Community Development Association Ltd

Honeysuckle House Bishopsland Sallymore Eustace Co. 22.09.08 Environmental Protection Agency, WWALicencing Division Johnstown Castle, JOhasbwn, Co. Wexford.

Further to adv81i.isement in Wiskhow People of Wednesday Augw! 13* 2008 entitled “ County Council - Application to the Environmental Protection Agency for a Waste Water Discharge Licence”, the Bdynore bkseGomanunity Development Association would like to make the following objection.

The advertisement in the Wicklow Pmgle should be deemed to be invdid as there is no clmhg datefor receipt of submissions and/or objections by the Environmental Protection Agency.

Backaround For a background to the initial proposal by Wicklow County Council to discharge wastewater effluent film a new Blessingtk Wastewater Treatment Pl&t into Golden Falls please refer to For inspection purposes only. Chapter 11 of “BallymoreEustace Consent Trout of copyright and ownerSalmon required Anglers for any other ’Association use. - History 1974 - 2007”. This book gives a very detailed description of promises made by the Local Authorities of Wicklow and Kildare regarding the proposed discharge from the Blesshgton Wastewater Treatment Plant and the subsequent pollution of the Golden Fall Reservoir.

ReDorts and Ouotes (A) Water Treatment Plant - Phase 5 Expansion -Yield of the :-

“GoldenFalls lies a short distance dtnunstreamfiom the dzm at Poulaphouco, and it’s dam impounds approximately 800,000 CU.~.of water. meflow to the Lifley properfi.om Golden Falls is predominately through the turbines. Because of the characteristics of the turbines, which do not work well on part load, and which have a discharge of 30 cu.m/hr onjkll load, releasesfiom Golden Fah tend to be intermjttent. The turbines are operatedfor siihours on, followed by six hours ofso that the channel cupaciw of the L@ey is not exceeded ”.

Directors: F Erdn, P Donnelly, K .Noh, M McDonald, M Deegan, E: Firth, M Mason, R Edwards, F Smith A Comp-&y Cimittxl by Guarantef.IZegistered in No 250791. Registered Charity No. 12075

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The characterdics of the Golden Faills impoundment are

Maximum level: 140.55 m OR Normal High Level of Stored Water 139.0m OD Noma1 Low level of Stored Water 136.0 m OD Emergency Low level of Stored Water 135.5m OD

The report ''Lei- Water Treatme,ntPlant - Phase 5 Expansion - Yield-ofthe-RivwLiff'ey by Nicholas 0 Dwyer Ltd and Tobin Consulting Engineers - April 2005" also has some very interesting scenarios in relation b how much water abstraction is planned for the LSey. eg Scenario No 5: Leixlip Absirmtion 225 mld Ballymore Eustace Abstraction 318mld No reservation of storage preferentially Rationing reduction of 5% demand at 183.6mOD Compensation water: I. 5cumecs at (Golden Falls)/ 2. Ocumecs at Leixlip

This scenario dthately was endorse,d by County Council, Dublin Counly Council, and the ESB at a meeting on Thursday I ImMarch 2005 as being the one which was agreed between the Local Authorities as beinghydrologically smtainable and the flow regime needed to give effect to it was agreed as being workcrble by the ESB.

In the introduction to the same report the following is stated:- "The Liffey is a shared water resource between Dublin City Council, who currently abstract 275 h4LDfiom the headwork irnpomdhent at Poulaphoucafor lre-mentat Ballpore Eustace WTP, and Fingal County Council who abstract I65 MLD at presentfiom the Leixlip Impoundmentfor treatment at their nearby Treatment Work. neLlfiy ir fithermore a For inspection purposes only. hydroelectric power resource, underConsent oflegislative copyright owner and required operational for any other controluse. by ESB, who generate power at Poulaphouca again at GolibFalls a short distance dmns&eam dflnally at Leidip- Over the years, as demand on the L@y for water supply has grown, the priorities of water svpply have asswned greater imporhulce in tern offrow regdation, and the ESB now eflectively manage the resource in response to the requirements of water supply, generating power

opportunistically as they do so. 'I

(No mention of Kildare County Coiuncil OR Wicklow County Council activities)

In Chapter 3, the section on Effluent ]Returns the report states:- "The principal efluent on the L@ey is the treated efluent discharge fiom the Osberstown WWTP. have made available to w the daily discharge recordfrom the WWTP over the periodfiom it 's commissioning in November 1999 to November 2004 ''

