I just have one quick slide in terms of the purpose of the symposium.
I just have one quick slide in terms of the purpose of the symposium.
Then I am going to move on with three or four slides and talk about the regulatory framework.
The provost talked about that there had been huge debate in the country.
And I just want to get, some key points from that.
But I want to quickly move on then and just give you a flavour
for the national inspection plan, which is tasked to the EPA
to craft, and for local authorities to deliver.
I am bringing it up in the sense of, tomorrow you will hear from my colleagues,
Donal Daly, who is up in the top of the left there,
who is going to talk about the risk methodology,
and later on by Margaret Keegan and Leo Sweeney, they will flesh it out.
So I will just whet the appetite on that.
I want to spend a bit of time then just on the role of research.
And what I have done is, I have called it 'Reeling back the years'.
I have tried to look at the standards back to 1975, and take you up to the current time.
And then I will just wrap up with a slide in terms of the next steps.
In terms of the symposium, if you look at
the titles of the various sessions, we have academics, researchers,
practitioners in the field, all wrapped around risk-based assessment,
catchment management, inspection planning, wastewater treatment technologies,
subsoil attenuation, regulatory frameworks, and then disposal options.
What we wanted to do was just give you a flavour about what's happening currently
nationally and then internationally.
And we are hoping that, between the two days,
and we were keen that there would be a second day
so that we would give people the opportunity to digest and to meet each other.
And then taking the fruits of all of those talks,
to be able to inform both the national inspection plan that we are going to be …
delivering towards the end of this year,
but also the huge area of remediation of these sites,
which is going to go on for many years.
OK, some legislation which I think is very very important,
just to recap on.
Because it provides the focus of what a lot of the audience
amongst local authorities and ourselves will have to grapple with
over the next couple of years. There are two pieces of legislation.
one has been around since 2007.
The heart of that piece of legislation, which for the foremost was to consolidate
a lot of old legislation in the sanitary services area.
But I think there was a Section 70 that was missed along the way.
But it's important to remind people that there's a duty of care
on the owner of wastewater treatment systems to ensure
that it's kept so as not to cause or likely to cause the risk to human health and the environment.
And if you go back to 1975, to Article 4 of the Waste Directive,
it talks about human health and the environment.
And all of what we are trying to roll out in terms of our framework
and what we will be looking at in terms of the remediation of sites
will be focusing on public health and the environment, its protection.
So then a lot of what the Amendment Act…it's not new in the sense of…
it's picking up from the 2007 Act and specifically Section 70.
So the Amendment which caused huge debate in the last…
almost 12 months in the country, the heart of it still dates back to 2007.
What does that require? I think most in the audience will know.
But for our overseas visitors, there is a requirement to have a registration system in place.
So every householder in the country has to register between now and February of next year.
And that's the first step in the regulatory process.
There's also then a requirement for them to maintain their system,
obviously in compliance back to the Section 70 of the 2007 Act
which is that their system does not constitute a risk to human health or the environment.
I put the next slide …or a little bullet point there, to comply with relevant regulations.
And I have a slide later on that talks about one specific regulation,
which will be the core of where we will be pulling the standards
that the inspectors who will be going out on the various inspections around the country,
what they will be trying to determine, either compliance or otherwise on that.
Then there's the whole legislative framework or stepping stones
in terms of the remediation of the sites.
And also I just put down at the end is that…which is something new…
is that in terms of the sale of properties …
please God when they occur much more than they are at the moment,
that there's a requirement that systems are registered.
Moving on, just drilling down to…just looking at what water services…
for the most part it's local authorities, the EPA and the inspectors have to do.
I have picked out a few things from both.
I am not going to dwell very much on them.
Because I want to go on to the role of research in the various standards.
But picking out some of the issues.
There is a central registration system but
the local authorities are individually charged
to have a public register of systems within their functional area.
And also anybody who registers to send out a certificate of registration.
When we come up with our national inspection plan
it's the function of the local authorities to deliver that.
And they will deliver that through both inspectors from within their own local authority,
or they can get people from the private sector if they so wish.
Interestingly enough set out in the legislation,
the water services authority then can communicate directly with the inspectors.
But there's also something which I haven't seen before,
is there is the opportunity of the EPA also to talk directly to inspectors.
So when these inspectors go out on site, please God, many of them will pass.
