Good morning. Thanks very much, David, for the intro.
And just to thank Margaret and Leo and the EPA and Laurence Gill, Trinity,
for the invitation to speak today.
Just as, well before I start, most of what I am going to talk about this morning
is just research that I carried out as part of my MSc that I completed in IT Sligo.
And it gives an overview of how local authorities are dealing with existing onsite treatment systems.
We are all aware of the planning system that deals with new systems.
But this is kind of looking at ones that are there for up to maybe 100 years or more.
So what I am going to look at this morning is, I am just going to give a small overview on background.
I am going to look at some of the methods that I used to conduct the research,
the results, and just a small bit of discussion and conclusions.
Some of the conclusions have been addressed in what Leo and Margaret
have already just spoken about. But I hope it’s of interest.
And if there’s any questions I will deal with them later.
So just some of the background.
The onsite wastewater treatment systems have been identified in many reports
as you are all probably well aware, as a potential source of direct and diffuse pollution.
3% of the nitrate, 7% of the phosphorus nutrient load to surface water
is attributed to septic tank and different types of treatment systems not operating properly.
And that was some of the work carried out by the Western RBD.
And up to half of faecal contamination is caused by onsite wastewater treatment systems.
From a local authority point of view most times that we find out that there’s a problem
with a septic tank or a treatment system is when someone gets their water tested,
there’s an odour, there’s a taste, or it’s showing up with high e-coli or coliform levels.
And we will head out, we will have a look and see what is the story.
Now as you saw yesterday more up to date figures,
but the 2006 Census reckoned there was just under 460,000 unsewered properties.
So that’s including properties that have declared they have no treatment system.
Now while this is mainly a rural phenomenon it’s interesting to note
that when you break down those figures, there’s nearly 30,000 that are classed
in what the CSO called urban influence areas.
Out of those 460,000 about a third of them have a non-group water scheme well.
So they have their own private well onsite.
So the potential for contamination of drinking water if not working properly is quite high.
And no presentation is complete without a few pictures of septic tanks gone wrong.
So as you can make out there we have a lovely fluorescent green colour in the middle
where this guy says, I have no problem with my septic tank.
So do you mind if we put in some dye? No. So this is what we find in the neighbour’s field.
And this is one of the issues for local authorities.
Many houses may have been built when the land beside them was owned by a family member.
And over time, ownership changes.
So you can end up with a situation where you have one owner of the house,
you have one owner of the field beside it, and often tensions flare.
And that’s where the local authority are called in.
Just a few more points on the background.
As has been mentioned already the new inspection regime is coming in in 2013.
So when I started looking at this in September 2011,
I decided to have a look and do some research on what was the current practice
being employed by local authorities for existing systems,
examine what is the best practice and also what were the resources available,
what were the issues on the ground?
And also as well to look at what were possible options and solutions that could be brought forward.
And as part of the whole reason for the symposium is to add to the knowledge
and hopefully come up with some ways of dealing with it.
The research was carried out in three main methods.
So there was an email questionnaire to the 34 local authorities.
I did a case study and interview with Cavan County Council,
and then also a focus group to review the findings and discuss some of the issues.
In terms of the email survey it was sent to the 34 local authorities.
We got a reply from 23 of the local authorities, with two of these stating
they did not carry out assessments, obviously enough some of the city councils.
21 local authorities then formed the basis for the analysis of the survey.
And we got…or I should say, I got a response from a wide geographical spread.
So it wasn’t just all the counties around north Tipperary.
We managed to get from Cork to Donegal.
So we got a good overview of what was happening throughout the country.
A case study then was also carried out looking at Cavan County Council.
And I focused on Cavan because they had introduced the
by-laws for treatment systems in 2004.
They had about eight years’ experience of the by-laws,
how they had actually worked on the ground.
And they were also noted as the exception in the European Court of Justice case
against Ireland for non-implementing the Waste Directive.
And I would have done an interview there with Colm O’Callaghan,
who is the Senior Executive Scientist in Cavan.
I just want to add as well, just a thank you to all the local authorities
who replied to the questionnaire. It’s very much appreciated.
Finally then was a focus group.
So the focus group was made up of representatives of three local authorities.
So there was North Tipperary, Roscommon and Offaly…we also…different grades of staff.
So we got involvement from technicians all the way up to Director,
to give a different overview.
Because often senior management have a different view on things than people on the ground.
And it’s good to get all those viewpoints together.
