Scottish Water new outfall in Campeltown Loch
Posted: Tue Jul 21, 2009 10:21 pmAdvertised in the Courier on 26th June
"Scottish Water
WATER ENVIRONMENT AND WATER SERVICES (SCOTLAND) ACT 2003
WATER ENVIRONMENT (CONTROLLED ACTIVITIES) (SCOTLAND) REGULATIONS 2005 (“THE REGULATIONS”)
Notice is hereby given, in accordance with Regulation 13 of the Regulations that an application has been made to the Scottish Environmental Protection Agency (SEPA) by Scottish Water for authorisation to carry out a controlled activity, namely:
Discharge of screened storm sewage to Campbeltown Loch at NGR NR 7452 2052 from Kinloch Park Pumping Station, Campbeltown via a new combined sewer overflow at Slaty Farlan Waste Water Treatment Works, Campbeltown.
Any person affected or likely to be affected by, or having an interest in, the application may make representations about the application to SEPA in writing within 28 days beginning with the date of this advertisement at the following address, quoting reference number CAR/L/1047270;
The Registry, SEPA, Graesser House, Fodderty Way, Dingwall, IV15 9XB
A copy of the application may be inspected free of charge, at the above address, between 09.30 a.m. and 4.30 p/m. Monday to Friday (except for local or national holidays) or by prior arrangement at the SEPA Lochgilphead office, telephone 01546 602876.
Written representations received within 28 days of this advertisement will be taken into consideration in determining the application. Any such representations will be placed in a public register unless the person making them requests that they should not be. Where such a request is made there will be included in the register a statement indicating that representations have been made which have been subject of such a request."
A hard copy of the application has been placed in the library in Aqualibrium.
The Task Force has made a representation which is reproduced below
"OBJECTIONS TO SCOTTISH WATER APPLICATION CAR/L/1047270 – AN INTERMITTENT DISCHARGE OF SCREENED SEWAGE EFFLUENT FROM A NEW COMBINED SEWAGE OVERFLOW FROM KINLOCH PARK WASTE WATER PUMPING STATION, CAMPBELTOWN TO CAMPBELTOWN LOCH AT SLATY FARLAN - NGR NR 7452 2052.
Key Concerns Re Application.
These are all centred around the discharges into the Loch which we believe cannot comply with the water quality standards applicable to the receiving waters (the EC Bathing Waters Standards). The water quality modelling, provided by SW, is not credible and compounds the initial error of seriously underestimating the volume of storm water and infiltration.
1. Drainage Model.
The water quality modelling submitted by SW claims compliance with the EC Bathing Waters Standards; this modelling is based upon spill predictions given in the Halcrow Drainage Report. SW has included in the application an audit by HR Wallingford of the Drainage Model. This Wallingford report describes the Drainage Model as “acceptable with reservations”. A detailed reading of this audit report reveals the high degree of the reservations. For example no account has been taken of actual flows through Kinloch Park pumping station (page 39, points 12 and 21). We do not understand why SW failed to provide Wallingford with the monthly flow records for Kinloch Park which they have provided to SEPA since 2006. The Wallingford Report stresses that real data from Kinloch Park on Base Infiltration, Storm Infiltration, Rainfall and DWF should be obtained and verified. It further states that the 2005 new flow survey only covers 47% of the model (page 40, point 22.1). The report also makes it clear that the Drainage Model is based on historical, incomplete and much amended data and nowhere states that it should be relied upon for the degree of accuracy required to produce reliable water quality modelling; to the contrary it capitalises that the Drainage Model is only fit “FOR INITIAL INVESTIGATION OF OPTIONS” (page 38). It further specifies that the rainfall and flow survey data is inadequate and the model is not verified to an acceptable standard and level of detail (page 38).