But if that situation doesn't arise, there's going to be stepping stones
in terms of the remediation of the sites.
And that starts through a whole series in terms of advisory notices.
So I am not going to go down one by one through.
But there is a step by step process,
including people to be able to have a second inspection done if they so wish.
In terms of the inspectors themselves,
they have powers to be able to enter and inspect a premises.
And then in terms of what they can do on site, the monitoring, sampling, photography…
they will take photographs…survey and excavate.
I have to say, our intention in the first instance is that
the inspections will be focused from a visual perspective.
They can request information also from the householder
in terms of the maintenance and servicing and the operation of the sites.
And then they are required legally to inform the householder, at some point in time,
in terms of the result of that inspection.
We estimate that the inspections will probably start the middle of next year.
We see the national inspection plan breaking out into two parts.
One, where we will have a lot of advice and education for the first part of the year,
then followed by inspections later on in 2013.
In terms of ourselves within the EPA,
we have a supervisory function over the performance of local authorities in this area,
which is not new. We had existing powers under the 1992 Act.
And as I said, we have to prepare the national inspection plan.
I will tell you a bit more about that later on.
And you will get more of it also tomorrow, as I said, from my colleagues.
We also have to appoint inspectors.
And at the moment we are working with a number of stakeholders.
And through the water services national training group
we are developing training material for these inspectors.
And then we can issue directions if we need to, both directly to the inspectors,
but also to the water services authorities.
I have one slide just on the regulations. There have been a few made.
But the most important one to date from the point of view of the inspection
are statutory instrument 223 of 2012.
And I said earlier on from this we believe that we can pull a number of the criteria
that the inspectors will be using in terms of their judgement,
whether or not systems are ….in terms of a risk to public health or the environment.
And it's worth just going down through some of the articles
from that particular regulation.
One of them is that the systems are required to operate and maintain their system
such that the wastewater or sewage does not emit discharge, seep, etc.,
except for where it is intended to discharge, unless it has a Water Pollution Act Licence.
Now there's a lot in there that we can pull on from the point of view of assessment,
in terms of the performance of systems.
The system should not result in ponding of wastewater, effluent onto the surface of the ground.
No rainwater, surface water, should enter the system, because of obvious reasons.
It could overwhelm the operation of the system.
And then just a statement in terms of all the component parts, that they are fit for purposes.
There was a huge debate, as many of you will know, in terms of
desludging and the operation of these systems.
So the regulations came down that it would be done so at appropriate intervals.
And that was wise in the context of
the population that might be within a household.
And I know the Provost talked about his own mother,
but I have to say an awful lot of what I have been doing here is looking at my own mother
in terms of the operation of her system.
And I can think back where at one stage there were six of us in the house
and we grew up and I would imagine the wastewater profile
within the house would have changed over the years.
My mother, who is in her 80s, lives on her own.
So from the point of view of desludging it's very difficult to come down hard and fast
to once a year, twice a year.
I think appropriate intervals represented common sense.
In terms of the national inspection plan, I just have two slides.
We are going to have to develop it in accordance with Section 70 of the Act.
And there are a whole load of bullet points that we will have to go through
in terms of to ensure that it is compliant with the Act.
But by way of a flavour it's going to have…
three of the inputs that are informing
our current thinking on it is that it will be intelligence led enforcement.
And Donal will flesh out in more detail tomorrow on that.
That's the risk methodology which is very much being driven
from modern technologies in enforcement and the use of GIS.
The RMCEI is a recommendation from the European Commission
that dates back now I think to 2001. And that's to do with all types of inspections.
But it's interesting within that, the broad definition in which inspection is held.
And the third input to the thing is the whole area of better regulation.
So that there is a lot within that particular domain that talks about advice and guidance to individuals.
So we have taken those three ingredients.
And our initial concept at this stage is that
we would divide the national inspection plan almost to two broad component parts.
And my colleagues, Margaret Keegan and Leo Sweeney,
will flesh this out a little bit more. But just to give you a taster of it.
We intend that the broad model will have an emphasis on site inspections
that we see happening towards the middle to the end of next year.
But that we will also, working with the water services authorities,
we will have as much involvement in the whole area of citizen engagement
in terms of incentives, to be able to help people to comply with the new legislation.
All pulling together to protect public health and the environment.
Just looking at some of the engagement strategies, we have,
when you land on the EPA website, in the front page, right in the middle,
it will guide you to our current advice and guidance,
which has been dynamic since the Bill was first published in that area.
