COMHAlRLE CONTAE MHAIGH EO =,atit Aras an Chontae, Caislean a 'Bharraigh, Contae Mhaigh Eo. Teileaf6in (094) 9024444 Fax (094) 9023937 Website: www.mayococo.ie

Your Ref. Our Ref.

grn July 2009.

Administration Environmental Licensing Programme Office of Climate, Licensing & Resource Use Environmental Protection Agency Headquarters P.O. Box 3000 Johnstown Castle Estate County Wexford

RE: Notice in accordance with Reaulation 18(ub) of the Waste Water Discharge fAuthorisation) Regulations 2007

APPLICATION: D0072-01- CENTRAL

Dear Mr McLoughlin

For inspection purposes only. Consent of copyright owner required for any other use. Further to your letter of 2gm May 2009, Ienclose the required responses to the queries raised in the correspondence.

For clarity, the responses have been made point .by point with the original queries indicated in italics.

Thank you,

Yours sincerely

Paddy Mahon Director of Services

MAYO COUNTY COUNQ, Aras an Chontae, , Co. Mayo. Tel: (094) 9024444

PRINTED ON RECYCLED PAPER EPA Export 26-07-2013:14:27:58 I Y.2 >: 7 "L*-, .-_ Achill Island Central Waste Water Discharge Licence Application Reguilation 18 Request

REGULATION 16 COMPLIANCE REQUIREMENTS

No. 1

Provide the name of the agglomeration to which the application relates.

Answer 1

The name of the agglomeration is Achill Island Central

No. 2

In Section B.9 (i) of the application form, the p.e. of the agglomeration is stated as being 4000. Please confirm that this figure includes the maximum average weekly loading for the agglomeration, to take account of the peak summer holiday season in Achill.

Answer 2

The Treatment Plant was designed to cater for a 4,000 PE. The estimated present figure of 2500 PE takes into account Resident visitors, Day visitors as well as domestic residents. i.e. it takes account of the peak summer holiday season.

No. 3

Where planning permission has been granted for development(s), but said development has not been commenced or completed to date, within the boundary of the agglomeration For and inspection this purposes development only. is being, or is to be, Consent of copyright owner required for any other use. served by the waste water works, provide the following information:

i. Information on the calculated population equivalent (p.e.) to be contributed to the waste water works as a result of those planning permissions granted; ii. The percentage of the projected p.e. to be contributed by the non- domestic activities; and, iii. The ability of the waste water works to accommodate this extra hydraulic and organic loading without posing an environmental risk to the receiving water habitat.

Answer 3

1. The PE for planning permissions granted but not yet constructed is 140 PE. 2. Approximately 35% of this is non domestic 3. There is sufficient capacity in the water treatment works to accommodate the extra Hydraulic and organic loading.

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EPA Export 26-07-2013:14:27:58 Achill Island Central Waste Water Discharge Licence Application Reguilation 18 Request

No. 5

The 3 secondary discharge points labelled SW2, SW3 and SW4 are described as secondary overflows in the Non-technical Summary and are annotated as secondary discharge points in Map B.2. Please clarify? If applicable, update Map B.2 and the relevant parts of the application accordingly. Please note that a Secondary discharge is defined as: “A potential, occasional or continuous discharge from the waste water works other than a primary discharge or a storm water overflow”.

Answer 5

Non-Technical Summary has been changed accordingly and attached.

No.6

Section F: Existing Environment and Impact of the Discharges: Assess the likelihood of significant effects of the waste water discharges from the Achill Island agglomeration at Purteen on the relevant European site(s) by referring to Circular L8/08 “Water services Investment and Rural Water Programmes – Protection of Natural Heritage and National Monuments” issued by the Department of Environment, Heritage and Local Government. In particular, the flow diagram in Appendix 1 should be completed and the results of each section recorded. Provide details of the results of this assessment within one month of the date of this notice. If significant effects are likely then an appropriate assessment must be carried out and a report of this assessment forwarded to the Agency within one month of the date of this notice.

