk
I refer to the above and to your correspondence dated 29~July, 2009 seeking further information in For inspection purposes only. relation to the application for aConsent discharge of copyright licence owner required for the for any Hackettstown other use. Wastewater Works.
Enclosed are the responses to the issues raised.
Should you have any query regarding the above please do not hesitate to contact me on 059 9136263.
Yours sincerely
carloul through the wdters of tsme
EPA Export 26-07-2013:16:43:22 For inspection purposes only. Consent of copyright owner required for any other use.
EPA Export 26-07-2013:16:43:22 1. Section B.l
Hackettstown is the name of the agglomeration that this Waste Water Application refers to. Hackettstown is the only settlement within the Agglomeration.
The Hackenstown Waste Water Treatment Plant is the only Waste Water Treatment Plant within the Agglomeration.
2. Section B.4
There is no Secondary Discharge Point within the Agglomeration.
3. Section B.9
The loading to the Hackettstown Waste Water Treatment Plant was estimated to be 1,100 pe by the Consultants, Mott McDonald Penit who are preparing the Preliminary Report for the Hackettstown Sewerage Scheme for Carlow County Council by means of a flow and load survey.
The WWTP is designed to treat a P.E. of 600 so it is currently overloaded.
Carlow County Council do not except to see any additional loadings to the WWTP for the next two years, up to 2012.
Mott MacDonalds in preparing the report took account of all maximum flows that could occur
Mott McDonald Pettit who are preparing the Preliminary Report for the Hackettstown Sewerage Scheme for Carlow County Council For estimate inspection purposes a future only. loading of 3,200 pe by 2031. Consent of copyright owner required for any other use.
This would be 88% Domestic and 12% Non -Domestic.
4. Section B.10 Capital Investment
The Preliminary Report will be submitted to the DEHLG by end of 2009.
However Carlow County Council have become very concerned with the poor state of the existing Hackettstown WWTP and the poor quality of the effluent from the WWTP into the River Dereen.
With this in mind Carlow County Council have made a submission to the DEHLG for funding for an Advanced Works Scheme to carry out immediate remedial works.
These advance works would involve the construction of a new 1,400pe WWTP on the site of the existing works.
Hacketstown Waste Water Works (Ref : D0243-01) Further Information
EPA Export 26-07-2013:16:43:22 This submission is currently with the DEHLG but if approval could be obtained the advanced works would be completed by the Q1 201 1.
5. Section C.l
The current works overflow to the River Dereen via the Primary Discharge in times of heavy storm flows. The overflow waters will have received no form of treatment.
The current storm overflow does not comply with guidelines laid down in the DEHLG "Procedures and Criteria in Relation to Storm Water Overflows".
The new storm overflow at the proposed Advanced Works will comply with "Procedures and Criteria in Relation to Storm Water Overflows" as per DEHLG.
The forward feed pumps pump on 3DWF for full treatment.
The Stormwater holding tank will be designed to hold a further 3DWF for 2 hours and then the effluent will overflow to the receiving waters. The water in the storm tank will have received screening and degritting prior to entering storm tank.
When the storm abates the storm water is pumped back to the forward feed pumps and then receives full treatment.
There are no pumping stations within the Agglomeration.
The current WWTP would on occasions overflow directly to the river due to blockages at the inlet screens and at the existing tanks.
The new proposed storm overflow willFor inspection be at purposesthe same only. pipe as the Primary Discharge Point for the proposed works which will beConsent the existing of copyright Primaryowner required Discharge for any other use. Point.
The new Storm Overflow is dependent on Carlow County Council receiving funding from the DEHLG.
In the optimum situation the new Storm Overflow could be operational by Q1, 201 1.
6. Section E.l
The new proposed storm overflow will be at the same pipe as the Primary Discharge Point for the proposed works which will be the existing Primary Discharge Point.
E296,341 N180,725
Haeketstown Waste Water Works (Ref: D0243-01) Further Information
EPA Export 26-07-2013:16:43:23 7. Section E.2 a) River Monitoring Programme EPA
The Treatment plant discharges into the River Derreen, which is a tributary of the River Slaney. The EPA llkenny Regional Laboratory canies out the chemical monitoring at 6 locations on the River Derreen in County Carlow. The downstream monitoring station is 0400 at Saulsford Bridge. Biological monitoring (Q value) is also carried out and is shown for 2004.
The chemical parameters sampled are for:
Temperature D.O. BOD Colow pH Conductivity Salinity Orthophosphate Ammonia Un-ionised ammonia Nitrite Nitrate Chloride Flow at some stations Colifonns at some stations.
These are summarised in the relevant section of the EPA River Water Quality Report in County
Cariow 2008 reporl which is attached. For inspection purposes only. Consent of copyright owner required for any other use.
b) Urban Wastewater Regulations Monitoring
In 2008 monitoring runs were carried out at Hacketstown Wastewater Treatment Works as follows:
Inlet (6), outlet (6), upstream (4), downstream (4). BOD, COD, Suspended Solids, Ammonia, Nitrate, Nitrite, Orthophosphate, Total Nitrogen, Total Phosphorus. The data in relation to the inlet and outlet monitoring is shown in Attachments E.3 and E.4. The data in relation to upstream and downstream monitoring is shown in Tables F.l(i)
Hacketstown Waste Water Works (Ref: D0243-01) Further Information 4
EPA Export 26-07-2013:16:43:23 c) Dangerous Substances Monitoring
For the purposes of the application dangerous substances monitoring was canied out at the following locations:
Outlet, upstream, downstream. Four sampling runs in the preceding 12 months prior to the application. Parameters as per Table F.l requirements. The data in relation to the plant outlet is shown in Annex 1. The data in relation to upstream and downstream monitoring is shown in Tables F. l(i). d) Drinking Water Abstraction Monitoring
There is no drinking water abstraction downstream on the receiving River Derreen and the nearest abstraction point on the River Slaney is located at Clonhasten upstream of Enniscorthy in Co Wexford. Wexford County Council abstract up to 5,000m3 a day at this location. e) Freshwater Fish Monitoring
The receiving River Derreen is not a designated Salmonid river, therefore there are no designated locations to be monitored. However, it is a tributary of the River Slaney which is a designated Salmonid river and monitoring is canied out by the Kilkemy EPA Regional Laboratory. f) Bathing Water Monitoring
No monitoring of bathing water designated locations was canied out in the 12 months preceding the application date. There are no designated locations. For inspection purposes only. Consent of copyright owner required for any other use.
