This memo has been cleared for submission to the Board by the Senior Inspector, Dr Karen Creed Signed: ->,,.> Date: .. . -

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OFFICK O F C L I M A T E , LICENSING & R E S O U R C E USE.

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DIRECTORS ..

E nvi ron me n ta I Programme

Licensing I

From: Orla I Iarrington - ~. . . ~

Date: 1311 0/09 ... - . .-

Application for a Waste Water Discharge Licence from Limerick County Council, for the agglomeration named Newcastle West, ! Reg. No. D0108-01

S c h e d u l e of d i scharge licensed:

L i c e n c e application rece i ved :

Notices unde r Regulation l8[3)(b) issued:

Information under Regulation 18(3)(b) r ece i ved :

Site notice check:

Submissionlsl Received:

Discharges from agglomeratioi with a population equivalent between 2,000 and 10.000.

22 S e p t e m b e r 2008

281 1 1 /2008

16/01 /2009, 25/03/2009

1611 0/2008

None

1 .Agglomeration

'I'liis licence application relates to tlic agglomeration of Newcastle West. in County Limerick. The wastewater treatment plant (M'WTP) as coiiimissioned i n I OS4 with a design capacity of9,000 P.E. The ciirrciit load to the plant is estimated to be 7.356 P.E., with a projected P E in 2014 of9.864 P.1:. A review ofthe licence would be reqiiired to accommodate a loading o f Over 9,000 P.E.

IIie sewerage network in Newcastle West is predominantly a combined system with the cftluent gravity fed to the wastewatei treatiiieiit plant. The average llow reading based on rccords from January 2008 to end July 2008 is 2,46Om'/day. 'The effluent undergoes secondar. treatment with nutrient removal. I t enters the treatment facility where it is split into t\+o oxidation tanks and then discharged to settleinelit tanks. The resulting liquid is discharged to the outlet chamber where it discharges to tlic River Dee1 as S W I . There is ferric closing on site for phosplrorus removal.

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CATECOKY Existing domestic Load Existing Non Domestic load-

Existing impostcd loid

Pending Development (uitliin 6 yrs of license) Futurc Connections (Domestic)

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2008 BASIS 7.~. housc OF ESTIMATE count 5.250 Ll, I.imerick County Council Flow 1.726 Recosds Leachate Volume Rccords , 371 (Uischargcd directly to plant) Existing load 7,356 Limerick Count) Council I ,008 Planning Department Ardagli 8 Castlenialioii Villages 1.500 (pumped direct to plant) Future Estimated Loads in 6 yrs 0.864 -

.~ ~,’

Following discussions with the I'ublic Authority Enforcement. it was found that they have no enforcement actions open against limerick County Council (LCC) with regards to Newcastle West W W T P .

However the Newcastle West agglomeration was lion compliant in 2007 with the requirements of' tlie Urban Waste Water Treatment Regulations as amended (S.1 No. 254 of 2001 and S.1 No.430 of 2004) on the basis ofeffluent qiiality' i.e. of'tlie I 5 samples taken for BOD testing 2 samples liad BOD le\eIs >25mg!l.

'There is phosphorus removal onsite and ati~iual averages for the priinary discharge are I .73mg/l for ortho phosphate. The effluent quality monitoring results for Total Ammonia vary significantly ranging from 1.54mgil to 40.31ng/l.

There are two otliei. interconnected combined sewer overflows_ SW2 and SW3. S W 2 is a concrete outfall pipe located in the South Quay and S W 3 is located at tlie North Quay in the centre of Newcastle West. They both overllow to tlie River h a , wliicli is a tributary of tlie River Deel. The cuinulative effect of SW2 and S W 3 is considered to be of medium significance under tlie DOEHLG 'Procedures and Criteria in relation to storm water overflows' 1995. It was reported in tlie waste waster discharge licence application that unrecorded complaints liad been received from tlie public. as tlie overllows are in a highly visible area of tlie town. The KL requires tlie licensee to record all complaints of an environmental nature. related to the discharge to waters from tlie waste water works i n accordance with the national environmental complaints procedure. LCC have assessed tlie storm water overflow (SWOs) and have identified a number ofshortcomings:

The overllows are known to operate in dry weather. This is due to blockages and is an operational problem. The overflows need to be designed for the effective containment of detritus and floating debris. SWOs should be designed iii accordance with the Criteria outlincd in tlic DOEHLG 'Procedures and Criteria i n relation to storm water overflows' 1995. 'This document states that storm overflow structures should be designed in accordance with the W R c publication ER304E2 with acceptable types of overflow strii~ture limited to high side weir, stilling basin and vortex chamber overtlow designed to achieve efficient solids separation and retention.