That gives a lot of guidance. But we are going to be building on that over the coming weeks.
And we will have very very shortly a three minute video clip
just looking at the domestic wastewater treatment systems,
their various component parts.
And hopefully to dispel some of the myths around some of these systems.
As I said it will be running for about three minutes, and hopefully we will have it up ….
well the YouTube clip up in the next couple of weeks.
And we intend to do more on it.
We have thoughts of putting in a video clip
later on in the year – what to expect from an inspection.
Then just moving on to the inspections.
Look our over-arching requirements in relation to them is that
we will be looking at the operation and maintenance regulations,
the regulations that I was talking to you about.
We will be using, as Dara mentioned earlier on, the risk based approach.
And then the quick identification and remediation of problem sites would be our priority.
As I said, not every system is going to be inspected.
We are going to have to be very clever in terms of the areas that we select,
in terms of the focus being on the environment and public health.
I am indebted to Ann Doggin, who I had met earlier on.
Ann, thanks very very much for just some photographs of
some of the things that we are going to be seeing.
And the reason I think it was interesting on those…
if you look at those and you go back to the standards,
in terms of what they talk about, ponding, odours,
that the actual effluent is going into the system in the first instance.
Judging from some of these that there's actually a system in place at all…
some of the things that these inspectors are going to be faced with.
I should also tell you as well is that our intention is that
when the inspections take place that people not just identify where the issues are,
but will come up with solutions as well, for the house owners that are cost effective.
OK. The second section of the talk I want to talk about is just …
I am calling that ‘Reeling back the years'.
And I quickly want to go through in terms of the standards dating back.
Some of them now well over 30 years ago.
And they are broadly divided into three.
There's the SR6 which is '75 and it was again updated in 1991.
Following that there was research. There was the EPA manual in 2000.
Then there was further research in terms of Trinity College.
Then the standard in play at the moment is the EPA Code of Practice.
And we haven't stopped there.
We have some current research that is being led by Trinity College
that I just quickly want to tell you about.
OK, first of all, while I was reading the document,
I just plucked out a few little things that caught my eye.
Now this is going back to 1975, SR6-75.
I thought it was interesting that they talked about, even back at that stage,
there was an emphasis on the percolation area rather than the septic tank.
Now it's amazing, even to this day people think there's a whole load of magical stuff
that happens in the septic tank, and that's why you have to throw the cat into it and stuff like that.
There's all sorts of nonsense going around.
At the heart...and we now have huge research to be able to support that….
is that the key in terms of the treatment is the whole percolation area.
And it's important that that is fit for purpose.
Interesting, it talked about that the construction of soak pits should be discontinued.
This is now '75 bear in mind.
And then it said, in some cases, disposal into water courses could be acceptable.
And it then goes on, depending on a listed number of categories.
The last one I thought was really interesting is that the word inspection was mentioned
way way back there. And what do they talk about the inspections?
That the percolation area should be visually inspected periodically.
And what's changed ….
now we have a system where it's now enshrined in legislation
that inspections have to become common place.
Moving on to 1991, the concept of site assessment,
which later on was further developed by our colleagues in Galway,
it re-emphasised that the percolation area is the most important point.
I think the centre of what we are keen to debate
with people and to discuss over the coming days,
and in particular to our international colleagues, is that whole area of low permeability.
That's where I believe we are going to have huge challenges in this country.
And what I talk to there is low permeability can result in terms of ponding of effluent,
odour and nuisance, public health risks and surface water pollution.
Interestingly enough, because it changed later on,
both the '75 and the 1991 actually linked the percolation test with the sizing of the pipe.
The whole hydraulics wasn't factoring in at that stage. That changed in 2000.
And it re-emphasised that soak pits were not satisfactory.
And they were not an alternative to the percolation area, and shouldn't be used.
What happened in the interim?
Well when the EPA was set up 1992 one of the first requests that came from local authorities is,
would you sort out the whole area of septic tanks.
So we commissioned research that was awarded to the Civil Engineering Department in Galway,
and most notably Michael Rogers.
And I have to say, I am delighted that Michael will be here with us over the next two days.
Unfortunately who is not with us, and I really want to acknowledge some of his pioneering work,
is John Mulqueen, who did a whole load of work in the area of soils.