And we also had representatives from the EPA, and also from IT Sligo.
And why they were brought together was to consider the findings of the analysis
of the questionnaire and the interview, just to make sure that I wasn’t being
overly blinkered and only looking at one particular thing, and identify gaps,
highlight possible options.
So the result of the research is that local authorities were asked
if inspections were planned or reactive to complaints.
Six local authorities out of the 21 carried out proactive inspections.
Most carried out as part of regulatory protection plans,
this is out of the six that carried out the proactive ones.
So they were carrying out septic tank inspections in areas
that were say for shellfish protection plans, drinking water protection plans.
When you look then at the staffing levels, of the local authorities
only one local authority had full-time staff involved with dealing
with problem existing treatment systems. There was 52 staff involved part-time.
This total, say 54 staff, would have carried out 448 proactive inspections
and 295 complaint related inspections.
Now this was roughly from say Spring 2011 to Spring 2012.
So roughly about a year of a period.
Staff time involved in the investigations varied from county to county.
Now you can see in this table here the top row is showing you, of the 52 part-time staff
the number of staff, and the bottom is showing you there the percentage of their time.
So we had 5 staff that only 1% of their time was involved in carrying out inspections.
23, 10%. 4 staff it was 20% of their time.
And 25% of their time, it was only for say 6 of the 52 staff.
When you add it all together it works out at roughly 5.35 full-time equivalent staff
carrying out these inspections in the 21 local authorities.
So what does an average inspection consist of?
A visual inspection, what I did was, in the questionnaire we gave people the different options
of what would be included in a standard inspection.
We asked them to rank them, put them together.
So common ones that came back were, a visual inspection of the tank
and the area around it for signs of ponding.
We have examination of the curtilage of the dwelling,
mainly looking at how the different connections –
was grey water going to a clean water source, etc.
Check the grey water connections as I mentioned,
and examination of adjoining land drains, where possible.
And I will give you an example in a few minutes of where everything doesn’t always seem as it is.
So dye testing was less frequently used in planned inspections than in complaint inspections.
Obviously enough this is reflected in the number of visits.
So for a compliant site, the average was just one visit per site.
So you visited the site, if you didn’t note any malfunction, any problem, that was it,
you moved on to the next.
In terms of non-compliant sites then, you will see here the number varies,
and you see the number of local authorities.
So out of the 21, two to three visits seems in around the average there.
It’s covering about 17 of the local authorities. Some of them just replied many.
Because with dealing with a non-compliant problem septic tank there’s never
that you can say this is only going to take two visits.
We are dealing with some in North Tipp that have taken five and six visits
where it’s going out trying to meet the home owner, trying to meet agents,
checking that work is done, going back to check that, you go out one day only part of it’s done,
you go back then to make sure that the rest is followed out.
And obviously enough then, that has an implication in terms of the resources that are required.
So what was the cause of these malfunctioning treatment systems?
So again the councils were asked to rank what they thought was the number one cause,
number two and so on.
So the number one cause was ground conditions unsuitable for the hydraulic loading.
Number two was the septic tank or treatment unit was cracked and leaking.
Number three was that grey water connected to a soakaway or drain.
Four was an unlicensed direct discharge to surface water.
Five was pumps and other electrical or mechanical components faulty and not repaired.
And, as spoken about yesterday, we have come across some sites where it was never turned on.
The power connection, a brand new treatment system, cost €3,000, put it into the ground
and they never wired it up to electricity. So you would often wonder.
And also then finally the system is not being desludged.
So we have there ranked in order of what was the most common cause
of the malfunctioning systems. And then percolation area compacted or built upon.
This is particularly now with older houses where people actually forget
where the percolation area was originally installed.
They decide they want to put an extension onto the house,
so where better to place the garage than on top of the percolation area.
What harm will it do? You know.
Proactive inspections. They are mainly meeting the regulatory requirements.
And this is partly an effect of limited resources.
You have to carry out your inspection plan say to protect your public health being a key priority.
So three of the five reasons for malfunctioning treatment systems as we saw there
were due to installation and maintenance issues.
And there’s a mismatch that strikes me between the proactive inspections carried out and the causes.
Because, of the six local authorities carrying out the proactive inspections,
four of those were dealing with shellfish and drinking water.
Whereas you will see there the number one cause is that the ground conditions aren’t suitable.
But this is down to resources and prioritisation.
And just a couple of pictures there of problems.
The top one there is actually the problem solved where all those pipes
were going to the surface water, and they are now connected into the WC system.
