COMHAIRLE CONTAE ÁTHA CLIATH THEAS
SOUTH DUBLIN COUNTY COUNCIL
MEETING OF ENVIRONMENT SPC
Wednesday, May 07, 2008
HEADED ITEM NO.
HEADED ITEM: E. Services
Illegal Dumps in the Dublin Mountains - Report
REPLY:
(1) An inventory of the location, capacity by material type and duration of current licensed dumps and landfill sites including authorised land reclamation.
There are no licensed landfills in South Dublin County. All refuse for the county is currently disposed of at Arthurstown Landfill, Kill, Co. Kildare which is licensed by the Environmental Protection Agency (EPA).
Friarstown tiphead.
Waste deposition on this site started in 1974, prior to current landfill licensing regulations. The landfill was closed and capped in 1997 and South Dublin County Council has responsibility for the aftercare of the landfill. The total area of the landfill was 60 hectares but only forty hectares of this were filled, with a total of 1.8 million cubic metres of waste placed over it’s life.
A landfill aftercare programme which involved environmental monitoring was developed and implemented in 1997 in line with the recommendations contained in the report of the consultants, K.T.Cullen and Co. Ltd at the time of closure. The report detailed a programme that addressed groundwater quality upgradient and down gradient of the facility, surface water draining the landfill catchment and gas emissions onto adjoining property. The Environmental Protection Agency approved this report. Gas and leachate monitoring is ongoing and surface and groundwater is tested once per year.
Authorised land reclamation sites
There are seven land reclamation sites located above the 110 meter contour in South Dublin County that are or were previously permitted under the Waste Management (Permit) Regulations 1998. Of these five sites are still active, two are no longer active (i.e. their permits expired and work on site has ceased). The material used in reclamation is inert and comprises of soil, stones and in some cases concrete. Permits are issued for three years, at a number of sites a second permit was applied for to complete works and these were granted. The details of the seven sites are as follows –
WPR036 Permit for land reclamation at Glenaraneen House, Glenaraneen, Brittas, Co. Dublin.
Permit dates: Initial permit granted Oct-03, current permit expires 14-Feb-09
Materials accepted: 17 01 01 Concrete; 17 01 02 bricks; 17 05 04 soil and stones; 17 01 07 Mixture of concrete, bricks, tiles and ceramics other than those mentioned in 17 01 06
WPR039 Permit for land reclamation at Deerpark, Mount Pelier, Old Court, Dublin 24.
Permit dates: Initial permit granted May 04, current permit expires 30 April 2010.
Materials accepted: Concrete 17 01 01; bricks 17 01 02; soil and stones 17 05 04
WPR040 Permit for land reclamation (specifically creation of access road through forestry lands) at Cruagh Road, Rockbrook, Rathfarnham, Dublin 16.
Permit dates: Permit granted Feb 04, and expired 31 Jan 2007.
Materials accepted: Concrete 17 01 01; bricks 17 01 02; soil and stones 17 05 04
WPR044/2 Permit for land reclamation at Kilakee Road, Rathfarnham, Dublin 24.
Permit dates: Permit due to expire 19 Febuary 2009, however work has ceased on the site. Site closure should occur in 2008.
Materials accepted: Concrete 17 01 01; bricks 17 01 02; soil and stones 17 05 04
WPR064 Permit for land reclamation at Lynch’s Park, Brittas, Co. Dublin.
Permit dates: expires 26th April 2009.
Materials accepted: soil and stones 17 05 04
WPR077 Permit for land reclamation at Steelstown, Rathcoole, Co Dublin.
Permit dates: expires 31 August 2010.
Materials accepted: soil and stones 17 05 04
WPR026 Permit for land reclamation at Glassamucky, Bohernabreena, Dublin 24.
Permit dates: granted December 04, expired November 06.
Materials accepted: Concrete 17 01 01; bricks 17 01 02; soil and stones 17 05 04
(2) A review of the number and nature of complaints and reports received by South Dublin County Council in the last 3 years.
It is difficult to accurately quantify the number of complaints received over the period mentioned that relate specifically to illegal dumping. All complaints are fully investigated by the enforcement section of South Dublin County Council and appropriate action is taken, where necessary. Often complaints relate to individuals importing small volumes of inert material such as soil and stones onto their sites, an activity which does not require a permit under the Waste Management (Permit) Regulations 1998. In many cases the placing of such imported fill has been the subject of a grant of planning permission. In other cases where such permission has not been granted the Planning Authority have taken enforcement action under Planning legislation.
There are a number of sites which are currently under investigation along with the EPA under Section 63(1) of the Environmental Protection Agency Acts 1992 and 2003. These sites are located at Kilakee; Ballycullen Equestrian Centre and Cruagh as outlined below.
Sites at Kilakee
Fill was imported onto land at Kilakee in 2002 to construct access roads/fire breaks without a waste management permit. It is estimated that approximately 82,900 tonnes of material was imported. A number of investigations have been carried out at the site since 2003, the latest of which was in April 2007 when SDCC contracted White Young Green Environmental (Ireland) to carry out a water and soil quality investigation, proceedings at the site were observed by the EPA. The results indicated that there was one localized area of soil contamination on land owned by Coillte which was excavated and disposed of appropriately in February 2008. The remainder of the imported material was deemed by WYG not to be a threat to human health and/or environmental receptors and therefore may remain in situ. The report was sent to the EPA. SDCC has contracted WYG to carry out additional soil sampling in the area where contaminated soil was removed in order to confirm remediation is complete and to carry out quarterly surface water and groundwater monitoring for a period of one year to confirm the assessment findings. SDCC is awaiting comments from the EPA prior to commencing with this monitoring plan.