And I see one of his colleagues, Carol Richardson, in the corner there.
I just want to acknowledge John's great work,
both in Galway and also with Teagasc down through the years.
I thought what I would do is that I will give you a flavour.
Now this is back to '95.
But it's interesting, looking back at the reports, the questionnaire survey
and the responses to that later on.
But flowing from the research the predominantly two big outputs were…
there were two documents on the whole area of domestic wastewater treatment systems.
And we also had one on smaller wastewater treatment systems
for you know smaller communities, businesses, and we called it leisure centres as well.
So the survey, it was interesting, despite this 1975 and the 1991 guidelines
at the time in terms of no soak pits,
it was interesting that 63% of the systems connected to a septic tank
were in actual fact soak pits.
And even more interesting, if you look down through the results from the local authority survey,
what were the issues back then.
They were talking about ponding, pollution of wells, malodours,
the bi-pass with the direct discharge to the drain or the stream.
It was interesting looking at some of Ann's slides,
you are seeing a lot of those.
And then the construction of a soak pit instead of a percolation area.
Just what I am thinking is, I am wondering was there a requirement in the
planning permission to say percolation area,
but still people stuck with the actual soak pit. That I don't know.
But that was one of the findings.
OK, moving on then very very quickly, the 2000 manual.
One of the big things, even though '91 talked about a site assessment,
it fleshed out a little bit more.
It talked about the desk study, the whole visual assessment of the trial hole.
And then it talked about the percolation test.
To reflect reality on the ground,
it divided the percolation test into two.
But one of the key things that it was trying to drive at the time was that,
the whole site assessment was to determine the vulnerability of the
groundwater resources and also the assimilation capacity of the subsoil.
Going back, read back to '75, is look it was all happening in the percolation area.
I alluded to it earlier on, for the first time it linked the hydraulic loading
to the requirement for pipe sizing,
which is here to this day, and very very important.
Moving on then. So we had the two guidance documents published in 2000.
And in enters Lawrence Gill, Bruce Misteer
and the Civil Engineering Department in University College Dublin.
And they did some rigorous assessment on some of the ideas
that we had put into play in the manual.
And I am delighted Mark Ross is here.
…from the States…we used a stratified sand filter that he had developed.
And then we were looking at the different subsoil types,
both at the high end and in the low end, in terms of look at
the emphasis on the percolation area, the performance therein.
Then, moving on, the Code of Practice. So what was different?
You see how the research had a huge influence on what we had included
in the 2009 manual. The polishing area was reduced.
That was a reflection on the requirement of the biomat,
which grows underneath, in the percolation area, underneath the sizing of the pipe.
The idea being that it doesn't grow as long where you have a secondary treated effluent.
Presumably because of less organic matter.
So we reduced the size of the polishing filter pipework.
We increased on the other side the depth of the polishing filter.
Because we had built the system. At this stage we had tested it.
There were some changes required in terms of the sand sizes.
The reed bed design changed.
There had been huge surveys done in terms of the hydraulic loading
from individual houses, which you can imagine can be dynamic.
So we came down in favour of 150 as opposed to the 2000 manual which was 180.
And then the college did a huge amount of work looking at the modified percolation test.
Currently then we are now faced with going out.
And we know there's going to be sites requiring remediation.
So we have research that you will hear much about in terms of today and tomorrow,
looking at what research can do in terms of providing solutions to the problem sites.
And to looking in particular both in terms of the treatment,
but also more crucially is that the disposal of wastewater.
I have said it once. I will say it twice and I will say it a third time.
The big challenging area is going to be in the low permeability sites.
So that's ongoing at the moment. And we will share that with you.
My final slide in terms of what we are trying to achieve,
both over the last couple of years and from the symposium today is that,
look, research has had a major part to play in terms of the guidance,
in terms of the documents that we produced in 2000 and 2009.
We now want it to play a huge part in terms of the remediation of the sites.
Also, and you will hear tomorrow from a number of people
who have been involved in the regulatory frameworks,
we also want to pick the best regulatory framework in Ireland,
so that we have the best fit for this particular sector.
So with that I will hand you back to the Chairman,
in terms of the audience and the practitioners, it's as much about networking.
And I look forward to talking to a number of you
during both the interval and maybe later on this evening.
Thank you very much for your time.
0:00:00 / 0:00:00
Gerard O'Leary, Director, EPA
Setting the scene