And the bottom one there is our favourite flourescein dye showing again
why this man’s treatment system isn’t working properly.
So a follow up of inspections, how they are actually carried out.
This is in terms of the enforcement measures that we carried.
So the number one was that a notice is issued under Section 12 of the Water Pollution Act.
This basically is an instruction from the local authority to the householder
to carry out particular works. It can also be simply just stop the discharge.
Number two was proposals are requested from the property owner,
a programme of works outlined to the householder, done in letter form.
So a slightly less formal approach. And then a Section 23 notice.
Now the Section 23 notice is a formal request for information.
So this would normally follow on from if the letter has been ignored.
And then prosecution under Section 3 of the Water Pollution Act.
So this is where you have your direct discharge into your land drain or watercourse.
So you go straight for a straight prosecution.
In terms of how local authorities actually assessed the proposals that were coming in,
they were asked in terms of what standard would they use.
38% there said they used the EPA Code of Practice. 48% fit for use.
And we got no reply from a number as well.
So other criteria as well that they would have used to examine the proposals
were public health issues.
So distance from wells, how does the proposed system fit in on site,
how near will it be to water courses, neighbours?
Then as well surface and groundwater quality in the area. Public nuisance. Cost.
And finally type of system proposed and the details of the proposals.
Now obviously enough that last one there will be considered throughout.
But it will be coloured by public health issues.
So very quickly now I am just going to go through the last couple of slides.
The disposal of the sludge from it, 80% of local authorities said
they would accept domestic wastewater…or sludge, subject to terms and conditions,
such as the capacity of the treatment system.
Local authorities were asked if they allow farmers to spread their own sludge on their own lands.
38% said, yes. 52% said, no.
There is an option there in the use of sewage sludge in agriculture that permits it,
but there’s terms and conditions, and many fear that farmers won’t…
or people in general won’t comply with those.
So some of the issues raised anyway, standards and guidance, resources and public awareness.
So some of this has already been covered.
There seems to be…to get consistency between use of an alternative standard
and the 2009 Code of Practice, also in terms of the standard of the treatment system
that’s used, possibly of a combination say for the treatment system
that you would use the Irish Agrement Board certified ones,
or from a list of approved international accreditors such as USEPA and so on.
Also you need to get compliance with Part H of the building regs, avoid legacy issues.
What I mean is that the local authority doesn’t tell somebody to do something,
when they go to sell the house then it can’t comply with part H of the building regs,
you want to try and avoid that.
So guidance for local authorities would be the need to …
how you deal with specific problems such as small sites that can’t meet the separation distance.
More information on use of say dye testing.
There was a talk yesterday about using say caffeine, boron, that type of thing,
to help particularly with water complaints.
Sorry now just two more slides and I will finish up.
Just to give you an example of some of the problems.
You see here the picture on your left there, that just shows you a house we inspected.
You go out, you have a look at that, you can’t see many issues there, we spoke about it yesterday.
Nice green lawn, no signs of ponding.
To the right there you see what the local stream looked like.
You can even see a tint of our dye again showing.
It just shows you some of the issues that when you initially go out
and do your non-intrusive inspection, all may not be what it seems to be,
and that’s where it’s important to get focused.
I just want to talk about the financing and the costs.
This is something that John O’Rourke in Roscommon County Council just flagged.
If everyone pays the €5 registration fee it gives you roughly about €2.25m of a fund.
This lasts for five years.
If you were to put a technician in a van on the road,
the cost of the van and the technician is estimated at €70,000 a year.
So for one year it’s just under €2.4m.
So obviously enough there’s a shortfall there, because that €2.25m
is supposed to last for five years.
And if you only look then at the rural counties it’s still €1.8m.
So these are some of the questions that need to be done.
Also a need for public awareness, because many people don’t have preconceived
misconceptions of how their treatment works.
Sorry, I am flicking through this, you can get it more in the paper that you have already.
But people have this notion that you should never empty, desludge a septic tank,
that the dead cat will solve everything out. It will get it going again.
So this is the challenge to get people to stop thinking in those ways.
Many people coming on the radio saying that if the grey water goes in
it kills off your treatment system and it goes unchallenged.
And it's very hard then when you go out trying to get people to upgrade.
So thank you very much for your attention.
0:00:00 / 0:00:00
Seamus O'Brien (North Tipperary Co. Council)
Local Authority Assessment of OSWWTS - Practice, Issues and Options.