8. Section E.4
The outlet quality requirement at Hacketstown WWTW as set out in the urban wastewater treatment regulations is as follows:
BOD = 25 mgll with 79%-90% reduction COD = 125 mg/l with 75% reduction SS = 35 mgll with 90% reduction
Monitoring for BOD, COD and SS for the 12 months preceding the application shows the following:
BOD: 0 results within the limit (6) COD: 2 results within the limit (6) SS: 2 results within the limit (6)
Hacketstown Waste Water Works (Ref: D0243-01) Further Information 2
EPA Export 26-07-2013:16:43:23 Qualitv Control Procedures
The EPA Kilkemy Regional laboratory cames out sampling and testing of river waters, freshwater fish programme and the drinking water abstraction programme.
Sampling required by the Urban Wastewater Regulations is camed out by Carlow County Council and analysis is camed out by T.E. Laboratories Ltd., INAB number 106T.
Sampling required by Dangerous Substances sections in the application is camed out by Carlow County Council and analysis is canied out by Environmental Laboratory Services, INAB number 11 IT.
9. Section F Appropriate Assessment
We attach an Appropriate Assessment for the Hackettstown Agglomeration and Appendix 8 Report on Mitigation Measures.
10. Section G.l Compliance with Council Directives
The existing WWTP for the Hackettstown Agglomeration is designed to treat the effluent from a Population Equivalent of 600. It is currently treating the Population Equivalent of 1,100 and is overloaded.
The WWTP is currently struggling with the incoming load and the final effluent is of a very poor quality. For inspection purposes only. Consent of copyright owner required for any other use.
Carlow County Council are currently progressing a scheme known as Tullow, Rathvilly, Hackettstown Sewerage Schemes through the WSIP. The Scheme is currently at Preliminary Report Stage and the P.R. will be submitted to the DEHLG before the end of 2009.
However due to the very poor performance of the Hackettstown WWTP at present, Carlow County Council are proposing to address the issue by fast forwarding Advance Works at the Hackettstown WWTP to improve the standard of the final effluent discharging into the River Dereen.
Carlow County Council are presently making an application to the DEHLG to fund these Advance Works.
The specification for the proposed works are:
BOD, 25mgll ss, 35mg/l Ammonia, 2.5mg/l Total P, 0.5mgll N 5mgll
Hacketstown Waste Water Works (Ref: D0243-01) Further Information
EPA Export 26-07-2013:16:43:23 Carlow County Council are proposing the following works:
The construction of a new WWTP with the capacity to treat 1,400pe.
The WWTP will consist of:
Inlet Works consisting of Screens and a Grit Classifier Forward Feed Pumps Balancing Tank Sequence Batch Reactor Storm Holding Tank Sludge Holding Tank Fenic Dosing Tertiary Treatment Outfall Chamber
Activated Sludge System
The SBR is a variable volume activated sludge system, which operates within a single reactor tank and does not require a separate secondary settlement tank.
The system operates in a time controlled cyclic mode which generally includes the following stages of operation.
o Fill o Aerate o Settlement o Decanting
o De-sludge For inspection purposes only. Consent of copyright owner required for any other use. o idle
ihe effluent then flows to a balancing tank and from here to sand filter for tertiary treatment.
Sludge is drawn off to a sludge holding tank.
Storm Water Treatment
The storm water overflow at the proposed Hackettstown WWTP will be designed in accordance with the guide lines laid down in DEHLG "Procedures and Criteria in Relation to Stonn Water Overflows", 1995.
The WWTP will pump on 3 DWF for full treatment. Flows in excess of 3DWF will go the Storm Holding which will hold 3DWF for 2 hours. Flows in excess of this will overflow to the River Dereen. However these overflows will have received screening, grit removal and a degree of primary settlement in the Storm Holding Tank.
Hacketstown Waste Water Works (Ref : D0243-01) Further Information I
EPA Export 26-07-2013:16:43:23 Outfall for storm water is via the Primary Discharge pipe discharging into the River Dereen at Grid Reference E296,341 N180,725.
Tertiary Treatment
The treated effluent will receive tertiary treatment via sand filtration. The treated efluent will flow unto the sand media and achieve filtration by flowing through the media.
The cleaning of the actual filter is performed by the sand washer, which continuously flushes the sand grains in the filter. An airlift sucks up sand from the bottom, where the grains are dirtiest, and feeds them into the sand washer. In the washer the dirt is separated from the grains of sand, partly through flushing, partly through fiction. The clean sand is then returned to the sand bed in an even layer at the surface.
Chemical Treatment
Phosphorous exists in three main forms in wastewater; ortho-phosphate, polyphosphate and organic phosphate. During aerobic treatment, the later two forms are converted to ortho- phosphate, which is the easiest form to precipitate using chemical addition.
Carlow County Council propose to remove phosphorous using Biological Treatment and a final polishing using chemical dosing of Fenic Sulphate. The Chemical Dosing location for the chemical precipitation of phosphorous shall be proposed at the aeration tank i.e. simultaneous precipitation, because polyphosphates and organic phosphorous are less easily removed than orthophosphorus. Adding Iron salts afier secondary treatment (where organic phosphorus and poly-phosphorus are transformed into orthophosphorus) results in the best removal of P.
For inspection purposes only. Consent of copyright owner required for any other use. Carlow County Council are very anxious to precede with these works in view of the poor quality final effluent being currently produced at the WWTP.
Carlow County Council hope to receive approval for the Advance Works in early 2010 and to commence works on site in the 44,2010.
Hacketstown Waste Water Works (Ref: D0243-01) Further Information o
EPA Export 26-07-2013:16:43:23 For inspection purposes only. Consent of copyright owner required for any other use.