2. Volume Of Discharge From the Proposed CSO At Slaty Farlan.
SW, in the Drainage Area Model Report, predicts an average 348,055 cubic metres discharge per annum. Using the monthly flow figures issued by SW for 2008 we have established that the annual discharge was approximately 1,366,585 cubic metres. Given that this volume would be reduced by the difference between the 2008 average flow to treatment during spills of 58.2 l/s and the planned increased treatment of 100 l/s the likely volume of discharge becomes 768,638 cubic metres as opposed to the 348,055, cubic metres used by SW in the latest water quality modelling; thus the real volume of discharge is likely to be some 120 % greater than the SW figure. In fact it will be even more than this since the available storage will be reduced from the current 4375 cubic metres to 1650 cubic metres by the proposed lowering of the foul well weir and the installation of pumps in the storm well. In fact the storage capacity which can be returned to treatment given the details of the pumping regime is 950 cubic metres (750 at Slaty Farlan + 200 cubic metres in the Kinloch Park storm well which could be returned to the foul well for treatment). At each spill event, with the reduction of “inline storage” from 4375 cubic metres to 900 cubic metres, 3475 cubic metres extra will be pumped from Kinloch Park only 750 cubic metres of which will be returned for treatment. The volume of discharge used in the water quality modelling for the withdrawn application was 559,933 cubic metres (for 2008); this showed intermittent discharges which did not reach the required water quality standards and which SEPA described in an internal memo as leading to non-compliance if the current recreational water area were to be extended to the wider Loch. Therefore the greater volume of at least 768,638 cubic metres will inevitably produce an equal and probably much greater degree of non-compliance with the EC Bathing Waters Standards.
3. Quality of Effluent Discharge.
SW’s application specifies new “supplementary treatment” works which would be capable of treating 80 l/s of the 100 l/s flow to full treatment. The nature of the technology to be used is not specified in the application although the SW Campbeltown project leader told us at the recent open day that a conventional treatment plant would be installed; later members of the Campbeltown Community Council were told that the technology had not yet been decided upon. Conventional technologies produce a final effluent discharge of lesser quality than the existing membrane plant. The discharge from the WWTW’s is continuous and will increase from the currently licenced DWF 2082 cubic metres/day (75 l/s FFT) to DWF 3169 cubic metres/day (100 l/s FFT) as specified in the new application for Kinloch Park, up to 80% of which could be more polluting than that produced by the current membrane plant This changed situation is not reflected in the water quality modelling. This again invalidates the water quality modelling.
It is our view that this significant increase and probable change of quality of the discharge from the Slaty Farlan Treatment Works should be the subject of a new application to SEPA which would include specific water quality modelling for the new discharge. This change to the discharge matches the definition given in SEPA document WAT-RM - 13 point 3.2 of a modified discharge made directly to identified waters (in this case Bathing Waters since SEPA has indicated that the SW application should be supported by water quality modelling to demonstrate compliance against EC Bathing Water Standards as a surrogate for the current Recreational Water status) i.e. “a change in discharge regime leading to an increased load or volume”. Thus the design criteria contained in section 4 and appendix A for Recreational and Shoreline Waters which state that the microbiological discharge for continuous discharges should be met at end of pipe must apply. This is of serious concern since SEPA document “Addendum to Report to Licensing Team” dated 28 January 2002 records that the discharge was only permitted into the “semi-enclosed water body which has restricted tidal movements”, since, “the cost of an outfall to meet SEPA’s 50 times dilution requirement was a significant factor in WOSW opting for a membrane bioreactor plant which produces a very high quality effluent”. The document goes on to state, “that the effluent receives only 6 times dilution”. Correspondence between SEPA and WOSWA relating to the original WWTW’s application makes it clear that it was only the high quality of the discharge produced by the membrane treatment that made it acceptable for this discharge to be in its current location rather than taken out of the Loch by means of a long sea outfall as was the original intention.
4. Conclusions.
• In conclusion, a detailed examination of the application reveals that SW has not provided credible evidence that the current proposal will achieve a compliant solution for Campbeltown since the discharges into the Loch will not comply with the water quality requirements. SW has continued to rely upon a discredited Drainage Model which bears little relation to recorded reality. We welcome their proposal to increase the flow to treatment which is now in line with our much disputed previously presented figures; however this increase must be balanced against the increase in spill volume brought about by the reduction in storage. SW’s inexplicable failure to acknowledge the truth is exemplified in the false claim made in the application that the Phase 1 works achieved compliance with the Kinloch Park licence; it did not do so as is recorded in writing by SEPA.
• Although we welcome the improvement to the works which should enable a higher treatment rate than previously we believe that the CSO should not discharge into the Loch. On this occasion, after some eight years of unsatisfactory performance, it should be expected, as indicated by the Waterwatch Scotland report, that the solution will be a final one which gives security to the people of Campbeltown. Improvement is not sufficient.
• SEPA has recognised that the new discharges should be modelled against the EC Bathing Water Standards. The water quality modelling provided by SW, given the large discrepancies between the spill data used in the modelling and the recorded reality of the Kinloch Park flow data over the last two years, is clearly flawed. The reduction in the storage volume is a further significant factor. The Wallingford Report on the Drainage Model expresses highly significant reservations. SW has failed to produce verifiable or even consistent data over many years; this current application continues this obfuscation.