In tlie licence application Section 2.4 Attachment C.1. LCC has listed recommended improvements to the existing overtlow. The RI. S'checl~tic. C'Z: S/ierific.c/ Iniproven~enc Programme ,for S/orm U'urw Oi~erf/oiv.s will require the licensee to complete tliesc improvements by end 2012. ('onr/i/ion 4. / I i i i tlie licence requires an assessment of the SWO's for compliance with tlic DOEHLG criteria on an ongoing basis.

Waste Water Treatment Plant

The plant is not operating efficiently. The applicant has identified six inaiii problems, which are contributing to this:

1 Comminuters are not operating satisfactorily. Large amounts of solids (paper. rags, grit) are entering the plant. which effects the efficiency oftlie plant. Existing Fuch spiral aerators in the oxidation ditches are not achieving adequate aeration and mixing to facilitate nitrilication. Not enough sludge is being \+asled from the process. which is dependent on Runlicky sludge plant accepting dewatered sludge. There is 110 storage on site at Newcastle West and this affects the ability ofthe operator to waste sludge from tlie process.

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' EPA urban wastcwalcr discharges in Ireland for population equivalent greater than 500 persons. A report for the years 2006-2007

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. Existing feriic dosing iii the plant would be more effective if reductions in solids are achieved. There is 110 balancingistorm tank tlicrclorc sudden increases in flows and leacllate loads can liavc an adverse cffcct or the plant. There is a noticeable differencc in the oxygen readings wlicii thc lcacliatc is discharged into the inlet chamber. I t is located it1 the lowest part of the catchtiicnt, which is regularly subject to flooding. The river watcr can sometimes backflow into the outlct chamber. 'This can occur after several days of heavy rain

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The RI, requires improvcmciits to be undertaken to address the operational problems outlined above by tlic 3 I " December 2012. This is addressed i t i Sciieriuie C': Specified inzprow'nent progruiiime.

3.Receiving waters and impact

The following table siitniiiarises tlie main considcratiotis in relation to tlie Dee1 River.

Table 2: Receiving waters

Characteristic Rcceiving water name and type

Resourcc use

Amenity value

Applicable Regulations

Designations E P A monitoring stations

Biological quality rating (Q value)

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Target Q WFD status

Category WFD protected areas

Classification River Dccl

River Arra Drinking water

-~ Game fishing

Surfacc Waters Regulations 2009 ~- __ UDlC I

None 24D020700

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24D020800 Q3 2008 upstream (improvement from 2005 Q value) Q4 2008 downstream (improvcmct from 2005 Q value) Q4 dowtistrc;rm ~~~ of discharge Poor

~~ .~ I a(at risk of not achieving good status) SPA 004077 River Shannon/Fergu

Askcaton Drinking Water Ilivcr

Tributary of Dee1 Drinking wsater abstraction 24km downstream at Askeaton. Not designatcd salmonid waters Monitoring data in application indicatcs non-compliance with the following parameters: Total Atnmonia. Ortho P, and BOD.

~- Hridge near Killaready (140tn ds ) ___ Grange Bridge (3.1 km dis) Q2-3 2005

03 200s

Downstream of 1 '' discharge huie 2

I>o\vnstrcam of I " discharge U,>,< 2

Approx 22 km downstrcam

Approx 20 kin downstream

"S s.i zo 212 0 i 2 n o 9 ract,\c ,maps

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Monitoring undertaken by tlie Agency indicates that tlie quality of tlie receiving water was rated in 2008 as being Q3 downstream of tlie discharge point and Q3 iipstreain of the discharge point. 'I'here is no designated site (SPA or SAC) in tlie genei-al vicinity of the discharge, or in the catcliinent of tlie receiving waters. with tlie exception of tlie Shaniioii Estuary, wliicli is approximately 22Km from Newcastle West. It is unlikely that the discharge wil l have any significant ilnpact on tlie Shannon Estuary. and no 'appropriate assessiiieiit' of impact ofthe discharge is therefore required.