EPA Export 26-07-2013:16:43:23 Code l4BOS
tion No. 0020 aurrat Rr (3km S of t4Yshall) .Ahr lor Carlaw Central Rsg VlS - lafesl Biological Qua1,fj Raling ( 2006 ) = Q4-5 3wR1 9 5.1 561 >;l$e 'i76 TCW 0 O JO 9 0 0 CJUU~ JH Cond Sas.:W >@no~ *T-~RIZ m.nn.amr *I*= )\Itale Jnlcide ;-Cali EC~, i,ovi T 9LSn 7yE Sl --nRP. Gi iiazec -SIC* :xWP ~~flh.,:~I,N!I~ xd, % z.z.~?h rFd C. I:oom -I(J:.y .5hsc ?113te ::'35 8.2 -1:. ? :7 '5 ?C 7t2 GS.01 0 1 3.03 00053 0.009 a.6 18 3 2 (13 a1 s:s~oq tin qtr:~~' tliorl Nu. 0100 Ul!-.(d st :B~RS~Ciinlwk 81 Oualirf Ratbl?. (. ZOO6 I = 05.4 3e'le' s 3;s szi
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me rime Tern 0 O 00 80 0 @:our pH Cond Selidly c--or Ammmiz Un.sn.m NllrIle Nilrsla Wllodde T.Col; E-Cotl Raw I: ! 9f 'IS11 mgn 02 m# 02 Hszan vSh olon iMilP mMN mgflNH3 mMN lia N ~$0I5Wml liooml m3h~s ! j iiI2008 1253 8.6 94 1 0.7 50 7.0 515 D 02 0.0003 0.018 6.4 20 i @I2038 12:05 80 111 13: 0.4 20 8.2 482 <001 ~0.01 0.014 5.7 :9 I ' 512008 12315 15 2 130 13.i 0.8 20 6.C 469 0.01 0.01 00WG OW9 4.8 '8 812W8 14:05 162 96 9.5 0.6 89 7 9 $15 0.05 0.04 0.3005 0.016 3? 18 . otz008 11:15 8.1 92 10.5 O.E 26 80 527 0 02 0.03 0.~2 0.011 4 7 17
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0.02 0.0003 ' 0020 7.8 23 IW812:10 84 107 925 EPA Export 26-07-2013:16:43:23 - - I E~,i.r~nnlentsiProlcmior Agetq, neglannl Water Lsboratory, Kilkonny . River Wale, Qurlily Monitoring Dsts Code l4BO5 Yore: ?,'lonitcrirr&W~E d!s~cqt!n~;ed at ssnlple station No 10on the R Burrei~ill 2007 - iollov~inghe implei>x)Matiocof the :inon~iorin:, pvog:m!>:e f31 the Water Ramewot,k Directive. . ~. -- n& .ie.ra. ---a Station Sampling Ilraniuxn NO Date ~~11IJ . Rase__ -. -. . -. - . ,. t. t. . . -.' _ .- 2s .24-Jaw02 ...... , 20-NOV-02: .c0.5 . , ,. I ':' E ;:; 3.0 -34.0 .__/ 0.0 -7.- 32.4 .- - . - ., ...... : Assessment ; 400: 24- an-02: ~.. .-.--61.5 37.z Tile Bilrren flows through a tillage area in north County Carlow. Nitrate !i-- - &?$ 20-~qy-04 . , 406 30-.Jun-04 , levels are high and have increased significantly since monitoring began in I . . ., .- .-24.4, ... ; hod 09-~ar-05; 40.3... . I the late 1970's - however nitrate levels appear to have stabilised since the 40q ,O-.,ul-O~, . 10.8...... , late 1090's (see graph below). Interrnitteilt agricultural pollution is also i ;b5 i evideilt at the thee lowermost stations...... i2-~5n-F)81.-43,s. ! 50d 20-Nov-02; 30.6' In 2002 ii was discovered that iuaniun: levels are elevated in the river Burren (see table below) - this is a 1 natura! characteristic. For inspection purposes only. Consent of copyright owner required for any other use. Change from 2007 No significant change &served EPA Export 26-07-2013:16:43:23 CARLOW COUNTY COUNCIL C0IIRUIU.E CHDYTAT THIATH*ELOCBA Appropriate Assessment of Biological Impacts of Hacketstown WWTP on Special Area of Conservation 000781 October 2009 Prepared by: Pascal Sweeney M.Sc., MZEEM, Consultant Ecologist, Sweeney Consultancy, Rahan, For inspection purposes only. Consent of copyright owner requiredMallow for any other use. Co. Cork. TeL 022/26780 HACKETSTOWN WASTE WATER WORKS Appropriate Assessment of Biological Impacts -1 - EPA Export 26-07-2013:16:43:23 TABLE OF CONTENTS Page SECTION 1 INTRODUCTION 3. SECTION 2 METHODOLOGY SECTION 3 RESULTS SECTION 4 CONCLUSIONS SECTION 5 NON-TECHNICAL SUMMARY APPENDIX 1 EPA Q-values 2007 APPENDIX 2 North South Share 2 Project Q-values 2009 APPENDIX 3 CHEMICAL DATA APPENDIX 4 REFERENCES For inspection purposes only. Consent of copyright owner required for any other use. APPENDIX 5 MITIGATION MEASURES HACKETSTOWN WASTE WATER WORKS Appropriate Assessment of Biological Impacts 2 EPA Export 26-07-2013:16:43:23 1. INTRODUCTION The present report by Pascal Sweeney, Consultant Ecologist, was commissioned by Carlow County Council. The discharge from Hacketstown Waste Water Treatment Plant enters the Dereen River within Special Area of Conservation 000781 (Slaney River Valley SAC). Under Article 6(3) of the EU Habitats Directive, there is a requirement for an Appropriate Assessment of the implications for the designated site of a discharge such as this, in view of the site's conservation objectives. The objective of this report is the assessment of the Dereen River in order to establish the current effect, if any, of the existing discharge on the biota of the river and the implications of any such effects for protected habitats and species within SAC 000781. Potential effects include both direct damage, such as from toxic impacts, and indirect damage from impacts on water quality. An intensive assessment of the biological water quality and status of the protected freshwater pearl mussel population in the Dereen River was recently carried out for the Freshwater Pearl Mussel Dereen River Sub-Basin Management Plan, a North-South Share 2 project, funded by the Department of Environment, Heritage and Local Government. Because the findings of this plan, soon to be available on www.wfdireland.ie, are known, fbrther field investigations were deemed unnecessary. This Appropriate Assessment report is a desktop study. For inspection purposes only. The scope of this assessment is: Consent of copyright owner required for any other use. Review of results of the Freshwater Pearl Mussel Dereen River Sub-Basin Management Plan survey. Review of EPA Q-values. Review of available chemical data from Carlow Co. Co. and EPA. Likely occurrence of protected aquatic species at and downstream of the proposed discharge point, based on available records. Likely impacts of the discharge on protected aquatic species and habitats. Cumulative effects on the qualifying interests of the Natura 2000 site. Measures to mitigate negative impacts on the protected species and habitats. HACKETSTOWN WASTE WATER WORKS Appropriate Assessment of Biological Impacts 3 EPA Export 26-07-2013:16:43:23 2. METHODOLOGY Because the Hacketstown WWTP is already in existence, the current impact on the biota of the receiving environment can be directly assessed. Biological water quality assessment is based on recent Q-values from EPA and the Freshwater Pearl Mussel Dereen River Sub-Basin Management Plan survey. The following chemical data relevant to the effluent discharge from Hacketstown WWTP were also examined to help in the interpretation of the biological analysis (Appendix 2): Carlow Co. Co. 200812009 results of chemical analysis of the river water. EPA 2008 results of chemical analysis of the river water. It is important .to note that the sampling sites are not the same for both sets of data. The Carlow County Council sites are much closer to the outfall than the EPA sites. Available records of species listed