• Further more the approximately 50% increased load on the Slaty Farlan WWTW’s discharge is of serious concern both in terms of the quality of discharge and the dilution capabilities of the receiving water; this concern was shared in 2002 by SEPA, when the volume of the discharge was much less. It would be iniquitous if, after some eight years SEPA was forced yet again to take enforcement action against SW if tests revealed that the quality of the discharge did not meet the current standard. Surety of compliance should be demonstrated prior to approval of this application.
• The proposal has the advantage of removing the frequent, lengthy and high volume discharges into the head of the Loch, but the volume of sewage spilled is unlikely to be significantly reduced and certainly vastly exceed that predicted by SW. This high volume discharge will, at a forecast expenditure of some £27 million merely be moved to another part of the Loch which has been described by SEPA as having limited tidal movement and dispersion capability.
• The “shifting sands” of SEPA’s policies, regulatory methods and statements has also been extremely unhelpful even though we accept that these changes may have been driven by others outside SEPA’s control. In 2007 we were assured that SEPA’s policy which specified candidate Shellfish Harvesting Waters would be treated as Shellfish Waters would apply; this has been withdrawn. Similarly SEPA documents referred to Recreational Water Standards; these also have been withdrawn. SEPA assured us that they would insist on water quality testing of the proposed receiving waters in order to ensure no deterioration; this assurance has also been withdrawn. These withdrawals come at a time when the rhetoric and EC directives emphasise an increase in water quality standards rather than a deterioration. It could be construed that the focus has been on the removal of our safeguards and enforceable standards rather than on providing a solution that does not pollute the Loch.
• For the people of Campbeltown the bottom line is that we have been badly served for many years and have a right to expect a solution which does not pollute the valuable resource of the Loch. Questionably better is not sufficient."
Whilst it might appear to those who have not been following progress so far, that this is a rather technical response, it should be remembered that £25m of public money is allegedly being spent on this proposal. It should be noted that whilst we do of course welcome the improvements, it appears that for the sake of saving a further £2m or thereabouts, we will have to put up with sewage sloshing about within the loch for ever more. We believe that it is worth fighting for a clean and unpolluted loch and would urge you to support our efforts in trying to get the sewerage overflow moved out of the loch - it is not too late to email SEPA - the deadline is this Friday and the email address is registry@sepa.org.uk Don't forget to give your full name and address and quote CAR/L/1047270
"Scottish Water
WATER ENVIRONMENT AND WATER SERVICES (SCOTLAND) ACT 2003
WATER ENVIRONMENT (CONTROLLED ACTIVITIES) (SCOTLAND) REGULATIONS 2005 (“THE REGULATIONS”)
Notice is hereby given, in accordance with Regulation 13 of the Regulations that an application has been made to the Scottish Environmental Protection Agency (SEPA) by Scottish Water for authorisation to carry out a controlled activity, namely:
Discharge of screened storm sewage to Campbeltown Loch at NGR NR 7452 2052 from Kinloch Park Pumping Station, Campbeltown via a new combined sewer overflow at Slaty Farlan Waste Water Treatment Works, Campbeltown.
Any person affected or likely to be affected by, or having an interest in, the application may make representations about the application to SEPA in writing within 28 days beginning with the date of this advertisement at the following address, quoting reference number CAR/L/1047270;
The Registry, SEPA, Graesser House, Fodderty Way, Dingwall, IV15 9XB
A copy of the application may be inspected free of charge, at the above address, between 09.30 a.m. and 4.30 p/m. Monday to Friday (except for local or national holidays) or by prior arrangement at the SEPA Lochgilphead office, telephone 01546 602876.
Written representations received within 28 days of this advertisement will be taken into consideration in determining the application. Any such representations will be placed in a public register unless the person making them requests that they should not be. Where such a request is made there will be included in the register a statement indicating that representations have been made which have been subject of such a request."
A hard copy of the application has been placed in the library in Aqualibrium.
The Task Force has made a representation which is reproduced below
"OBJECTIONS TO SCOTTISH WATER APPLICATION CAR/L/1047270 – AN INTERMITTENT DISCHARGE OF SCREENED SEWAGE EFFLUENT FROM A NEW COMBINED SEWAGE OVERFLOW FROM KINLOCH PARK WASTE WATER PUMPING STATION, CAMPBELTOWN TO CAMPBELTOWN LOCH AT SLATY FARLAN - NGR NR 7452 2052.
Key Concerns Re Application.