Due to the acceptance and treatinetit of landfill leachate there is an increased risk of dangerous substances within the WWI'I' discharge. The KL spccifies biannual monitoring of relevant metals and organic compounds in the primary discharge (SW I ) . The applicant has identitied long-term capital works, which include the installation of an anoxic tank [or de- nitrification. The KL requires the installation ofan anoxic tank by 31/11/12.

The assessinerit of the impact of the wastewater discharge considered the wastewater composition and quantity. receiving water monitoring results. and assiinilative capacity calculations. The dilution factor is approximately 19 on the basis of Dry Weather Flo\i (DWF) discharge voluine (0.023m3/scc) and 95%ile flows in tlie Kiver Decl. This figure may fall to 14.5 dilutions as discharge voluine increases in future years.

Assimilative Capacity results in Table 3 and 3b are presented for both tlie existing population equivalent of c. 7.405 [).e. and tlie plant design capacity of 9,000 p.c. with reference to the relevant water quality standards.

Median river llow lias been used i n the caIc~ilatioii~ for orthophosphate. whereas 95%ile flow was used for all othcr parameters. 13ackground concentration values are taken from monitoring conducted for the application.

Table 3: Assimilative capacity calculations - - existing plant at 7,405 p.e. 1 Parameters 1 Discharec 1 I3;ickeround 1 I'rriniissd 1 Ciinlrihuliiin I l'miclecl 1 I

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Ortho-Phosphate

Monitoring undertaken in tlie River Dee1 by tlie Agency i n recent years has indicated that the quality of the receiving water lias showed significant improvement both up stream (Q2-3 to Q3) and downstream of the primary discharge SWI (Q3 to 04). These ratings indicate that while upstream of the WWTP is moderately polluted the contribution made by the effluent on the downstream Q rating is marginal. 'l'his Q4 rating for downstream is consistent with 'good status', which is required to be inaintaincd under the Water Framework Directive.

There is iio assimilative capacity for ortho-phosphate in the River Dee1 due to upstream activities. 7he incan upstream concentration of ortho-phosphate is 0.1 I mg/l. This is 433% of the target ortho-phosphate concentrations for 'good' quality rivers of <0.035mg/l (mean) under tlie European Communities Environmental Objectives (Surface Waters) Regulations 2009 S.I No. 272 of2009 (Surface Water Regs 2009).

With regard to reduction of background levels for the various parameters. Limerick County Council (LCC) have a dedicated water quality management team who are targeting sources (primarily agricultural) of these parameters in the County. The Phosphorus Regulations National Implementation Kcport. 2005 published by the OEE lists some of the work undertaken by LCC i i i identifying and rectifying significant sources of phosphorus loading. LCC have performed septic tank and farm surveys. Risk assessments relating to slurry storage and silage effluent containinelit. Minor works are remedied and re-inspected for compliance. Where ina.jor problems are identified. tlie farmer is asked to submit an Effluent Management Plan, prepared by his agricultural adviser within 6 weeks. When these works are completed a re-inspection is carried out to ensure compliance. While these measures are aimed primarily at phosphorus, they can be expected to have an impact on other parameters such as ammonia.

In the case of sewage treatment plants ICC: in their application state that they, 'propose to limit any individual increase i n ortho-P i n the receiving waters to O.Olmg/l at 50%ile flows'. The RI. requires the primary discharge (SWI) to meet the ortho-phosphate ELV of Img/l until 3 1/12/12, which equates to an increase in the ortho-phosphate level in tlie receiving water at median flow of0.01 mg/l and compares well to the relevant water quality standards. It is also iii agreement with LCC proposals. The average ortho-P concentration in the primary discharge (SWI) is 1.73mgil. 'I'hc ELV o f I ng/l is nearly half of the current discharge concentration and will require additional ferric dosing to achieve this.

.The proposed 13.V for 01/01/13 is set at 0.5mg/l ortho-phosphate having regard to the EPA Waste Water Treatment Manuals: primary, secondary and tertiary treatinelit Table 7.1 Achievement of a 0.5lilg/l ortho-I' limit requires not just ferric dosing; it is dependant on an efficient treatment process. 'I'he licensee will he required to complete the improvements set out in Schediile c': Sjxcificri iiiipvowiiiwi/ progroinrile i n order to ensure compliance with this ELV. This ortho-phosphate coiicentratioii will make a significant contribution to maintaining Q4 status in the receiving uatcr. It will reduce the contribution made by the primary discharge on tlie downstream concentration from 0.0 I mg/l to 0.003mg/l.