in Annex I1 of the EU Habitats Directive were checked. For inspection purposes only. Consent of copyright owner required for any other use. HACKETSTOWN WASTE WATER WORKS Appropriate Assessment of Biological Impacts 4 EPA Export 26-07-2013:16:43:23 3. RESULTS 3.1 EPA Q-values The Hacketstown WWTP outfall is on the Derreen River, between EPA Sites 0300 and 0400. The Derreen River enters the River Slaney between EPA Sites 1400 and 1600. EPA Q-values for the Derreen River and the River Slaney are presented in Appendix 1. The Derreen results show a drop of half a Q-value between Sites 0300 and 0400 in 2007, while in 2001 and 2004, when Site 0400 was not assessed, there was also a drop of half a Q-value between Sites 0300 and 0420, the next downstream site. Q-values recorded in the Derreen River and tributaries for the North South Share 2 Project in 2009 are presented in Appendix 2. These show slightly polluted conditions (43-4) at both Sites 0300 and 0400. Three small tributaries that flow to the Derreen River between these two sites were assessed. These are listed as Tributaries 10, 11 and 12. Two were found to be moderately polluted (Q3) and one slightly polluted (43-4). From these results, it is difficult to estimate the degree to which the Hacketstown WWTP has been impacting on the biological water quality in recent years. From 2001 to 2007, the WWTP effluent could have contributed significantly to the recorded drop in water quality, because the tributaries For inspection purposes only. are probably too small to have hadConsent such of copyright an ownerimpact. required forThe any other2009 use. results, showing slightly polluted conditions both upstream and downstream of the outfall, do not implicate the Hacketstown WWTP in a lowering of biological water quality. It must be borne in mind, however, that these samples were taken soon after the water level dropped following flood conditions and might not accurately reflect localised impacts to their full extent. 3.2 Chemical Data Recent chemical data from Carlow County Council and EPA are presented in Appendix 3. On most dates that chemical sampling took place, orthophosphate and nitrate levels were higher at the downstream sites. HACKETSTOWN WASTE WATER WORKS Appropriate Assessment of Biological Impacts 5 EPA Export 26-07-2013:16:43:23 3.3 Protected Habitats and Species. In this section, the impact of Hacketstown WWTP discharge on each of the habitats and species for which the SAC is designated, is estimated. While the zone of potentially highest impact was taken as being from the discharge point to I km downstream and this section of river was the main focus of the detailed investigation, the entire downstream freshwater section of the river was considered when assessing the presence of protected habitats and species and the potential effects of the discharge on these. The Site Synopsis for the Slaney River Valley SAC states: "The site is a candidate SAC selected for alluvial wet woodlands, a priority habitat on Annex I of the E.U. Habitats Directive. The site is also selected as a candidate SAC for jloating river vegetation, estuaries, tidal mudjlats and old oak woodlands, all habitats listed on Annex I of the E.U. Habitats Directive. The site is further selected for the following species listed on Annex II of the same directive - Sea Lamprey, River Lamprey, Brook Lamprey, Freshwater Pearl Mussel, Twaite Shad, Atlantic Salmon and Otter." Several of the species and habitats listed above are terrestrial and could not be affected by the Hacketstown WWTP discharge. Some are estuarine, in which cases the distance from the outfall to the saline waters must be taken into account when assessing the likelihood of any impacts. 3.3a Protected Habitats For inspection purposes only. Consent of copyright owner required for any other use. Floating River Vegetation Of the Annex I habitats listed above, only floating river vegetation would occur within 1 km downstream of the discharge and is therefore considered to be the only Annex I habitat that could potentially be affected to any significant degree. A slight increase in plant nutrients would result in increased growth of floating river vegetation. A more substantial increase in plant nutrients could cause an increase in the competitive interactions between plant species, resulting in a loss of species. The increases in plant nutrients downstream of the outfall, seen in the available chemical data indicate a likely impact on floating river vegetation. Old Oak Woodlands Terrestrial habitat, unaffected by discharges to rivers. HACKETSTOWN WASTE WATER WORKS Appropriate Assessment of Biological Impacts 6 EPA Export 26-07-2013:16:43:23 Alluvial Wet Woodlands Alluvial wet woodland occurs along banks of the Slaney, particularly in the lower reaches and the tidal section, e.g. at Macmine marshes. Plant growth in this habitat could potentially be positively affected to some extent if there were increased nutrient concentrations in the water. The increases in plant nutrient levels downstream of the outfall seen in the available chemical data are probably not of sufficient magnitude to impact on this habitat, given the distances involved. Estuary, Tidal Mudflats Saline habitats which potentially could be affected by substantially increased nutrient concentrations in the freshwater sections of rivers. The increases in plant nutrient levels downstream of the outfall seen in the available chemical data are probably not of sufficient magnitude to impact on these habitats, given the distances involved. 3.3b Protected Species Twaite Shad (Alosa fallax). Twaite shad is an anadromous fish which enters large estuaries in late April or May to spawn in gravels near the end of the freshwater reaches, with the only known spawning population of Twaite shad in Ireland occuning in the River Barrow (Doherty et al. 2004). Adult Twaite shad are also known to occur in the lower parts of the River Slaney (King and Linnane, 2004), although spawning has not been recorded here in recent years. Threats to Irish shad populations include deterioration of water quality and habitat degradation. For inspectionThe increasespurposes only. in plant nutrient levels downstream of the Consent of copyright owner required for any other use. outfall seen in the available chemical data are probably not of sufficient magnitude to impact on this species, given the distance from Hacketstown WWTP to the upstream end of the tidal range and the fact that the EPA 2007 data showed the biological water quality improving to unpolluted conditions (Q4) before reaching the lower end of the River Slaney. Sea Lamprey (Petromyzon marinus). King and