You are advised to provide the Forrequested inspection purposes information only. in accordance with the Consent of copyright owner required for any other use. “Note on Appropriate Assessments for the purposes of the Waste Water Discharge (Authorisation) Regulations, 2007 (S.I. 684 of 2007)” which is available at www.epa.ie

Answer 6

Find enclosed a Copy of the ‘Appropriate Assessment of Achill Island Waste Water Discharge Licence Application 2009’

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No. 7

Section G.1- Provide evidence that emissions from the agglomeration are in compliance with the Council Directives listed in section G of the application form including Bathing Water Legislation, S.I. No. 155 of 1992 (Quality of Bathing Waters Regulations).

Answer 7

a) Bathing Water Regulations

Mayo County Council sample results indicate compliant with the Regulations. The results from 2008 are attached providing evidence of compliance.

b) Urban Waste Water Regulations

Mayo County Council sample results taken from monthly samples from 2008 to date indicate compliance with the Regulations. Results are attached. Achill Island WWTP discharges to sea.

c) Water Framework Regulations

A draft Plan for the Western River Basin District has yet to be adopted by Mayo County Council. If adopted, Mayo County Council will pay regard to this Plan in its management of Achill Island WWTP.

For inspection purposes only. Consent of copyright owner required for any other use.

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EPA Export 26-07-2013:14:27:58 Achill Island Central Waste Water Discharge Licence Application Reguilation 18 Request

d) Dangerous Substances Regulations

Pesticides and Solvents Substances standards and Metal and other Substances standards, listed in the Standards Schedule of the Regulations apply to substances in a water body. The discharge from Achill Island WWTP was monitored for all these substances as part of the wastewater discharge licence application and results indicate that levels are below those acceptable in a water body.

Substance Unit Standard Result Atrazine ug/l 1 0.003 Dichloromethane ug/l 10 <1 Simazine ug/l 1 0.013 Toluene ug/l 10 <1 Tributylin ug/l 0.001 0.02 Xylenes ug/l 10 <1

Arsenic* ug/l 20 <0.5 Chromium* ug/l 15 <0.5 Copper* ug/l 5 1 Cyanide* ug/l 10 2.3 Fluoride* ug/l 1500 0.0045 Lead* ug/l 5 <0.5 Nickel* ug/l 25 2 Zinc* ug/l 40 5 *Standards for metals and other substances in tidal waters are used.

It must be noted that these substances will be further diluted in the receiving water.

For inspection purposes only. Consent of copyright owner required for any other use.

e) Groundwater Directive

Achill Island WWTP discharges to sea. Secondary discharges in the agglomeration are to surface water.

f) Shellfish Directive

There are no designated shellfish waters in proximity to the Achill Island WWTP outfall

g) Drinking Water Directive

There is no surface water for abstraction point in proximity to the Achill Island WWTP outfall

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h) Birds Directive

There are no SPA’s in proximity to the Achill Island WWTP outfall

i) Habitat’s Directive

Please refer to the appropriate assessment attached.

For inspection purposes only. Consent of copyright owner required for any other use.

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EPA Export 26-07-2013:14:27:58 Achill Island Central Waste Water Discharge Licence Application Attachment A.1

A.1 Non-Technical Summary

1. Waste Water Discharge Licence Background

Mayo County Council, Aras an Chontae, Castlebar, Co. Mayo is making an application to the Environmental Protection Agency (E.P.A.) for a waste water discharge license for the Achill Waste Water Treatment Plant (WWTP) at Purteen and the associated agglomeration known as Achill Island Central, in compliance with the Waste Water Discharge (Authorisation) Regulations 2007 (S.I. No. 684 of 2007).

Under Schedule 2 of the above regulations, the prescribed date for submissions of Waste Water Discharge License Applications for agglomerations (with discharges with a population equivalent of 2,001 PE to 10,000 PE) is 22nd September, 2008. The waste water works at Purteen, Achill Island falls under this category, presently having an agglomeration with an agglomeration population equivalent (PE) of approximately 2,500 PE.

The original scheme was built in 1991.

2. Description of Purteen, Achill Island Waste Water Works.

The Purteen Waste Water Treatment Plant with a design capacity of 4,000 PE is currently being operated by Mayo County Council. Treated effluent from the Plant is discharged to the Atlantic Ocean (Primary Discharge Point.)

The waste water works in Purteen, Achill Island consists of a Wastewater Treatment Plant with a collection network of Foul Sewers and 4 No. pumping stations. For inspection purposes only. Consent of copyright owner required for any other use.

The municipal treatment works is based on the extended aeration process and is designed to treat sewage from a population equivalent of 4000 PE.