Site at Ballycullen
The EPA wrote to South Dublin County Council on 7th September 2007 regarding a complaint of waste being imported to the site at Ballycullen. The enforcement section of SDCC carried out an investigation of the site and also looked at previous site investigations going back to March 2004.
It was found that 20 tonnes of contaminated material (containing elevated levels of hydrocarbon) was brought onto site, the Planning Authority issued a notice to carry out a site investigation. On foot of this, the contaminated material was removed. It was also found that there was no impact on the adjacent surface water stream.
The EPA carried out a joint inspection with SDCC environment section in early April 2008. They have recommended that SDCC carry out additional surface and groundwater (well) sampling and analysis.
Sites at Cruagh
In 2007 a number of complaints were received regarding two sites at Cruagh, the first site was where soil and stones had been imported under WPR040 (Section 55 issued) a waste management permit issued by SDCC; the second site was on adjacent lands.
SDCC had carried out a number of site investigations prior to these complaints and it was found that a number of conditions of WPR040 had been breached, specifically that imported fill had exceeded width and height guidelines and had possibly encroached onto others lands. The EPA wrote to SDCC in October 07 and instructed us to carry out a risk assessment at the site to determine if materials deposited posed a risk to the environment as there is an allegation that unsuitable material for land reclamation was deposited on these lands. The Planning Authority is pursuing an enforcement action against the landowner at the same site instructing him to remove all materials imported under WPR040 as he did not have planning permission for this activity. The landowner has subsequently applied for retention. Until the outcome of these proceedings has been decided we are unable to proceed with the risk assessment. SDCC are satisfied that there is no waste activity currently taking place at the site and are continuing to monitor the situation and the EPA have been informed of the status.
Regarding the second site, Environmental Efficiency Engineers were contracted by the landowner to carry out soil analysis in 2007 their report showed that the soil was not found to be contaminated The Waste Management Dept. are satisfied with this report have forwarded it to the E.P.A. for comment and are awaiting a reply . The Planning Department is also pursuing an action against the landowner regarding this site.
Other sites at Cruagh
There were a number of complaints made to SDCC and the EPA regarding a number of further sites at Cruagh around the same time as the complaints already mentioned. SDCC carried out a site investigation at the invite of the EPA in August 2007. In all cases there was a history with the Planning Authority where inert fill had been imported without planning permission and was subsequently removed, in one case there was no action taken because the amount of fill was very small and of an inert nature.
(3) The number, duration and nature of outstanding enforcement and compliance orders relating to dumping and suspected illegal landfills.
Currently there are three outstanding enforcement / compliance orders relating to illegal dumping. One is a Section 55 notice (Cruagh above) under the Waste Management Act 1996 as amended, which is an instruction to a landowner recipient to clean up a site. This notice cannot currently be enforced due to a planning enforcement action on the same land. The other two outstanding notices are Section 18’s (for sites other than above) under the Waste Management Act 1996 as amended i.e. a notice requiring the recipient to provide information regarding suspected waste activities.
(4) Impact of dumping on rivers, streams and roads
Rivers, Streams
With regard to authorized / permitted sites, each application for land reclamation is assessed for site suitability. If a site is in proximity to a feeder stream to a reservoir, for example, the application will be turned down. Depending on the site, conditions are attached with the permit to sample any neighboring watercourses before, during and after reclamation activity. Furthermore sampling at selected locations (rivers & streams) is undertaken on a regular basis by the Water Pollution Control Section for Dangerous Substances, Phosphorous and under the Water Framework Directive results to date have been satisfactory
Roads.
The impact of transporting large quantities of material can have a negative effect on roads in particular minor roads. However all activities are now governed by Planning and/or Permitting, a report is sought from the Roads Department stipulating their requirements which are included as a condition(s) in the issue of a Permit or the grant of Planning Permission
(5) Other relevant information
Section 22 sites (historical unregulated waste disposal sites).
Background.
Ministerial Direction (WIR 04/05) under Section 60 of the Waste Management Acts 1996 to 2005 it reminds Local Authorities of its responsibilities under Section 22 of the above act it refers to an inventory and risk assessment of all non licensed closed landfills (i.e. historic unregulated waste disposal sites).
C.O.P. intro 04/07
Site Categorisation
Category 1: Historic Local Authority Landfills that existed from 15/07/1977 to 1997.
Category 2: Private Waste Disposal Facilities (Landfills) that operated from 15/07/1977 to 31/03/1980.
Category 3: Illegal Landfills (Public & Private) operating since the introduction of the Waste Managing Licensing Regulations 1997.
Code of Practice:
To assist local Authorities the E.P.A. developed a code of practice in April 2007. This code was developed to ensure a consistent approach to environmental risk assessment by all L.A.’s in former waste disposal sites and in particular to the assessment of the environmental impact and remediation options for historic unregulated waste disposal sites. These sites ceased operations before entry into force of a waste-licensing regime and therefore were not subject to a specific waste authorisation requirement and were not in breach of national legislation.
Application of Code of Practice (Summary)
- Identify Sites (commencing with 1998 report, Survey of Waste Contaminated Lands in County Dublin) Categories 1 & 2 above.
- Conceptual Model to be developed by L.A. (This has been done in S.D.C.C. with assistance of the I.T. & Planning Depts, the E.P.A. and the G.S.I.)
- Use conceptual model to assess site.
- Carry out walkover survey of site.
- Using information gathered from steps 3 and 4 rate sites as Low, Moderate or High Risk
- Site Registration: Sites are to be entered on the National E.P.A. Section 22 Register by each L.A.
- Examine suspected old illegal dumps, additional to the identified at 1 above. These are to be examined using the Code of Practice method which is outlined above (Category 3).
Status report
Each one of these sites will be examined and rated using the Code of Practice methodology. This work is well underway and discussions with the EPA are ongoing. No sites in South Dublin have as yet been entered on the EPA register.