Limane (2004) recorded no juvenile sea lamprey in the Derreen River, nor in the main channel of the river Slaney. Kurz and Costello (1999) report that sea lamprey has occasionally been observed downstream of Emiscorthy. The increases in plant nutrient levels downstream of the outfall seen in the available chemical data are probably not of sufficient magnitude to impact on this species, given the distance from Hacketstown WWTP to the upstream end of the tidal range and the fact that the EPA 2007 data showed the biological water quality improving to unpolluted conditions (44) before reaching the lower end of the River Slaney. HACKETSTOWN WASTE WATER WORKS Appropriate Assessment of Biological Impacts 7 EPA Export 26-07-2013:16:43:23 Brook Lamprey (Lampretaplaneri) and River Lamprey (Lampretafluviatilis). King and Linnane (2004) recorded juvenile brooWriver lamprey in nine of the ten sites electrofished on the Derreen River. They also found a widespread distribution of brook and river lampreys in the main channel of the Slaney. A significant drop in water quality could negatively affect any lamprey population present, but Maitland (2003) indicates that lamprey do not require very high water quality. The current water quality of the Derreen River is therefore sufficient to support these species and the discharge is not impacting on their status. Freshwater Pearl Mussel (Margaritifera margaritifera). Within SAC 000781, the freshwater pearl mussel population is concentrated in the Dereen River. Survey work for the North South Share 2 Project found, however, that this population is in severe decline, with no recruitment ofjuveniles. The current biological water quality of the Derreen River, both upstream and downstream of the Hacketstown WWTP is far too low for a sustainable population of freshwater pearl mussels, which need pristine conditions for successll reproduction. Any lowering of water quality has a negative impact on pearl mussels. Atlantic salmon (Salmo salar). The Site Synopsis for The Slaney River Valley SAC states: "The Slaney is primarily a spring salmon fishery and is regarded as one of the top rivers in Ireland for early spring fishing. The upper Slaney and tributary headwaters are very important for spawning." For inspection purposes only. Consent of copyright owner required for any other use. The main channel of the River Slaney, but the Derreen River, is a Salmonid Water, designated under the European Communities (Quality of Salmonid Waters) Regulations of 1988 (S.I. No. 293 of 1988). The chemical data presented in Appendix 3 are within the standards specified for compliance with these regulations in Salmonid Waters, both upstream and downstream of the outfall for the following parameters for which data are available: Temperature, Dissolved Oxygen, BODS, pH, Non-ionised Ammonia, Total Ammonium, Suspended Solids. The egg and juvenile stages of the salmon life cycle are very vulnerable to deteriorations in water quality (Hendry and Cragg-Hine, 2003). A significant drop in water quality would also negatively affect adult salmon. The slightly polluted (43-4) biological water quality in the Derreen River is not satisfactory for the egg and juvenile stage of salmon. Otter (Lutra lutra). HACKETSTOWN WASTE WATER WORKS Appropriate Assessment of Biological Impacts 8 EPA Export 26-07-2013:16:43:23 Within the South Eastern River Basin District, which includes the River Slaney catchment, Baily and Rochford (2006) recorded positive results at nearly 73% of the sites surveyed, indicating a widespread distribution of the species. If water quality dropped to the extent that the abundance of prey species were significantly affected, otters could be negatively impacted. However, given that Baily and Rochford (2006) found no significant difference in the occurrence of otters between polluted and unpolluted sites (their data appears to show a slight preference for slightly polluted sites over both extremes), it would appear that the slightly polluted conditions in Derreen River is not likely to affect otters. For inspection purposes only. Consent of copyright owner required for any other use. HACKETSTOWN WASTE WATER WORKS Appropriate Assessment of Biological Impacts 9 EPA Export 26-07-2013:16:43:23 4. CONCLUSIONS 4.1 Conservation Objectives. Summarising the main threats to the designated site, the Site Synopsis for The Slaney River Valley SAC states: "Waste water ozrtjlows, rltnofffrom intensive agricultural enterprises, a meat factory at Clohamon and a landfill site adjacent to the river and,further industrial development upstream in Enniscorthy and in other towns could all have potential adverse impacts on the water quality unless they are carefully managed." The relevant conservation objective pertaining to the discharge to Hacketstown WWTP must therefore be to avoid impacts from high BOD, suspended solids and nutrients by proper treatment of the effluent before discharge to the river. 4.2 Cumulative Impacts. 2009 Q-rating results for the Derreen River and its tributaries (Appendix 2) indicate a widespread problem of low-level point source and diffuse pollution throughout the catchment that must have a cumulative negative impact on the freshwater pearl mussel and salmon. This is borne out by the finding of serious decline in the pearl mussel population. The 2007 EPA Q-ratings show unpolluted conditions (44 or better) at 11 of the 14 sites assessed on For inspection purposes only. the River Slaney. Slightly pollutedConsent conditions of copyright owner (Q3-4) required forwere any other recorded use. at the other three sites, all of which are downstream of Bunclody. The following facility in the catchment of the River Slaney, have a waste licences: Brownfield Restoration Ireland Ltd, Licence Code W0204-01. This waste licence is for activities associated with the cleanup and remediation of an unauthorised landfill of approximately 240,000 tonnes (applicant's estimate) of mixed construction and commercial waste emplaced during the 1970s to 2001 at three areas at a working sand and gravel pit of area 15ha, in Whitestown Lower, County Wicklow. The licence sets out in detail the conditions for management of the facility, control, monitoring, closure, restoration and aftercare. Swalcliffe Ltd., Licence Code W0181-01. This waste licence is for activities associated with the cleanup of an unauthorised landfill of approximately 10,000 tonnes of mixed construction, HACKETSTOWN WASTE WATER WORKS Appropriate Assessment of Biological Impacts10 EPA Export 26-07-2013:16:43:24 chemical, municipal, hospital, and hazardous clinical waste emplaced in 2001 at a disused sand and gravel pit of area 