24 1Ballinacarrick IR L NH350M 090151b2800443c7

User Manual: L-NH350M

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INSPECTORS REPORT
WASTE LICENCE REGISTER NUMBER

24-1

(1) Summary:
This application relates to an existing landfill (Ballinacarrick Landfill) for the disposal
of household, commercial, and industrial wastes.
Donegal County Council

Name of Applicant

Ballinacarrick Landfill
Ballintra,
Ballyshannon
Co Donegal.
24,000tpa
(Maximum to landfill from 1st Jan 2000 to closure is
100,000tonnes)

Facility Name (s)

Quantity of waste (tpa)

Environmental Impact Statement
Required

No

Number of Submissions Received

8 valid submissions

Inspector’s Recommendation

The proposed decision as submitted to the Board be
approved.

SITE VISITS:
DATE
15/5/98
27/10/98
30/8/99
17/5/00

PURPOSE
Check Site Notice
Site visit
Site visit
Site visit

PERSONNEL
P. Carey
P. Carey
P. Carey
P. Carey, M Henry, C Mac Gearailt

OBSERVATIONS
Site Notice complies with Art. 8
Site visit
Site visit
Site visit

An Article 16 (4) notice was issued to Donegal County Council on 1st June 2000
requiring significant quantities of outstanding information in relation to this site. This
information was received on 7th and 16th of June 2000.
(2) Activity Summary
This site has an area of approximately 7.5 ha and has been operational since 1980.
Waste input was initially approximately 4,000tpa rising to 23,000tpa in 1999. Only
household, commercial, construction & demolition and non-hazardous industrial solid
waste are to be accepted at this facility. The licensee has stated that waste currently
being accepted at this site from Sligo will no longer be accepted after September 2000.
This is currently approximately 11,000tpa.
This facility is currently unlined with no leachate control measures. Uncontrolled
releases of leachate into local small watercourses has occurred in the past.
However, compliance with the conditions of the proposed decision, particularly with
regard to capping, leachate management and surface water control measures will result
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in a significant reduction in uncontrolled leachate discharges from the site with a
corresponding ongoing and continual improvement in both surface and groundwater
quality.
The landscape is blanket bog in nature and the restoration plan aims to restore the site
to the original field patterns in place before the landfilling activity began. The
application was made on 27/2/98.
(3) Facility Location
Appendix 1 contains a site location map and a plan showing the layout of the
facility.
The facility is situated between Ballyshannon and Donegal town approximately 2.5km
off the N25. The vicinity of the site is bogland by nature with approximately 15 houses
(some unoccupied) within 500m of the site. The nearest dwelling is a mobile home
approximately 50m from the site entrance, while the nearest permanent dwelling is
approximately 350m to the north.
There are two proposed SAC’s (Ballintra Hill and Lough Golagh/Breezy Hill) and one
proposed NHA (Carricknahorna Lough/Lough Gorman) within 2.5km of the site.
(4) Waste Types and Quantities
Condition 5 of the proposed decision controls the quantities and types of waste to be
accepted at the facility.
YEAR
2000 to 2005

NON-HAZARDOUS
WASTE (tpa)
24,000

HAZARDOUS
WASTE (tpa)

TOTAL QUANTITY OF
WASTE (tpa)
st

Not Applicable

100,000 from 1 Jan 2000

The licensee will also be required to carry out an annual void space survey (Condition
9.11). The quantities of waste to be accepted for each waste type are specified in
Schedule H: Waste Quantities.
(5) Facility Design
Access to the site is via a third class road (2.5km) from the N25. Site security around
the boundary of the facility is currently in the form of a gate and limited palisade
fencing adjacent to the site entrance. The licensee will be required to upgrade this
fencing to encircle the perimeter of the site.
The proposed decision requires that the following infrastructure be put in place within
nine months of date of grant of licence (Condition 4)
• Weighbridge
• Wheelwash
• Improved internal access road
• Site office
• Waste Inspection/Quarantine area
Lining
There is currently no liner in place at this facility. The licensee is limited to waste
disposal either on existing waste (Condition 5.6) or in cells lined to landfill directive