Condition 5 of the RL requires a programme of improvements for tlie Newcastle West WW-I'P. Schedirle C': .spi~cijid iiiipri)i'eiiwi?l pro,cyaiiiiiie i n tlie RI . will require the licensee to complete iinprovcmcnts by 31/12/12 to allou the plant to meet the ELVs post 2012.

The water quality i n the River Arra. which is tlie receiving waters for the storm water overflows, lias deteriorated from Q4 to Q3. which is the lowest rating since 1996. The RL Schedule ('2: S@cified itniimwiiien/ prograiiinie ,fur .sluriii wa~cr overflows will require the licensee to complete improvements by end 201 2. Condition 4. I I i n the licence requires an assessment of the SWO's for compliance with tlie DOEHLG criteria on an ongoing basis.

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Total Ammonia

l'he Dee1 w#ater quality imanagement plan specifies a limit of 0.5mg/l N total ammonia (959'0ile). It also specifies a limit of 0.02mg/l N of un-ionised ammonia (95%ile). These figures have been established from The EC Directive on the quality of freshwaters needing protection or improvement in order to support fish life (78/659/EEC). 111 aqueous solution, total ammonia is present in two forms tin-ionised ammonia (NH3-N) and ionized-ammonia (NH4+-N). .I'he tin-ionised form is regarded as the form that is toxic. Concentrations of the toxic un-ionised ammonia increase with elevated temperature and pH. Non-ionised ammonia levels i n freshwater. are directly intluenccd by the pH and temperature levels within the water body. The relationship is depicted i n tlie following table:

Table 4: Concentrations in MilligramsiLitre of Total Ammonia in Fresh Water, which contain an un-ionised ammonia concentration of 0.02mgil NH3.

Source: Parameters of Water Quality Interpretation and Standards (EPA. 200 I )

The pl I and temperatiire monitoring in the application shows a 959"ile temperature reading of 15°C and a 95%ile pll reading of 8.6 upstream of primark discharge point (SWI). At these levels the background concentration of' total aiiiiiiwiil required to give rise to 0.02mg/l un- ionised ammonia is 0.25mgil (refer to table 4). A total ammonia limit of 0.5liig/l is not low enough to meet the 0.02mg/l tin-ionised ammonia. I t is also noteworthy that the value of O.O?mg/l as set out in S.I. No. 293 of 1988 is :I long-term toxic effect level for fish. both salmonid and cyprinid. Lethal lcvcls are considered to be approximately ten times greater than tlie 0.02mgil limit.

The Surface Water Regs 2009 specify a limit of <0.140mg/l 95%ile or a iiieaii value of <0.065mg/l total ammonia for good status rivers. Froin information provided in the application it is evident that there is limited capacity tipstream ol' discharge point SWI for total ammonia. The mean upstream concentration of total ammonia is 0.09mg/I. 'I'he total ammonia concentration in the discharge ( SWI ) ranges from 1.53 to 40.3mg/l. The mean total ammonia measured downstream of the WWIl' is 0. I Smgil which is an increase of 0.06rngil. The 95%ile downstream is 0.286mgil which is an increase 01'0.1 76mg/l both of which exceed tlie Surface Water Kegs 2009.

The assimilative capacity calctilatioiis have demonstrated that tlie predicted downstream concentration of total ammonia with a proposed E1,V of 15liig/~ for the primary discharge is 0.88ing/l. The ELV is representative of tlie current primary discharge (SWI) prior to any improvements being implemented. The do~nstream ineasured concentration is signilicantly less than that predicted by tlie assimilative capacity calculations. Furthermore the calculations assume a discharge concentration equal to tlie ELV at all times. which is quite a conservative assumption.

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The ELV is based on existing discharges from the primary discharge point (SWI) and as a result will not cause further deterioration in the quality o f the receiving water. Improved performance will be achieved \\hen upgrades are completed. These tipgrades combined with monitoring requirements specified in Schcduie U in the RI> should ensure compliai~ce with ELV post 201 2.