The Municipal Treatment Process consists of the following:

ƒ Inlet works with 12mm automatic screen, standby manual screen, screenings flushed to macerator, compaction and grit removal ƒ 2 No. Aeration Tanks ƒ 2 No. Secondary Settling Tanks ƒ Final Effluent Sampling Point ƒ Sludge Pumping ƒ Sludge Thickening ƒ Sludge Dewatering ƒ Supernatant return to inlet works

D0072-01 A.1 Page 1 of 2

EPA Export 26-07-2013:14:27:58 Achill Island Central Waste Water Discharge Licence Application Attachment A.1

Of the 4 No. pumping stations, 2 of these pump directly to the WWTP, with the remaining 2 located as topography dictates around the catchments. 3. Sources of Emissions:

Emissions from the Treatment works are discharged to the Atlantic Ocean (through an outfall labelled SW1). This is the primary discharge point.

There are 3 No. secondary discharge points (labelled SW2, SW3 and SW4). These are secondary overflows at the Pump Houses located at PS4, PS2 and PS3 respectively.

These secondary overflows are provided in case of difficulties, such as power cuts at the pumping plant and excessive rainfall.

To protect Keel Strand there is no secondary overflow at the Keel Pumping Station. There is, however, a Balancing Tank and a standby Generator.

To protect Strand the total pumping capacity at the main Dooagh Pumping Station is 12 times D.W.F.

4. Nature and Quantity of Foreseeable Emissions:

The wastewater treatment works is designed to treat the wastewater treatment to the standards required by the Urban Wastewater Treatment Regulations. i.e. BOD 25 mg/L, COD 125mg/L and SS 35 mg/L

The average volume currently discharged from the municipal effluent stream of the Treatment Plant is 562.5m³/day (2,500 PE @ 225l/per PE day). This is equivalent to an average daily discharge For inspection purposes of 162 only. kg Bod. It is not anticipated that Consent of copyright owner required for any other use. the municipal effluent will increase appreciably in the meantime.

5. Technology for Prevention or Reduction of Emissions:

Emissions from the Wastewater Treatment Plant are monitored and the treatment process is constantly adjusted to maximise the efficiency of the plant in removing pollutants.

6. Supervision of Works:

The wastewater treatment works is staff by a plant manager and an assistant. The Plant Manager’s hours are 39 hours for a 7 day week plus any necessary overtime and call outs. Cover for the Plant Manager is provided every 4th weekend and holidays.

D0072-01 A.1 Page 2 of 2

EPA Export 26-07-2013:14:27:58

APPROPRIATE ASSESSMENT Of ACHILL ISLAND CENTRAL WASTEWATER DISCHARGE LICENCE APPLICATION 2009

In accordance with the Waste Water Discharge For inspection purposes only. Consent of copyright owner required for any other use. (Authorisation) Regulations, 2007 (S.I. No. 684 of 2007) And Article 6(3) and 6 (4) of the Habitats Directive 92/43/EEC

EPA Export 26-07-2013:14:27:58 Achill Island Central Wastewater Discharge Licence Application – Appropriate Assessment

1. INTRODUCTION Mayo County Council, Aras an Chontae, Castlebar, made an application to the Environmental Protection Agency (EPA) for a Waste Water Discharge Licence, for the Achill Island Central Wastewater Treatment Plant & Agglomeration (i.e. ‘Achill Agglomeration’), in compliance with the Waste Water Discharge (Authorisation) Regulations 2007 (S.I. No. 684 of 2007), in early September 2008. Under Part II Schedule 5 (5) of the Wastewater Discharge (Authorisation) Regulations 2007, In considering an application, where it appears to the Agency (i.e. Environmental Protection Agency) that the discharge concerned, or the proposed discharge, as the case may be, is likely to have a significant effect on a European site, either alone or in combination with other operations or activities, the Agency shall cause an assessment to be made of the implications for the site in view of that site’s conservation objectives, and the Agency in deciding on the application shall have regard to the conclusions of the assessment. The Island Achill Central Wastewater Treatment Plant at Purteen discharges into the Achill Head Special Area of Conservation (Site Code 002268) via a primary and secondary discharge point. Another secondary discharge point is located within the Keel Machair/Menaun Cliffs Special Area of Conservation (SAC) and proposed Natural Heritage Area (pNHA) (Site Code 001513). In addition, the Croaghaun/ SAC and pNHA (Site Code 001955) is located within 3km of these discharge points. This report includes: 1. Screening of the proposed plan in order to determine whether an Appropriate Assessment is required. 2. The Appropriate Assessment which evaluates the potential impacts of the Wastewater Treatment Plant discharges on the Natura 2000 site and identifies proposals so that adverse effects are avoided.