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requirements. This PD specifies the lining system to be used in the event of any new
area of the facility being used for disposal purposes.
Leachate management
There are no leachate control measures currently in place at this site. The applicant will
be required to install a leachate management system (Condition 4.14) which will
include the following:
• Leachate abstraction points with high level alarms.
• Construction of a sub-surface leachate toe drain.
• Provision of adequate leachate storage and treatment facilities.
• Diversion of a stream which currently runs under the landfill, and extraction of
leachate from the culvert left behind.
The applicant proposes to treat leachate using a Puraflo system (peat based biofilm)
and discharge to a local stream. The stream 95-%ile flow and proposed leachate
emission flow are as follows;
• Max discharge of leachate
160m3/day (5m3/hr)
42m3/day (4.8 x 10-4 m3/sec)
• 95-%ile flow in stream
It is evident from this, that the stream in effect, would become a conduit for treated
leachate.
Therefore, due to the lack of assimilative capacity and dilution the licensee will be
required to tanker the leachate off-site and discharge to an agreed WWTP (Condition
4.14.4).
Landfill gas management
The licensee will be required to install at least 12 extraction wells on site to prevent
off-site migration of gas. The licensee will be required to install these wells on an
ongoing basis in parallel with the phased site infilling programme. The analysis
presented as part of the application indicated high proportions of H2S and other
odorous landfill gas (LFG) minor constituents. Therefore, due to potential odour
problems and greenhouse gas implications (and past complaints) the licensee will be
required to install active collection and flaring of LFG. The licensee will be required to
commence flaring of landfill gas within 18 months of date of grant of licence. This PD
specifies ELV’s for the LFG flaring system.
(6) Facility Operation/Management
Waste Acceptance/Handling Procedures
Conditions 5.1 and 5.2 and Schedule H of the proposed decision restrict the types of
waste to be disposed of at this site. Disposal of hazardous wastes, liquid wastes, septic
tank waste, silt and dredgings, oil/water mixtures, oils, animal excrement and blood are
prohibited. Condition 5.3 specifies waste acceptance procedures to be followed.
Nuisance Control
Potential nuisances are controlled by Condition 6 - Environmental Nuisances.
Hours of Operation
Condition 5.8 controls the hours of operation of the facility (8:30am – 5pm Monday to
Friday inclusive and 9am – 1pm on Saturdays with the exclusion of Bank Holidays), as
applied for by the licensee.
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Phasing
The site will be infilled on a six phase sequence. It is envisaged that each phase will last
approximately 8 months.
(7) Restoration and Aftercare
The applicant has proposed to return the site to grazing and restore the former
hedgerow/field boundaries as indicated on the 6” OS map of the area. The landscape
around is generally bogland with a patchwork of grazing areas. The final height of the
facility is limited to 104mOD, as proposed by the applicant (Condition 8.2) and is
designed to reflect the prevailing landscape character (Condition 8.1). Planting will
also reflect the local landscape. The licensee will be required to install 1m high earthen
berms around the site (to 2m in parts) for screening purposes. These will be seeded and
planted, and integrated into the restoration & aftercare plan. Capping of the site will be
as per Condition 4.16 of the proposed decision.
The licensee is required to have completed the restoration of the facility within 12
months of completion of landfilling activities on site.
(8) Emissions to Air
Emissions to air include landfill gas, odour and dust. Dust and landfill gas monitoring
requirements are set out under Condition 9.1 & 9.2 of the proposed decision. Dust
control requirements are established under Condition 6.6. Compliance with Condition
6.7 will ensure that nuisance will not arise from the licensed activity. Odour and other
nuisances will also be abated by the requirement for sufficient quantities of daily cover.
(9) Emissions to Groundwater
This landfill was established on an area of blanket bog. Strata underlying the site vary
but generally consist of the following:
• Peat layer
• Sandy silty CLAY (boulder clay)
• Schist (bedrock)
In areas which have been landfilled on, the peat will have compressed under the weight
of existing waste. However, it also appears that in some areas of the landfill waste has
been deposited directly onto rock outcrop.
The aquifer beneath this site would be considered to be of local importance, at most,
with poor production. However, the quality of groundwater in the aquifer is poor.
Analyses undertaken as part of the application indicated that levels of Calcium,
Magnesium, Manganese, Alkalinity and Nickel (List II) were in excess of drinking
water quality standards both upgradient and downgradient of the landfill.
However, there was some elevation of Ammonia (NH3), Potassium (K), Barium (Ba)
and Nitrite (NO2) in downgradient boreholes and this contamination is likely to be due
to the presence of the landfill. (see Table 1)
Parameter
Level observed (mg/l) Drinking water standard (mg/l)
NH3
0.5 - 0.78
0.3
NO2
<0.05 - 0.18
0.1
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Ba
K

0.07 - 1.05
6.5 - 28

0.5
12

Table 1 – Contaminants evident in monitoring boreholes

Groundwater sampling and analysis was also carried out for a range of List I
parameters and none were detected.
Compliance with the conditions of this proposed decision, particularly with regard to
capping, leachate management and surface water control measures will result in a
significant reduction in uncontrolled leachate discharge from the site with a resulting
significant ongoing improvement in both surface and groundwater quality.
The licensee will be required to monitor the six existing groundwater boreholes around
the site in accordance with Schedule E5 of this proposed decision. This includes a
requirement for the applicant to monitor the following;
•
•

one upstream & two downstream bedrock boreholes
one upstream & two downstream overburden boreholes (annually only).