These are all centred around the discharges into the Loch which we believe cannot comply with the water quality standards applicable to the receiving waters (the EC Bathing Waters Standards). The water quality modelling, provided by SW, is not credible and compounds the initial error of seriously underestimating the volume of storm water and infiltration.
1. Drainage Model.
The water quality modelling submitted by SW claims compliance with the EC Bathing Waters Standards; this modelling is based upon spill predictions given in the Halcrow Drainage Report. SW has included in the application an audit by HR Wallingford of the Drainage Model. This Wallingford report describes the Drainage Model as “acceptable with reservations”. A detailed reading of this audit report reveals the high degree of the reservations. For example no account has been taken of actual flows through Kinloch Park pumping station (page 39, points 12 and 21). We do not understand why SW failed to provide Wallingford with the monthly flow records for Kinloch Park which they have provided to SEPA since 2006. The Wallingford Report stresses that real data from Kinloch Park on Base Infiltration, Storm Infiltration, Rainfall and DWF should be obtained and verified. It further states that the 2005 new flow survey only covers 47% of the model (page 40, point 22.1). The report also makes it clear that the Drainage Model is based on historical, incomplete and much amended data and nowhere states that it should be relied upon for the degree of accuracy required to produce reliable water quality modelling; to the contrary it capitalises that the Drainage Model is only fit “FOR INITIAL INVESTIGATION OF OPTIONS” (page 38). It further specifies that the rainfall and flow survey data is inadequate and the model is not verified to an acceptable standard and level of detail (page 38).
2. Volume Of Discharge From the Proposed CSO At Slaty Farlan.
SW, in the Drainage Area Model Report, predicts an average 348,055 cubic metres discharge per annum. Using the monthly flow figures issued by SW for 2008 we have established that the annual discharge was approximately 1,366,585 cubic metres. Given that this volume would be reduced by the difference between the 2008 average flow to treatment during spills of 58.2 l/s and the planned increased treatment of 100 l/s the likely volume of discharge becomes 768,638 cubic metres as opposed to the 348,055, cubic metres used by SW in the latest water quality modelling; thus the real volume of discharge is likely to be some 120 % greater than the SW figure. In fact it will be even more than this since the available storage will be reduced from the current 4375 cubic metres to 1650 cubic metres by the proposed lowering of the foul well weir and the installation of pumps in the storm well. In fact the storage capacity which can be returned to treatment given the details of the pumping regime is 950 cubic metres (750 at Slaty Farlan + 200 cubic metres in the Kinloch Park storm well which could be returned to the foul well for treatment). At each spill event, with the reduction of “inline storage” from 4375 cubic metres to 900 cubic metres, 3475 cubic metres extra will be pumped from Kinloch Park only 750 cubic metres of which will be returned for treatment. The volume of discharge used in the water quality modelling for the withdrawn application was 559,933 cubic metres (for 2008); this showed intermittent discharges which did not reach the required water quality standards and which SEPA described in an internal memo as leading to non-compliance if the current recreational water area were to be extended to the wider Loch. Therefore the greater volume of at least 768,638 cubic metres will inevitably produce an equal and probably much greater degree of non-compliance with the EC Bathing Waters Standards.
3. Quality of Effluent Discharge.
SW’s application specifies new “supplementary treatment” works which would be capable of treating 80 l/s of the 100 l/s flow to full treatment. The nature of the technology to be used is not specified in the application although the SW Campbeltown project leader told us at the recent open day that a conventional treatment plant would be installed; later members of the Campbeltown Community Council were told that the technology had not yet been decided upon. Conventional technologies produce a final effluent discharge of lesser quality than the existing membrane plant. The discharge from the WWTW’s is continuous and will increase from the currently licenced DWF 2082 cubic metres/day (75 l/s FFT) to DWF 3169 cubic metres/day (100 l/s FFT) as specified in the new application for Kinloch Park, up to 80% of which could be more polluting than that produced by the current membrane plant This changed situation is not reflected in the water quality modelling. This again invalidates the water quality modelling.