DirFWrs: F Bredin, P DowUy, K Nolan. M M-GDoQM, M Deegan, E: Firth, M Mason, R Edwards, F Smith A Company Limited by GuaranteeXegisteredin Dublin No 250791. Registered Chm-ty No. 12075 '

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(B) Flood Risk Management through Reservoir Storage and Flow Control - J Fibpatrick and T Bree - ESB International - National Hydrology Seminar 2001

Golden Falls dam is situated about 2>Kmdownstream of Poulqhouca and acts-ar a regulating reservoir for dischargesfiom Poulaphouca. It allows the generating turbines at Poulaphouca to run forfour hows,Jilling Goldenfalls. Then the volume of water is released downstream at a lower discharge rate discharged over a 24 hour period. The dam is a mass concrete gravity type dam and has a total length of 1Oh and a maximum height of 15m.

Beinion of Ballvmore EUStace-COnlmNnitv-~~VeveLoDmentassociatiO~ The above extracts from available reports show that the Golden Falls and Poulaphouca Reserviors are integral parts of water abstraction infi-astructure for the Greater Dublin Region. In addition they are an integral part of the Flood Management System for the Liffey Catchment. They are also used in power production by the ESB. The Liffey itself is used for the discharge from the 80,000 pe WWTP at Osberstown. These are facts and they are known and reported in the reports listed above. What is not mentioned in these reponts, but what is every bit as important in the context of the upper Liffey, is 0 the amenity nature of the Poulaphouca and Golden Falls Reservoirs, for water sports and angling purposes Note:- it should be noted that the trout caughtfiom Golden Falls are generally eaten - conJrmation should be given to the local anglirg club that this is deemed by the EPA to be safee,especially in light of the unnaturalflow characteristic of the reservoir and the potential for concentrating 9f the discharge prior toflushing the reservoirfor dilution. 0 the 6,000 pe discharge from the WWTP (the subject of this submission) into the Golden Falls Reservoir, 0 the discharge from the Dublin City Council WTP just downstream of the Golden Falls For inspection purposes only. Dam, Consent of copyright owner required for any other use.

0 the 2000pe discharge proposcxl for the Ballymore Eustace WWTP again just downstream of the Golden Falls dam near the Ballymore Eustace Liffey Bridge. 0 THE pNHA STATUS OF GOLDEN FALLS In overall terms the EPA needs to consider the cumulative effects of the WWTP discharges it has to licence in the coming months under the Wastewater Discharge (Authorisation) Regulations 2007 and the impacts on the River Liffey as a whole. It is not enough to licence significant discharges into the Liffey without fmrt examining how the Liffey operates and it's Unnaturaj and controlled flow characteristics.

In terms of the specifics of this application to discharge wastewater fiom the Blessington WWTP into Golden Falls, the EPA must also consider the following:-

Reasons for the Environmental Protection Agency to refuse permission to Wicklow County Council to discharge wastewater to the Golden Falls Reservoir.

Directors: F Bredin, P Donnelly, K .Nolan, M McDoaald, M Deegan, EI Firth, M Mason, R Edwards, F Smith A Company Limited by Guarantee Registered in Dublin No 25079 I. Registered Charity No. 12075

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Golden Falls Characteristics. The mte of flow into Golden Falls differs from the rate of flow out of Golden Falls. When water is not flowing through the turbines in Golden Falls, only 1.5cu.mh compensation flow is leaving the Golden Falls Reservoir. During this time the Golden Falls reservoir can be holding steady / filling from / or possibly draining if less than 1.5cu.d~is entering Golden Falls through the Poulaphouca dam. During the times when Golden Falls is steady or draining(without activating the Golden Falls dam) the wastewater discharges are building up within the reservoir as a plume Prom the outfall point, which happens to be at the most upstream point in the reservoir. At this time the reservoir is in our opinion polluted, until the water is released at the Golden Falls dam and the reservoir is flushed (much like a toilet) downriver, before being filled from Poulaphouca again. (This all happens between certain maximum and minimum reservoir levels) The Ballymore Eustace Community Development Association would like a study to be carried out of the characteristics of Golden Falls Reservoir, examining e Input (from Poulaphouca) and Output (from Golden Falls) Frequencies / Quantities e Impact of Abstractions - both at Poulpahouca and Leixlip e Relationship between ESB power generation and water abstraction e Ability of ESB in future to provide emergency water in the Liffey in the event of a downstream pollution event or for amenity purposes eg Liffey Descent e Flow control when reserved water in Poulaphouca is released to cater for water abstraction in Leixlip e Existing Polluting Discharges into Golden Falls e Flow characteristics within the reservoir - direction of current, potential sludge deposit locations, pollution plumes klharacteristics during the various dam releases, impact of water ski club and power boat on reservoir, sedimentation quality in Golden Falls. e Impact ofpolluting discharge on ESB Dam works e Cumulative effect on Ballymore Eustace of 6000pe Blessington discharge and 2000pe Ballymore Eustace discharge Forand inspection Dublin purposes City only. Council WTP discharge and unregulated Consent of copyright owner required for any other use. discharges. e Characteristics ofthe Blessington WWTP Discharge e Security of Pipeline to Golden Falls from Blessington e Impact of discharge on Flora and Fauna Impact to date of discharge fiom Blessington WWTP at outfall location (evidence of significant contaminated mound of sludge / solids deposited at outfall) e Impacts of climate change e Impact on amenity activities ;It Golden Falls e Impact on Fish quality

