The new ‘Code of Practice: Wastewater Treatment and Disposal Systems serving Single Houses (p.e. ≤ 10)’
Margaret Keegan P.Geo Inspector Public Authority Enforcement
Overview What is a Code of Practice?
What it is not?
Why we need it? How it was developed? What it contains? When will it come into force? What difference will it make?
What is a Code of Practice? Section 76 of the EPA Act authorises the EPA to prepare and publish codes of practice for the purposes of providing guidance, with respect to compliance with any enactment or otherwise, for the purposes of environmental protection It provides a framework for site suitability assessment, system selection, design, installation and maintenance of on-site wastewater systems Allows for innovation and advances in technologies once they have the appropriate approvals in place Competent persons are required for site assessment, system design, installation and maintenance What it is not?
It is not a receipe book that provides the solutions for all scenarios nor a complete design manual
Why we need it? (1) Build on EPA manual 2000 EPA 2000 not being applied uniformly across the country New European standards have been published (EN 12566) Additional research has been undertaken and the findings have been incorporated into the CoP More emphasis is needed on installation, operation and maintenance Enforcement to date has been poor in some parts of the country There are still poorly sited wastewater treatment systems being installed across the country
Why we need it? (2)
Low Permeability Subsoil
Why we need it? (3)
Looks ok from a distance
Close up – wet, lush grass, odours… Effluent!!
Why we need it? (4)
Flooding
Flood Plain
Surface water ponding
Why we need it? (5)
Why we need it? (6)
Trial Hole CLAY BS5930
T test hole
24 hours later
Why we need it? (7)
Karst
Shallow soils
Attenuation Problem – NOT Hydraulic
Why do we need it?
Water Services Act 2007Section 70 refers to the general duties of an owner or occupier & S.70(2) states: “The owner of a premises shall ensure that all drains, manholes, gullytraps and storage and treatment systems for waste water, including related accessories, not in the charge of a water services provider, which serve that premises are kept so as not to— (a) cause, or be likely to cause, a risk to human health or the environment, including to waters, the atmosphere, land, soil, plants or animals, or (b) create a nuisance through odours.”
How it was developed? (1)
A draft CoP was issued for consultation in 2007
built on the guidance contained in EPA 2000
Received 65 submissions that included over 1660 individual comments Submissions and comments were reviewed by the Agency Met with some of the stakeholder groups including DETA, IOWA, NSAI and DoEHLG to discuss their submissions
How it was developed? (2) Main Submissions Format to be changed Too much guidance Not enough guidance Legal position of the document to be clearly stated Increase scope of Code from 1-10 p.e. to 1-50 p.e. in line with EN12566 Discharge standards to be reviewed Discharge standard or % reduction or both to be stated Sites with T>90 being unsuitable, considered by some to be a problem for development in parts of the country Concerns raised with decrease in T value from 5 and 1 Issue of density to be better clarified
How it was developed? (3) Main Submissions continued. Minimium site size was raised Dilution calculations to be included Additional guidance sought on assimilative capacity and phosphorus limits in relation to discharges to surface waters Should highlight that many local authorities do not allow discharges to surface waters The chain of responsibility should be more clearly defined Emphasise the onus on the householder & on developers The upgrading of existing WWT systems should be dealt with in the CoP Provision for green technologies e.g. composting/dry toilets, evapotransporation ponds, willows, new technologies
How it was developed? (4) The CoP takes into account:
The requirements of the new CEN standard EN12566 Recommendations from new research, which also results in clarifications, improvements and corrections Input from practitioners on the workability and clarity of the document Consideration of comments and submissions made during the consultation process
What it contains? (1)
Part 1 details the requirements and standards to be achieved (Code itself) Part 2 contains further guidance on how to achieve compliance Key Messages are:
Importance of proper site assessment taking account of local conditions and of wider experience in the area, development plan and other policies The need for design of on-site wastewater treatment systems specific to the local conditions The need for follow through by the builder/homeowner/supervisory authority – i.e. installation/commissioning/maintenance as per design and planning conditions
What it contains? (2) Some Changes Performance standards for wastewater treatment systems Requirements of the EN 12566 series of standards and technical reports It allows for the use of innovative products and technologies, not specifically covered by the CoP so long as they are certified, are fit for the purpose for which they are intended and meet the performance requirements of the CoP A modified percolation test to be used for high T value sites An upper percolation test result limit for discharges to ground to take account of impervious soils (T>90 – site unsuitable for discharge to ground) Change to the acceptable range of percolation values for Septic tank systems (3 ≥T ≤ 50) Secondary treatment systems (3 ≥T ≤ 75)
What it contains? (3) Dilution calculations Improved design details for intermittent filters and polishing filters A new chapter on maintenance More emphasis on installation Site improvements more defined Improved Site Characterisation Form (electronic) Provides for the implementation of specific provisions of the Water Services Act
What it contains? (4) EN 12566
EN 12566 series and their publication is the remit of the NSAI: Part 1: Prefabricated Septic TanksPublished by the NSAI as an Irish Standard Part 2: Soil Infiltration SystemsPublished by the NSAI as a Code of Practice Part 3: Packaged and/or Site Assembled Domestic Wastewater Treatment PlantsPublished by the NSAI as an Irish Standard Part 4: Septic Tanks Assembled In-situ from Prefabricated KitsPublished by CEN as a standard Part 5: Pre-Treated Effluent Filtration SystemsPublished by CEN as a technical report Part 6: Prefabricated Treatment Units for Septic Tank EffluentIn preparation Part 7: Prefabricated Tertiary Treatment UnitsIn preparation
What it contains? (5) Site Characterisation form
When will it come into force? Draft CoP with the Minister for Environment, Heritage and Local Government for comment Code of Practice will come into force on specified date. Notices will be in national newspapers and in Iris Oifiguil It will be admissible in court The DoEHLG intend to issue guidance by means of circular letters to all local authorities DoEHLG to amend the Building Regulations to reference the CoP EPA to withdraw EPA 2000
What difference will it make?
NONE unless Competent/professional assessors, installers and maintenance contractors are used and provide documented evidence of assessment, installation, operation and maintenance Homeowner/ Builders accept responsibility to ensure that wastewater treatment systems are “kept so as not to…. cause, or be likely to cause, a risk
to human health or the environment, including to waters, the atmosphere, land, soil, plants or animals, or create a nuisance through odours.”
Acceptance that NOT all sites are suitable for discharge of treated wastewater to GROUND ⇒ Sites will FAIL Packaged Treatment Systems not the panacea in all cases….. Effective enforcement through the planning and water pollution regulations is essential to ensure protection of environment and human health
THANK YOU
Photographs gratefully received from Donal Daly, Robbie Meehan and Toddy Radford