0.42ha, in Coolamaddra, County Wicklow. The principal activity is specifically related to the excavation and recovery of waste by sorting and its segregation prior to off-site disposal at a licensed facility. The licence sets out in detail the conditions for operation and management of the facility. Ramvere Landfill, Licence Code W0066-02. The licence specifies that there are to be no direct emissions to groundwater and that no leachate is to be discharged to surface waters. All leachate is treated off-site at a suitable WWTP. Greenstar Limited (Enniscorthv). Licence Code W0241-01. The licence specifies that there are to be no direct emissions to groundwater. The licence also specifies conditions and limits for emission to sewer. Killurin Landfill Site. Licence Code W0016-02. The licence specifies that there are to be no direct emissions to groundwater and that no leachate or contaminated surface water is to be discharged directly to the River Slaney catchment. All leachate is treated off-site at Enniscorthy WWTP. The following facilities in the catchment of the River Slaney have IPPC licences: Murrav Timber (Ballon) Limited, Code P0556-01. The licence specifies the monitoring requirements for surface water discharges. The licence also specifies measures for the protection of groundwater and surface water and actions to be taken if contamination For inspection is purposes detected. only. Consent of copyright owner required for any other use. Slanev Foods International Limited and Slanev Proteins, Code P0074-03. The licence specifies emission limits to the River Slaney. Hogg Enternrises Limited. Code P0622-01. The licence specifies measures for the protection of surface waters and groundwater at the facility. The licence also specifies conditions on the landspreading of the sluny produced. Wexal International. Code P0394-01. The licence specifies measures for the protection of groundwater and surface water and emission limits to sewer and to the river Umn. The licence also specifies the monitoring requirements for ground and surface water and actions to be taken if contamination is detected. HACKETSTOWN WASTE WATER WORKS Appropriate Assessment of Biological Impacts1 1 EPA Export 26-07-2013:16:43:24 Rennard Pig Farms Limited, Code P0453-02. The licence specifies measures for the protection of surface waters and groundwater at the facility. The licence also specifies conditions on the landspreading of the sluny produced. Provided that the facilities listed above comply with the terms of their licences, they should have no cumulative impact on the conservation objectives of Special Area of Conservation 000781. While it would be very difficult ascertain the exact degree to which the efluent from the Hacketstown WWTP adds to the cumulative impact on the Natura 2000 site and its conservation objectives, the present survey indicates that there is some impact. 4.3 Mitigation Measures. The findings of this report indicate the need for measures to improve the effluent quality. Upgrading of Hacketstown WWTP is necessary. The most important measure, in addition to the standard treatment by oxidation and sedimentation, would be the removal of phosphorus. Details of measures currently in place in Hacketstown WWTP and planned future improvements are provided by Carlow County Council in Appendix 5. For inspection purposes only. Consent of copyright owner required for any other use. HACKETSTOWN WASTE WATER WORKS Appropriate Assessment of Biological lmpactsl2 EPA Export 26-07-2013:16:43:24 5. NON TECHNICAL SUMMARY A desktop assessment was canied out in order to assess the current effect, if any, of the discharge from Hacketstown Waste Water Treatment Plant (WWTP) on the Derreen River and the implications of any such effects for protected habitats and species within the Special Area of Conservation (SAC). Biological water quality assessment results and chemical data indicate some impacts of the WWTP discharge on the Derreen River by. Seven species and four habitats which are listed for protection under the EU Habitats Directive were identified as being present, or likely to be present at or downstream of the WWTP outfall. The results indicate a likely impact on freshwater pearl mussel, salmon and floating river vegetation. Mitigation measures currently in place and planned for Hacketstown WWTP are outlined. For inspection purposes only. Consent of copyright owner required for any other use. HACKETSTOWN WASTE WATER WORKS Appropriate Assessment of Biological Impacts1 3 EPA Export 26-07-2013:16:43:24 APPENDIX 1 EPA Q-values Derreen River (12D01) EPA Q-values 2001 - 2007 Station No. Station Location 0050 Br SW of Toorboy 0150 Br NE of Ballykilmurray Lr 0200 2nd Ford uls Hacketstown Br 0300 Hacketstown Br 0400 Saulsford Br 0420 Br dls Saulsford Br 0500 Acaun Br 0550 Knockeen Br 0600 Knockloe Br 0700 Rathglass Br 0800 Ford uls Slaney R confl River Slaney (15N01) EPA Q-values 2001 - 2007 Station No. Station Location 0100 Seskin Br 0200 Kelsha Br 0400 Waterloo Br 0600 Tuckmill Br 0700 Just dls Baitinglass Br 0770 Maiden's Ford 0800 Aldborough Br 0900 Ford uls Rathvilly 1000 Rathvilly Br 1020 Ikm For dls inspection Rathvilly purposes Br only. 1100 ConsentRathmore of copyright Br owner required for any other use. 1200 Moatabower Br 1290 0.5km uls Tullow Br 1400 Ford 3km dls Tullow Br 1600 Kilcarry Br 1800 Slaney Br Bunclody 2000 1.3km dls Clohamon Br 2100 Ballycarney Br 2200 Scarawalsh Br 2220 Just W of Salsborough Br 2400 1 km dls Enniscorthy Br HACKETSTOWN WASTE WATER WORKS Appropriate Assessment of Biological Impacts - 14 - EPA Export 26-07-2013:16:43:24 APPENDIX 2 Derreen River (12D01) North South Share 2 Project Q-values 2009 NS Share 2 Code EPA Code Location Derreen A 0150 Br NE of Ballykiimurray Lr Derreen B 0200 2nd Ford uls Hacketstown Br Derreen C 0300 Hacketstown Br Derreen D 0400 Saulsford Br Derreen E 0500 Acaun Br Derreen F 0550 Knockeen Br Tributary 1 29968 18340 3 Tributary 2 29990 18330 3-4 Tributary 3 29944 18266 3-4 Tributary 4 29872 18308 3-4 Tributary 5 29827 18258 2-3 Tributary 6 29782 18159 3-4 Tributary 7 29771 18138 3-4 Tributary 8 29818 18106 3 Tributary 9 29828 18071 3-4 Tributary 10 29543 18082 3 Tributary 11 29536 18063 3 Tributary 12 29447 18053 3-4 Tributary 13 29454 17997 3-4 Tributary 14 2930818064 34 Tributary 14A 29275 18165 3-4 Tributary 15 29271 18039 3-4 Tributary 16 29228 18034 3 Tributary 17 29102 17892 3 Tributary 18 29029 17925 3-4 Tributary 19 29006 17843 3-4 Tributary 20 29025 17690 3-4 Tributary 21 For inspection purposes28940 only. 17642 3 Consent of copyright owner required for any other use. Tributary 22 28973 17487 3 Tributary 23 28915 17454 3 Tributary 