Golden Falls is an impoundment reservoir. It is not safe to assume that if you discharge wastewater into the upper end of the impoundment that the reservoir throughput will achieve appropriate dilution and disperse the effluent downstream efficiently.

Directors: F Brerslin, P Donnelly, K J'hlan, M McDonald, M Deegan, E Firth, M Mason, R Edwards, F Smith A Company Limited by Guarantee Registered in Dublin No 250791. Registered Charity No. 12075

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Poilution The Minutes of the monthly meeting of the Kildare County Council, dated 31 March, 2003” show a motion raised by Councillor John Dadis “Concernedthat Golden Falls in Ballpore Etatace is highly polluted (Hypertrophic) - Conscious that the River Li$%y downstream of Golden Falls is a major national amenity and a source of drinking waterfor Kildare and Dublin; Determined to safeguard public health and the environment” The Council’s response was: Kildare County Council views with aiann the findings of the EPA report Water Quality in 1998 - 2000 and resolves to take urgent and egective action toprevent Wicklow County Council or any other Agency from discharghg pollutants into Golden Falls or the River Lifey.

The Water Quality Management Plan for the Liffey Catchment specifies that the mean annual concentration for total Phosphate is not to exceed 0.035mgA P. Figure for Golden Falls during 2007 reveal that total Phosphorous concentration is above the 0.035 mg/l P level, Faecal Coliforms counts of over 2400 were adso recorded during 2007.

With levels ofpollution as they are in the reservoir, the ESB has had to implement strict Health and Safety measures for it employees working on the reservoir, turbines, screens, filters etc.

When the EPA identified Golden Falls as Hypertrophic in 2000, Wicklow County Council appeared to blame others. “Salmara” a salmon fishery had at the time a Section 4 discharge licence from Kildare County Council and Wicklow County Council appeared to blame this operation for the pollution. It was during this disagreement that representatives from Salmam allegedly produced photos of what appeared to be a sludge mound underneath the outfall from the Blessington WWTP. The ESB drains this reservoir on occasion to facilitate overhaul work on the t Golden Falls dam and this allowed such a photo to be taken. It is very important that this alleged sludge mound is fully investigated by the EPA. For inspection purposes only. Consent of copyright owner required for any other use. There may be number of other unrcmlated trade / domestic discharges into the Reservoir and these should be fully investigated. i.e. ESB, Hotel and others

Amenities Golden Falls Reservoir is very important to the local economy in terms of the amenities it provides. The reservoir has in the past hosted international water skiing events. It has been used for triathlon events eg Focus Ireland Triathlon Challenge 2005. The Ballpore Eustace Trout and Salmon Anglers Association has liishing rights to the lake and attracts many anglers on seasonal / day permits. In addition, thr: use of the Village as a film location over recent years has involved use of the Liffey just downsfream ofGolden Falls. Braveheart, King Arthur and Lassie all involved scenes where hours at a time had to be spent in the water. The Ballpore Eustace Community Development Association is currently in discussion with Dublin City Council about providing River Liffey walks along Golden Falls and the Liffey immediately downstream of the Golden Falls dam. Most importantly however is the proposal to designate Golden Falls (as well as Poulaphouca as a pNHA.