(10) Noise Emissions
The noise sources identified on site were the vehicles delivering waste and the
bulldozer currently used on site. Noise monitoring was carried out in the centre of the
site and at the nearest adjacent noise sensitive location.
The noise monitoring results taken during the operation of the facility were primarily
affected by the local traffic. Results from the noise monitoring indicated that noise
levels within the site boundary, in terms of LAeq during routine activities, is in the order
of 47-49 dB(A).
Noise emission limits are specified by Schedule F1. Noise monitoring requirements are
set out in Conditions 9.1, and Schedule E4. The licensee will be required to specify
two additional noise monitoring locations at the site boundary, within three months of
date of grant of licence.
(11) Emissions to Sewer
There are no emissions to sewer from this site.
(12) Emissions to Surface Waters
The site is bounded by two surface water drains which run ultimately to the Ballintra
river (undesignated river i.e. not Salmonid) and from there into Durnesh lake. The
stream adjacent to the landfill shows evidence of contamination caused by the
infiltration of leachate from the landfill mass into the stream. Elevated Conductivity,
BOD, COD, coliforms and faecal coliforms are apparent in samples taken downstream
of the landfill. Again, this is due to the uncontrolled discharge of untreated leachate
from the site.
Leachate management works alluded to above (Condition 4.14), along with the surface
water management works required by Condition 4.17 (see below) will serve to
significantly reduce uncontrolled leachate discharge from the site. Consequently, this
will significantly improve both surface and groundwater quality on an ongoing basis.
Requirements of Condition 4.17 are as follows;
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•

Separation of contaminated surface water from clean surface water

•

Construction of a clean surface water toe drain.

•

Design of drains around site including possible use of open drainage ditches, french
drains or other methods for surface water control (as per draft Landfill Site Design
Manual)

•

Provision of holding lagoons or treatment systems (e.g. reed bed systems) for
collected surface water.
The licensee will be required to monitor surface water at four locations around the site.
Condition 9.1 and Schedule E5 specify the monitoring requirements. This includes a
requirement for the licensee to monitor at one upstream, two adjacent and one
downstream location.
(14) Waste Management, Air Quality and Water Quality Management Plans
Consideration was given to the Draft Waste Management Plan for Donegal County
Council May 2000. This plan has not yet been adopted. This plan indicates an intention
to operate this site for a further 4-5 years and dispose of approximately 100,000 tonnes
from January 2000.
(15) Other Impacts
Access to the site is via a third class road known locally as The Bog Road. This road is
described in the application as narrow in parts, not clearly defined, and showing
evidence of deterioration and rutting. In parts the road is only 3.0m-3.5m wide. The
site is near the village of Ballintra where traffic could potentially pass through,
particularly when coming to the site from a northerly direction. However, given that no
EIS was required for this activity (<25,000tpa) prohibiting access through Ballintra
village and requirements for upgrading of the access road falls outside the scope of this
proposed decision.
(16) Submissions/Complaints
Eight valid submissions were received in relation to this application, Appendix 2
contains copies of the submissions.
1, 2 & 3. Submissions from Mr Harry Lloyd, Northern Regional Fisheries Board.
[Dates Received 7/9/99, 15/1/99, and 23/3/98].
Three submissions were received from Mr Lloyd.
These submissions refers to uncontrolled escape of leachate from the site,
inadequate capping resulting in increased quantities of leachate, and the impact the
landfill is having on surface waters adjacent to the site and possibly downstream
also (Durnesh Lough)
RESPONSE
The proposed decision will ensure that the facility does not cause environmental
pollution when the activities licensed are carried out in accordance with the conditions
of the proposed decision. Extensive leachate, surface water and groundwater control
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measures are required as part of the proposed decision. Discharge of leachate to
surface waters from this facility is prohibited. Leachate treatment is required along
with subsequent discharge to an agreed waste water treatment plant. Capping
requirements are specified and consist of adequate daily and intermediate along with
final capping provisions.
4. Submission from Mr. Adrian Kennedy on behalf of Dúchas [Date Received
29/3/99].
The submission requests that achaeological monitoring be carried out prior to
further development of the site.
RESPONSE
Condition 4.22 requires that prior to commencement of any excavation works in
undeveloped land on-site, the licensee shall submit to the Agency for its agreement, a
pre-agreed proposal with Dúchas regarding archaeological supervision of said works.
5. Submission from Mr. Patrick White on behalf of Dúchas [Date Received
15/6/98].
The submission raises concerns regarding possible impact of leachate discharges
from the site, otherwise the submittee has no objection to the proposal.
RESPONSE
As above
6. & 7. Submissions from Mrs Regina Meehan – local resident [Dates Received
1/2/99 and 25/8/98].
The submission includes a number of general newspaper articles regarding landfills
and a list of ‘Tipping Conditions’ issued to contractors from Donegal Co. Co
regarding operation of the landfill. Mrs Meehan stated that these ‘Tipping
Conditions’ were issued by order of the courts following a case against Donegal Co.
Co. Mrs Meehan also encloses well water analysis regarding what she felt was
contamination of her well caused by the landfill.
Mrs Meehan raises a number of issues specific to the this facility as follows:
1.
Odour nuisance from the site
2.
Bird nuisance from the site
3.
Rats from the site
4.
Windblown litter from the site
5.
Is there landfill gas testing to be carried out on the site?
6.
Contamination of her well
RESPONSE
1.
Odour
Odour will be controlled by adequate provision of capping on site, and adequate
covering of the working face at the end of the working day (Condition 5.9 & 5.10).
The licensee will also be required to install a landfill gas collection and flaring system.
Waste being carried to the site shall be covered as per Condition 6.5. Condition 7.3