It is our view that this significant increase and probable change of quality of the discharge from the Slaty Farlan Treatment Works should be the subject of a new application to SEPA which would include specific water quality modelling for the new discharge. This change to the discharge matches the definition given in SEPA document WAT-RM - 13 point 3.2 of a modified discharge made directly to identified waters (in this case Bathing Waters since SEPA has indicated that the SW application should be supported by water quality modelling to demonstrate compliance against EC Bathing Water Standards as a surrogate for the current Recreational Water status) i.e. “a change in discharge regime leading to an increased load or volume”. Thus the design criteria contained in section 4 and appendix A for Recreational and Shoreline Waters which state that the microbiological discharge for continuous discharges should be met at end of pipe must apply. This is of serious concern since SEPA document “Addendum to Report to Licensing Team” dated 28 January 2002 records that the discharge was only permitted into the “semi-enclosed water body which has restricted tidal movements”, since, “the cost of an outfall to meet SEPA’s 50 times dilution requirement was a significant factor in WOSW opting for a membrane bioreactor plant which produces a very high quality effluent”. The document goes on to state, “that the effluent receives only 6 times dilution”. Correspondence between SEPA and WOSWA relating to the original WWTW’s application makes it clear that it was only the high quality of the discharge produced by the membrane treatment that made it acceptable for this discharge to be in its current location rather than taken out of the Loch by means of a long sea outfall as was the original intention.
4. Conclusions.
• In conclusion, a detailed examination of the application reveals that SW has not provided credible evidence that the current proposal will achieve a compliant solution for Campbeltown since the discharges into the Loch will not comply with the water quality requirements. SW has continued to rely upon a discredited Drainage Model which bears little relation to recorded reality. We welcome their proposal to increase the flow to treatment which is now in line with our much disputed previously presented figures; however this increase must be balanced against the increase in spill volume brought about by the reduction in storage. SW’s inexplicable failure to acknowledge the truth is exemplified in the false claim made in the application that the Phase 1 works achieved compliance with the Kinloch Park licence; it did not do so as is recorded in writing by SEPA.
• Although we welcome the improvement to the works which should enable a higher treatment rate than previously we believe that the CSO should not discharge into the Loch. On this occasion, after some eight years of unsatisfactory performance, it should be expected, as indicated by the Waterwatch Scotland report, that the solution will be a final one which gives security to the people of Campbeltown. Improvement is not sufficient.
• SEPA has recognised that the new discharges should be modelled against the EC Bathing Water Standards. The water quality modelling provided by SW, given the large discrepancies between the spill data used in the modelling and the recorded reality of the Kinloch Park flow data over the last two years, is clearly flawed. The reduction in the storage volume is a further significant factor. The Wallingford Report on the Drainage Model expresses highly significant reservations. SW has failed to produce verifiable or even consistent data over many years; this current application continues this obfuscation.
• Further more the approximately 50% increased load on the Slaty Farlan WWTW’s discharge is of serious concern both in terms of the quality of discharge and the dilution capabilities of the receiving water; this concern was shared in 2002 by SEPA, when the volume of the discharge was much less. It would be iniquitous if, after some eight years SEPA was forced yet again to take enforcement action against SW if tests revealed that the quality of the discharge did not meet the current standard. Surety of compliance should be demonstrated prior to approval of this application.
• The proposal has the advantage of removing the frequent, lengthy and high volume discharges into the head of the Loch, but the volume of sewage spilled is unlikely to be significantly reduced and certainly vastly exceed that predicted by SW. This high volume discharge will, at a forecast expenditure of some £27 million merely be moved to another part of the Loch which has been described by SEPA as having limited tidal movement and dispersion capability.
• The “shifting sands” of SEPA’s policies, regulatory methods and statements has also been extremely unhelpful even though we accept that these changes may have been driven by others outside SEPA’s control. In 2007 we were assured that SEPA’s policy which specified candidate Shellfish Harvesting Waters would be treated as Shellfish Waters would apply; this has been withdrawn. Similarly SEPA documents referred to Recreational Water Standards; these also have been withdrawn. SEPA assured us that they would insist on water quality testing of the proposed receiving waters in order to ensure no deterioration; this assurance has also been withdrawn. These withdrawals come at a time when the rhetoric and EC directives emphasise an increase in water quality standards rather than a deterioration. It could be construed that the focus has been on the removal of our safeguards and enforceable standards rather than on providing a solution that does not pollute the Loch.
• For the people of Campbeltown the bottom line is that we have been badly served for many years and have a right to expect a solution which does not pollute the valuable resource of the Loch. Questionably better is not sufficient."
Whilst it might appear to those who have not been following progress so far, that this is a rather technical response, it should be remembered that £25m of public money is allegedly being spent on this proposal. It should be noted that whilst we do of course welcome the improvements, it appears that for the sake of saving a further £2m or thereabouts, we will have to put up with sewage sloshing about within the loch for ever more. We believe that it is worth fighting for a clean and unpolluted loch and would urge you to support our efforts in trying to get the sewerage overflow moved out of the loch - it is not too late to email SEPA - the deadline is this Friday and the email address is registry@sepa.org.uk Don't forget to give your full name and address and quote CAR/L/1047270