The KL requires ambient moltitoring to demonstrare no deterioration in tlie receiving water in the interim and to confirm improvelnent in water quality following remedial measures. The RI. requires that post 2012 the ELV for total ammonia will be Imgil giving a predicted downstream quality of 0. I33111g/1. which compares favourably with the relevant 95%ile total ammonia water quality standard of 0.140tng/l. De-nitrification in the plant is required to meet this level of ammonia in the discharge. C’onr/i/ion 5.4 of the RL states that the licensee shall complete tlie improvements as set out ill Schcdiile C‘: Slierified Iniprovenwnf Profimninie in order to ensure compliance \\it11 tlie emission limit values as set out in Schediile A : Di.sc/mrges of this licence.

noi)

l h e W W T P lias secondary treatment and was designed to achieve a 25mgil BOD concentration. The background for BOD is 2.68mg/l. There is 110 assimilative capacity in the River Dee1 for BOD. The primary discharge at 95%ilc flow will increase the BOD concentration in tlie receiving \vater (River Dccl) by I .2mg/l. ‘l’hc proposed ELV for BOD is 251ngil and lias been ttsed i n the assimilative capacity calculations in ‘fable 3. The RI, proposes that post 201 2 tlie FLV for ROD wi l l be I5mg/l giving an increase of 0.59 mg/l. In these circumstances. an increase of 0.59 mgil ROD is considered reasonable with respect to the relevant water quality standards and is below Limerick County Councils proposal of I ingil BOD increase in tlie receiving water.

Monitoring undertaken i n the Kiver Dee1 hq the Agency in recent years has indicated that the quality of the receiving mater 118s sho\ved significant improvement both up stream (Q2-3 to Q3) and downstream of the primary discharge SW I (Q3 to 04). These ratings indicate that \vhilc upstream of the Waste Water Treatment Plant (U’WTP) is moderately polluted the coiitribution inade by the effluent 011 the downstream Q rating is marginal.

4.Ambient Monitoring

The RL requires monitoring of the receiving water for a range of parameters both upstream and downstream o f priinar!, discharge. This is to verify that no deterioration of the receiving water quality is occurring due to discharge.

S.Combined Approach

The Waste Water Discharge Authorisation Regulations. 2007 ( S I . No. 684 of 2007) specify that a ‘combined approach‘ in relation to licensing of waste water works must be taken. whereby the emission limits for the discharge are established on tlie basis of the stricter of either or both. the limits and controls required under the Urban Waste Water Treatment Regulations (S.I. No. 254 of?OOI) and the limits determined under statute or Directive for the pitrpose of achieving the ctiviroiitiiciital objectivcs established for surface waters, groundwater or protected areas for the \hater body into \chich the discharge is made. The RL as drafted gives effect to (lie principle of the Comhincd Approach as defined in S.I. No. 684 of 2007.

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6.Programme of Improvements

The monitoring required under Scheride U. I reqiiires that a composite sampler be installed on the effluent stream within 3 inonths of tlic date of grant ol licence. Composite samplers are required under Schedule 5 of the IJrban Waste Water Treatment Kcgulations 2001. Limerick County Council rccomniends a programine of improvements to eliminate some of the operational problems at tlie plant:

To eliniinatc tlie difficulties with blockages installation of a fine screen (6mm) with bypass and \\asher Construct a holding tank for the disposal ofthe leacliate so it can be released slowl) into the process and avoid shock loading. Construction of tidal tank and non-returii valve at tlie outlet to tackle the problem of backflow into the outlet cliaiinel at times ol'lieavy rain Detailed hydraulic modelling of the sewerage network is also proposed to be undertaken witli a view to reniove or improve tlie operation of the SWOs. It is reconimcnded to construct sludge storage facilities on site i i i Newcastle West. as adequate solids are not being \\asled lrom the plant process. Install a dedicated anoxic tank for de-nitritication

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Tlie I>epartinent of the Environment, Heritage and Local Government are awaiting proposals lrcim Limerick County Council to prioritise a ~mgrainme of improvement uorks for Newcastle West WWI'I'. 'I'he upgrade of tlie WW'I'I' is included i n the Water Services Investment I'rograminc (WSIP) under 'Schemes to advance through planning'. Tlie DoEH&I.G will provide a total allocation ofE14.6M. Liinerick County Council proposes to apply to the DOEHKiLG for fiinding to complete tlie abwe improvement \\(Irks with a view to having thein finished w i t h i n a 3 year timeframe namely by end 2012.

7.Compliance with EU Directives

In considering the application. regard was had to tlie requirements of Regulation 6(2) of the Waste Water (Discharye) Authorisation. Kcgulations. 2007 (S.1. No. 684 of2007) notably:

Drinking Water Abstraction Kegulations

There is a ground water abstraction point approximately 15Km downstream at Ratlikeale. Tlie water supply for Ratlikeale is served by a borehole and spring sotirce. They are located 2.8Kin and 2.SKin from the River Dee1 respectively.