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requires that activities occurring on site shall not cause significant impairment of, or
significant interference with the environment beyond the facility boundary.
2. & 3.
Bird and rat nuisance
Bird and rat nuisance will be controlled by Condition 6.8 which requires a plan to be
put in place addressing the control and/or eradication of bird, vermin and fly
infestations at the facility. This programme shall include as a minimum;
• details on the control measures including rodenticides & insecticides to be used
• operator training
• mode and frequency of application
• inspection and maintenance records
• measures to contain sprays within the facility boundary.
Condition 6.3.1 will also require the use of netting around the working face. All areas
within the landfill apart from the working face shall be adequately capped.
Condition 5.12 requires that cover material be maintained across the entire landfill so
that no waste other than cover material or material suitable for specified engineering
works is exposed.
Condition 6.7 requires that vermin, birds, flies, mud, dust and odours do not give rise
to nuisance at the facility or the immediate area of the facility, and that any method
used by the licensee to control any such nuisance will not cause environmental
pollution. Groundwater monitoring requires monitoring of any rodenticides used on
site on an annual basis (Table E5)
4.
Windblown litter.
Condition 6.3.1 requires that prior to the disposal of waste in any cell, litter fencing
shall be installed and maintained around the perimeter of the active tipping area.
Condition 6.3.3 requires that all loose litter accumulated within the facility and its
environs, excluding that which is deposited on the working face, shall be removed on a
daily basis. Daily inspection of litter control infrastructure is required under Condition
6.3.2
5.
Landfill gas testing
Condition 4.15 deals with landfill gas management. This condition requires the
installation of 12 landfill gas (LFG) extraction wells to protect against lateral migration
of landfill gas. This condition also requires the licensee to install active collection and
flaring of LFG. Monitoring of FLG will be carried out at six locations.
6.
Well contamination
Mrs. Meehan encloses monitoring information, which indicates that her house well was
contaminated from the landfill. Reports are included from the public analyst laboratory,
from the ASEP laboratory (Queens University Belfast) and from the North Western
Health Board, between 1995-1996. These reports indicate that there was elevated
Ammonia in the water (2.13mg/l) on 3/4/97, however there was no evidence of any
other contamination (bacterial or chemical). Information submitted by the applicant
states that this house is now on the mains water supply. However, Condition 9.3
requires the licensee to survey the existence of any downgradient wells within 1km of
the facility and propose a monitoring programme for appropriate wells. It is not clear
whether Mrs Meehan’s well is still in use or even in existence. If it can be sampled then

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it will be included in the monitoring programme, whether it is in use or not (subject to
the agreement of the well owners).
8. Submission from Mrs Angela Meehan – local resident [Dates Received
5/1/99].
Mrs Angela Meehan is the daughter of Mrs Regina Meehan. This submission
requests that the Agency consider the submission of Mrs Mehan’s mother and reinforces the points raised by Mrs Regina Meehan.
RESPONSE
Dealt with in submissions 6 & 7 above.
Signed:
Name:

Dated: ______________
Cormac Mac Gearailt.

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APPENDIX 1
LOCATION & LAYOUT DRAWING

3026.21 A03 Site location
&
3026.23 A04 General site layout

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APPENDIX 2
SUBMISSIONS

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APPENDIX 3
SITE PHOTOGRAPHS

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