24 28868 17459 3 Tributary 25 28755 17339 2-3 'Some Q-values were ascribed as "tentative" because of the possibility of impacts of recent very heavy flow on the invertebrate communities. HACKETSTOWN WASTE WATER WORKS Appropriate Assessment of Biological lmpacts 15 EPA Export 26-07-2013:16:43:24 APPENDIX 3 CHEMICAL DATA APPENDIX 3A. Carlow Co. Co. ROUTINE MONITORING 200812009 For inspection purposes only. Consent of copyright owner required for any other use. HACKETSTOWN WASTE WATER WORKS Appropriate Assessment of Biological Impacts EPA Export 26-07-2013:16:43:24 Station No. 0400 Station No. 0300 Saulsford Br - Hacketstown Br dls Hacketstown - dls Kepak Ltd. A A N‘w P-00- BOO mg/102 LNWOC~ mbml~d A 0 0 0 P Ortho-phosphate 8ZXG8N a N 2b~o~ m mgN P WWWNN Cn w?g*P Chloride mgN -A244 4- -22 --L--LNWN N--LAN--L Nitrate mg/l N N N N N gbwww- inbbmm- - 0 0 0 0 PPPPP o o o P 6 8 Z 2 2 g Ammonium mg/lN mP5AOP wm-4 rnm~ww PPPPP P P P P P Non-ionised 00000 00000 00000 o o o o o AmmoniamgN 000-0 002 ~wmo- For inspection purposes only.0"Zww NH3 Consent of copyright owner required for any other use. A ggggg X 2 X Z Nitrite mgN N 00 22022 zzU7PN W Dissolved Oxygen 2 2 2 2 A 2 owwow 020-w % 02 rnmslma m UN* -A -a A A A - Conductivity @ PWWPP N-AN- o~mrnwP - rn w a 2SoC uS/cm 4 4 .A A lop~m?FP'lo? Temperature 'C m -4 a m - ambow Alkalinity z g 2 % 2 mgll CaCo3 EPA Export 26-07-2013:16:43:24 APPENDIX 4 REFERENCES Bailey, M. and Rochford J. (2006) Otter Survey of Ireland 2004/2005. Irish Wildlife Manuals, No. 23. National Parks and Wildlife Service, Department of Environment, Heritage and Local Government, Dublin, Ireland. Doherty, D., O'Maoilkdigh, N., and McCarthy, T.K. (2004). The biology, ecology and future conservation of the Twaite shad (Alosa,fallar Lace 'PE' DE), Allis shad (Alosa alosa L.) and Killarney shad (Alosa fallax hillurniensis Tate Regan) in Ireland. Biology and Environment: proceeding of the Royal Irish Academy: 104B: 93-102. King, J. J. and Linnane, S. M. (2004). The status and distribution of lamprey and shad in the Slaney and Munster Blackwater SACS. Irish Wildlife Manuals, No. 14. National Parks and Wildlife Service, Department of Environment, Heritage and Local Government. Kurz, 1. and Costello, M.J. (1999). An outline of the biology, distribution and conservation of lampreys in Ireland. Irish Wildlife Manuals No. 5, Duchas, The Heritage Service. Maitland. P.S. (2003) Ecology of the River, Brook and Sea Lamprey. Conserving Natura 2000 Rivers Monitoring Series No. 5, English Nature, Peterborough. For inspection purposes only. Consent of copyright owner required for any other use. HACKETSTOWN WASTE WATER WORKS Appropriate Assessment of Biological Impacts - 18 - EPA Export 26-07-2013:16:43:24 APPENDIX 5 Hacketstown WWTP - Mitigation Measures For inspection purposes only. Consent of copyright owner required for any other use. HACKETSTOWN WASTE WATER WORKS Appropriate Assessment of Biological Impacts1 9 EPA Export 26-07-2013:16:43:24 For inspection purposes only. Consent of copyright owner required for any other use. EPA Export 26-07-2013:16:43:24 CARLOW COIINTY COUNCIL C"U"hlliLl r"OYi*e E"l*ili*TIOC"* CARLOW COUNTY COUNCIL HACKETTSTOWN WASTE WATER WORKS WASTEWATER DISCHARGE LICENCE APPLICATION For inspection purposes only. Consent ofAppendix copyright owner required for any other use.5 Mitigation Measures for Appropriate Assessment for Hackettstown Agglomeration Hacketfstown Waste Water Works Mitigaaon Measures for Appropriate Assessment 1 EPA Export 26-07-2013:16:43:24 Hackettstown and the Catchment Area Hackettstown Agglomeration is located 28 kms northeast of Carlow Town on the Dereen River. The catchment area consists of the agglomeration of Hackettstown. No areas outside of Hackettstown are pumped or transferred to the Hackettstown WWTP, The present loading from the catchment to the WWTP is estimated to be 1100pe. The WWTP has a capacity to treat a population of 600pe. The Hackettstown Waste Water Treatment Plant is an older type WWTP consisting of an lmhoff Tank, Percolating Filters and Humus Tank and is currently performing very poorly producing a very poor quality effluent. Hackettstown Waste Water Treatment Plant The original WWTP in Hackettstown had been built in 1947 for a capacity of 600pe. The plant consisted of an Imhoff Tank, Percolating Filters and Humus Tank and is currently perfomling very poorly. The WWTP had become severely overloaded by the 2000s. The Hackettstown Waste Water Treatment Plant is currently a point source of BOD, S.S. N and P loading into the River Dereen. Carlow County Council are currently progressing a scheme known as the Tullow, Rathvilly, Hackettstown Sewerage Schemes through the WSIP. The Scheme is currently at Preliminary Report Stage and the P.R. will be submitted to the DEHLG before the end of 2009. However due to the very poor performance For inspection of purposes the only.Hackettstown WWTP at present, Carlow County Consent of copyright owner required for any other use. Council are proposing to address the issue immediately by fast forwarding an Advance Works Contract at the Hackettstown WWTP to improve the standard of the final effluent discharging into the River Dereen. It is hoped that the Advance Works Contract will go to tender in 2010 and will be constructed in 2011 Due to the sensitivity of the receiving waters Carlow County Council will specify a high standard for the new works. This was done with a view to putting in place mitigation measures to minimise the impact of the Hackettstown Agglomeration on the receiving waters and in particular on the c SAC known as The Slaney River Valley, Site 000781 which includes the River Dereen. The River'Dereen is of particular importance due to its Freshwater Mussel Population. The specification will call for an effluent standard of: Hackettstown Waste Water Works Mitigation Measures for Appropriate Assessment EPA Export 26-07-2013:16:43:24 BOD, 2Smg/l SS, 35mg/l Ammonia, 2.5mgll N Smgll Total P, 0.Smgll To achieve this objective the new works include tertiary treatment and ferric dosing to reduce P levels. The new WWTP also will have facilities for the management of Storm Water. The new WWTP will treat 3DWF and pump the rest forward to a Stonn Water Holding Tanks The Stosm Holding Tank will hold 3DWF for 2 hours. Water that then overflows will have received primary settlement treatment and screening. Obviously at this stage flows in the receiving waters will be very high which will assist dilution. The new WWTP consists of the following: Inlet screen with by-pass-manual stainless screen, wash water and automatic sampler Grit Classifier and blower Sequence Batch Reactor Balancing