Diredars: F BresJin, P DonneUy, K -Nolan, M McDonald. M Deegan, E Firth, M Mason, R Edwards, F Smith A Company Limited by Guarantee Registered in Dublin No 250791. Registered Charity No. 12075

EPA Export 26-07-2013:01:30:58 13allymore Eustace Community Development Association Ltd Livestock With elevated levels of Faecal Colifoirtns showing in 2007, and unhindered access to the reservoir on all sides to livestock, the question arises as to how safe it is for such livestock to be drinking from the reservoir with a treatment plant of 6,000 pe discharging into it. The question also arises as to the pollution being caused by allowing the same livestock to access the reservoir and the cumulative effect of this and the other discharges. \ Ownership The ESB own, control and manage Golden Falls Reservoir. Therefore they should be required to provide a letter of consent for the disc:harge into the reservoir and in doing so they must be able to describe the interaction between waster abstraction, flood management, power generation and pollution control. (The ESB appear 1.0 licence the current discharge into Golden Falls from Blessington -the CDA would like to question the legality of this licence as tbe EBS may not be a competent authority for the protection of waters). The ESB should also be in a position confirm that they are in a position to provide a safe place to work under, Health and Safety legislation, for it’s employees working on the Dam at Golden Falls.

County Development Plan Kildare County Devellopmeint Plan Chapter 16 -Evaluation of lilcely significant impacts on the environment of implementing the pian. Under the heading of “Environmental Factors in - 16.2.1.” the plan states that “adjacent to the earitem boundary, in ...... locally important sand and gravel aquifers occur. Any activity therefore on the eastern Kildare uplands has the potential to aiTect those aquifers as a result of the elevation gradient, high permeability and groundwater flow direction. Then under “Vulnerable Watersheds - 16-2.2.” the plans states that “The River Liffey water catchment area covers the north-eastem quarter of County Kildare including For inspection purposes only. 0 Golden Falls and Poulaphouca”Consent of copyright owner required for any other use.

Wicklow County Development Plan In Chapter 5 on infrastructure - the plan states under “Water Quality - 5.3” - It is the Councils overall aim to protect existing groundwater aquifers, surfacewaters and coastal waters from pollution. The Water Framework Directive 2000 aims to achieve a “good status” for all water by 2015. The Council will implement policies to deliver on this objective”. Then under “River Water Quality - 5.3.1” it goes onto say “Policy WS: The Council will implement the provisions of the River Basin Management Plans in order to protect the environment, pub1 ic health and the recreational potential of these water bodies” On Wastewater Treatment the plan states under 5.4.1. Policy WS 1: “The Council will provide satisfactory wastewater treatment and ancillary works to all towns and villages in the County to serve existing and future populations in accordance with the Wicklow Settlement Strategy and Hierarchy, in accordance with the Water Framework Directive 2000, the Water Services Investment Programme and those identified in schedule 9.3 (of which Blessington WWTP is identified as Blessington and the Villages of Lacken, and (This does not appear to be referred to in the application and requires clarification as this would nead to significant additional infrastructure attached to ttre Blessington WWTP)

Directors: F Breslin, P Donnelly, K Nolan, M McDonald, M Deegan, E Firth, M Mason, R Edwards, F Smith A Company Limited by Guarantee Registered in Dublin No 250791, Registered Chm-tyNo. 12075

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Blessington Expansion In accordance with the Wastewater Discharge (Authorisation) Regulations 2007, mer development within the town of Blessington should be prohibited until such time as an appropriate location for the discharge is identified. It is not acceptable that the EPA, put a decision on this licence on the long finger pending further reports by Wicklow County Council. A licence should be issued subject to eliminating the discharge within a certain timefiame and prohibiting hrther development in the meantime. From the various documentation available and on file it is unclear whether the Blessington wastewater treatment plant is operating at capacity or not. It has been designed to cater for a 6,000 pe. The population according tci the 2006 census is well over 4,500. Blessington also has a significant commercial / industrial loading which in the opinion of the CDA would put Blessington over the 6,000 pe equivalent already. This does not account for the significant planning permissions already Sancti01Led yet unbuilt in the town. Therefbre NO FURTHER DEVELOPMENT SHOULD BE PERMITTED IN BLESSINGTON

Stormwater / Emergency Overflows The Ballymore Eustace CDA would like to seek clarification regarding the management of overflows from the Blessington WWTP. In the event of an emergency breakdown at the Blessington WWTP, how is the flow inanaged and where does it go? How much attenuation is in place before raw sewage begins to enler Golden Falls?