Tlie nearest \*atcr abstraclion point on tlic River Dee1 is 2 I K m do\\nstreain of tlie primary discharge point (SM'I) at Askcaton The Ilcel has K P A (register of protected areas) status froin Rullaun 20 Km downstream from SWI to Askcaton. a length of approximately 4Km. The applicant provided a risk assessment report to re\,iew tlie potential risks associated with the Newcastle West W W T P as they pertain to downstream water abstraction locations. the nearest being Askeaton which is 2aKm downstream ofthe primary discharge.

The RL requires the report to be reviewed annually and the ineilsures identilied in the reporl to be impleinented within I2 ~nontlis of grant of licence.

Condition 6.3 states that tlie licenscc shall immcdiatcly notily the \\ater services authority and/or other groups responsible for the downstream absWdctioI1 of drinking water, of any exceedcnce of an ELV associated with the discharge or any other relevant incident as defined b) the licence. There are 110 sensitive waters (waters designated under tlie Urban Waste Water Treatment Regulations) located in the vicinity ofthe dischargc.

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b'ater Franicwork Directive l2000!6~_!t_c_]

The RL. as drafted. transposes the reqiiireincilts of the Water l'rainc\+ork Directive. The inain physio-chemical parameters of concern are ortho-phosphate. total aiiiinoiiia and ROD. The river Dcel shows elevatcd conccntrations of tlie above parameters. Under thc water framework directive all water bodies must reach good status by 201 5 wit11 more stringcnt concentration limits. 'l'his RI- imposes strict t:,l.V limits. as there is no assimilative capacity in tlie Rivcr Deel. Those limits specified in Sched~dr A. / of the RL are determined with the aim of achieving good water quality status by 201 5.

Urban Waste Water Trcatnient Directive [91/27 IIEECI

The Newcastle West agglomeration was non compliant in 2007 with tlic requirements of the lirban Waste Water Treatment Regulations as amended (S.l No. 254 of 2001 and S.l No.440 of2004) on the basis of effluent qtiality' (BOD. COD. SS). The RL as draftcd has regard to tlie requirements of the Urban Waste Water Treatment Dircctivc. specifically with rcyard to ELV's and monitoring requircmcnts.

Bathinx Water Directive [2006/7/11C1

There are no dcsignated bathing \\atel's on the Rivcr Dee1

EC Freshwater Fish Directive 12006144iCC1

There are no designated Salmonid waters in the vicinity o f the discharge

Shcllfish Waters Directiy~c 1?.006/1 I3/EC1

lhere arc 110 designated shellfish waters

Dangerous Substances Directive [2006/1 I /Ea The applicant has providcd sampling results for the I9 dangerous substances in tlic primary dischargc for the purposes of thc liccncc application. The ineasurcd conccntrations are not considered significant. Due to the acceptance and treatment of landfill leachate there is an increased risk of dangerous substances within tlic W W T P discharge. The RL specifics in Condition 4.10 biannual inonitoring of relevant metals and organic compounds iii tlic primary discharge ( SW I ) .

As stated discharges from the Newcastle West agglomeration are made to tlie River Deel. which flows into the Shannon estuary 24Km do\\nstreatn of primary discharge (SW I ). The river Shannon at this point is a candidate Special Area ofConservation (cSAC). (Lower Rivcr Shannon, Site Code 002165). Most o f the estuarine part of tlic sitc (the Shannon and Fergus estuaries downstream of Limerick City) arc designated SPA (Site Code 004077) under the Birds Directivc, primarily to protect large nuinbcrs of migratory birds present in thc winter.

There is unlikely to be a significant impact of the dischargc (s) on thc cSAC or SPA so an appropriate assessnicnt \+as not required.

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Submissions

No subinissiotis received iii relation to this application,

Charges

The RL sets an annual cliarge for the agglomeration at F3.828 and is rcflective of the monitoring and enforcement regime being proposed for the aggloineration.

Kccommendation

I recoinrnend that a Final I,icence be issued subject to the conditions and for the rcasoiis as set out in the attached Kecominended 1,icencr.

Signed

[d- (.. ~

j r &la I larr ing~~ri

Oflicc of Climate. I...-..sing and Resource Use

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