Tank RASIWAS Pumps Tertiary Treatment consisting of sand filtration Fenic dosing system with drench shower and bund Sludge holding tanks Control building Access road Shower, toilet, hand basin and store For inspection room purposes only. Consent of copyright owner required for any other use. Strom water holding lank with capacity to hold 3DWF for 2 hours Flow measurement on inlet flow, outlet flow, sludge removal and storm overflows The Hackettstown Waste Water Plant is operated by the following staff : 1 No Caretaker Carlow County Council will provide the Caretaker with all necessary training to ensure a high standard of plant operation and maintenance. The new WWTP is fully automated to further assist the caretaker. The plant is manned between the hours of 08.00 and 12.00 Monday to Friday with the plant being also manned between the hours of 08.00 and 12.00 on Saturday and between the hours of 10.00 and 12.00 on Sunday. Hackettstown Waste Water Works Mittgation Measures for Appropriate Assessment 3 EPA Export 26-07-2013:16:43:24 Call out systems are in place whereby staff are notified of malfunctions in the plant operation and are in a position to get to the plant and address the problems immediately. A contract is in place with a service provider to cany out maintenance to the plant on a regular basis. Carlow County Council are presently sefling in place the PMS (Performance Management System). This will involve each caretaker compiling a monthly report on the Plant Operations. The caretakers report will be approved by his line manager and by a Senior Engineer in Water Services. Carlow County Council are committed to operating and maintaining the WWTPs within the County to level necessary to produce an effluent to the required standards and to achieve this consistently. Receiving Waters The treated effluent from the Hackenstown Waslewater Works discharges via a 300mm diameter Casr lron pipe into the River Dereen which flows along the western boundary of the WWTP. Dangerous Substances : The final effluent has been tested for dangerous substances as per the Dangerous Substances Directive and results are compliant with the Directive. To comply with Phosphorus Regulations (S.1. No 258 of 1998) there will be iron coagulant dosing provided to reduce the phosphorus level to lmgll total P. Water Directive : The objectives of the Water Framework Directive (WFD) are to protect all high status waters, prevent further deterioration of all waters and to restore degraded surface and ground waters to good status by 2015. A major programme is under way to achieve this target. The provision by Carlow County Council of a new 1,400pe WWTW at Hackettstown with secondary and teliiary treatment and a tight specification will meet help achieve these objectives. The SERBD draft management plan developed under the WFD is on display at present and will be complied with by Carlow County Council. For inspection The purposes SERBD only. Management will be adopted by the end of Consent of copyright owner required for any other use. 2009. The new Hackettstown WWTP will help the River Dereen achieve "good" status in line with the objectives of the Water Framework Directive. The new WWTP when constructed will greatly help in reducing the pollutants entering the Rives Dereen from the Hackenstown Agglomeration and will reduce considerably the Hackettstown Agglomeration as a source of P and N loadings into the River Dereen. Conclusion Carlow County Council are currently awaiting approval from the DEHLG to carry out an Advanced Works Contract at the WWTP in Hackettstown. This will ensure a much reduced loading entering the River Dereen. Fenic dosing will be provided at the plant and so will tertiary treatment. Hackettstown Waste Water Works Mitigation Measures for Appropriate Assessment 4 EPA Export 26-07-2013:16:43:24 Stormwater Management will also be included in the new works and will bring the storm water overflow at the Hackettstown WWTP in line with the "Procedures and Criteria for Storm Water Overflows" as per DEHLG Guidelines. At a capacity of 1400 pe the plant will be adequately sized to cater for the wastewater loadings from the Hackettstown Agglomeration up to a least 201 5. This WWTP will allow Carlow County Council to do its par( in removing pollution from the Dereen River and contributing to improvements in the water quality in the Douglas and also the Slaney and the SAC 00078 1. The new WWTP will eliminate a substantial source of phosphate and nitrate loading into the Dereen River. The new WWTP will allow Carlow County Council to achieve the objectives and programmes set out under the SERBD Management Plan and in the Dangerous Substances Directive. Carlow County Council have put the necessary mitigation measures in place to deal with potential impacts outlined in the Hackettstown Agglomeration Appropriate Assessment. For inspection purposes only. Consent of copyright owner required for any other use. Hackettstown Wrrste Water Worlu Mitigation Measures for Appropriate Assessment 5 EPA Export 26-07-2013:16:43:24 For inspection purposes only. Consent of copyright owner required for any other use. EPA Export 26-07-2013:16:43:24 Total Nitrates ortho- Total Total EntityName Sample Ammonia BOD COD suspended Date (N) phosphate Nitrogen Phosphorus Solids , Hacketstown Sewage Works lnlet "I 32 Hacketstown Sewage Works Outlet Hacketstown Sewage Works Downstream Hacketstown Sewage Works lnlet Hacketstown Sewage Works Outlet Hacketstown Sewage Works Upstream Hacketstown Sewage Works lnlet Hacketstown Sewage Works Outlet Hacketstown Sewage Works Downstream Hacketstown Sewage Works lnlet Hacketstown Sewage Works Outlet Hacketstown Sewage Works Upstream Hacketstown Sewage Works Downstream Hacketstown Sewage Works lnlet Hacketstown Sewage Works Outlet Hacketstown Sewage Works Upstream Hacketstown Sewage Works lnlet Hacketstown Sewage Works Outlet Hacketstown Sewage Works lnlet Hacketstown Sewage Works Outlet Hacketstown Sewage Works lnlet Hacketstown Sewage Works Downstream Hacketstown Sewage Works Outlet Hacketstown Sewage Works Upstream Hacketstown Sewage Works Downstream For inspection purposes only. Consent of copyright owner required for any other use. Hacketstown Sewage Works Outlet Hacketstown Sewage Works Upstream Hacketstown Sewage Works lnlet Hacketstown Sewage Works lnlet Hacketstown Sewage Works Downstream Hacketstown Sewage Works Outlet Hacketstown Sewage Works Upstream Hacketstown Sewage Works lnlet Hacketstown Sewage Works Downstream Hacketstown Sewage Works Outlet Hacketstown Sewage Works Upstream Hacketstown Sewage Works lnlet Hacketstown Sewage Works Outlet EPA Export 26-07-2013:16:43:24