Monitoring and Analysis - From Ajpplication Final effluent is discharged to Golden Falls via a 225mm diameter pressure pipe with an average volume of 1010.49m3/day. Who (What Agency) sets and enforces limits? Secondary Biological treatment for a lpe of 6,000 - Was 6,OOOge already been reached? March 2007 -March 2008 - Average BOD of 7.74mgA- What is maximum and how many times was 20mgA breached? For inspection purposes only. March 2007 - March 2008 - AverageConsent of SS copyright Of 1 1.76owner requiredmg/l -What for any other is use.maximum and how many time was 30mgh breached? Q 3-4 at Ballymore Bridge - April 2007 - Abundant growth of Caldophora spp and heavy siltation were noted. (Significant monies were spent in 2007 improving the river bed and reinstating salmon spawning grounds - Eastern Regional Fisheries Board / Ballymore Eustace Trout and Salmon Anglers / Dublin City Council involved) Phosphorous - Maximum Level 6.3 mg/l. Discharge actually takes place in the Kildare County Council hnctional area. (No Planning permission - permission was to lay ]pipe only) 1985 ESB license - what jurisdiction has ESB on water quality (no application to KCC) - Maximum discharge of 8 172m3 -What powers has ESB to take enforcement action for flow exceedances and pollution?

Section B.9 (i) Population Equivalent of Agglomeration - 1996 - 27 I 6pe 2000 - 4,500pe

Attachment B. 1 1 - Wicklow County Council confirms not having received any Section 63 requests from EPA regarding Golden Falls - Did Kildare County Council receive any Section 63 Notices under the EPA Acts 1992 and 2003 as amended by Section l3 of the P o E Act 2003 for Golden Falls.

Directors: F Breslin, P Donnelly, K .Nolan, M McDonald, M Deegan, E Firth, M Mason, R Edwards, F Smith A Company Limited by Guarantee Registered in Dublin No 250791. Registered Charity No. 12075

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Ballymore Eustace Community Development Association Ltd

The Coagulant being used in the Blessington WWTP is Aluminium Sulphate - consider that Alum is also used in the Dublin City iCouncil Water Treatment Plant - confirmation is required that the cumulative effect of the discharges are considered in terms of release of Aluminium into the Liffey.

Previous History Planning In November 1984 Kildare County Council gave planning permission (ref 295184) to Wicklow County Council to lay the discharge pipe hmBlessington Sewerage Treatment Plant through townslands in County Kildare in order to reach and discharge into Golden Falls. It is the contention of the Community Development Association that the conditions of that planning permission have not been met, EPA Reports The EPA Report “Water Quality in Ireland 1998 - 2000” pointed out that Golden falls Lake was in the Hypertropic Category i.e. Very Polluted. Yet no action was taken against Wicklow County Council who it appears chose to lay the blame on others. Section 63 PoE requests Could the Environmental Protection Agency confirm to the Ballymore Eustace Community Development Association whether they have had cause to issue Section 63 Notices under the Protection of the Environment Act 2003 on either Kildare Couniy Council and / or Wicklow Cctunty Council in relation to Golden Falls and if so what the outcomes of those investigations were?

Other Options Wicklow County Council has never fully considered other options with regard to the discharge of the wastewater from Blessington WWTP. The Ballymore Eustace Community Development For inspection purposes only. Association considers Golden FallsConsent to of be copyright an easy owner target. required for any other use. This discharge is inappropriate and consideration should be given to at least imposing strict tertiary limits, nutrient removal conditions and monitoring arrangements and preferably to consider possible alternatives such as discharging to Osberstown WWTP ,CO Kildare or to the Dublin Region at CityWest, Saggart for treatment at Ringsend. Further development in Blessington shduld now be prohibited

We trust that the EPA in assessment of Wicklow County Council’s application to discharge into Golden Falls will address all of the concerns ofthe Ballymore Eustace Community Development Association and refbse to allow this discharge to continue into this inappropriate location. Yours truly,

Fi aBreslin *Chairperson Ballymore Eustace Community Development Association

Tel: 045-864925 Mob: 087-9956085

Directors: F Braslin, P Domelly, K .Nolan, MMcDonald, M Deegan, E: Firth, M Mason, R Edwards, F Smith A Company Limited by Guarantee Registered in Dublin No 250791. Registered Charity No. 12075

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