Purpose of Appropriate Assessment For inspection purposes only. Consent of copyright owner required for any other use. Articles 6(3) and 6(4) of the Habitat Directive 92/43/EEC require an Appropriate Assessment of plans to prevent significant adverse effects on Natura 2000 sites. Article 6(3) Any plan or project not directly connected with or necessary to the management of the site but likely to have a significant effect there on either individually or in combination with other plans or projects, shall be subject to appropriate assessment of its implications for the site in view of the site’s conservation objectives. In the light of the conclusions of the assessment of the implications for the site and subject to the provisions of paragraph 4, the competent national authorities shall agree to the plan or project only after having ascertained that it will not adversely affect the integrity of the site concerned and if appropriate, after having obtained the opinion of the general public. Article 6(4) If, in spite of a negative assessment of the implications for the site and in the absence of alternative solutions, a plan or project must nevertheless be carried out for imperative reasons of overriding public interest, including those of social or economic nature, the Member State shall take all compensatory measures necessary to ensure that the overall coherence of the Nature 2000 site is protected. It shall inform the Commission of the compensatory measures adopted.

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EPA Export 26-07-2013:14:27:58 Achill Island Central Wastewater Discharge Licence Application – Appropriate Assessment

The purpose of this Appropriate Assessment (AA) is to address the potential impacts of discharges from the Achill Wastewater Treatment Plant on the conservation objectives of three Natura 2000 Sites: Achill Head SAC (Site Code 002268); Keel Machair/Menaun Cliffs SAC / pNHA (Site Code 001513); and Croaghaun/Slievemore SAC / pNHA (Site Code 001955). There are no Special Protection Areas within 3km of the study area. The AA must determine whether the project is likely to have significant adverse effects on these sites either along or in conjunction with other plans and projects in the area and whether these effects will adversely affect the integrity of the SACs in terms of their nature conservation objectives. Figure 1.1 - Location Map – Achill Central WWTP and associated discharges and adjacent Natura 2000 sites.

For inspection purposes only. Consent of copyright owner required for any other use.

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EPA Export 26-07-2013:14:27:58 Achill Island Central Wastewater Discharge Licence Application – Appropriate Assessment

2. APPROPRIATE ASSESSMENT - THE PROCESS According to European Commission Methodological guidance on the provisions of Article 6(3) and (4) of the Habitats Directive 92/43/EC (2001) and MN2000, the assessment requirements of Article 6 establish a stage-by-stage approach as follows: Stage 1 - Screening for a likely significant effect: An initial assessment of the project or plans effect on a European site(s). If it cannot be concluded that there will be no significant effect upon a European site, an AA is required; Stage 2 - Appropriate Assessment: The consideration of the impact on the integrity of the Natura 2000 site of the project or plan, either alone or in combination with other projects of plans, with respect to the site’s structure and function and its conservation objectives. Additionally, where there are adverse impacts, an assessment of the potential mitigation of those impacts. Stage 3 – Assessment of alternative solutions: The process which examines alternative ways of achieving the objectives of the project or plan that avoid adverse impacts on the integrity of the Natura 2000 site: Stage 4 – Assessment where no alternative solutions exist and where adverse impacts remain: An assessment of compensatory measures where, in the light of an assessment of imperative reasons of overriding public interest (IROPI), it is deemed that the project or plan should proceed. Each stage determines whether a further stage in the process is required. If, for example, the conclusions at the end of Stage One are that there will be no significant impacts on the Natura 2000 site, there is no requirement to proceed further. The following Assessment has been prepared in consultation with the following documents: Department of Environment, Heritage and Local Government (2008) Circular L8/08. Water Services Investment and Rural Water Programmes – Protection of Natural Heritage and National Monuments. For inspection purposes only. Consent of copyright owner required for any other use. EPA (2008) Wastewater Discharge Licensing Appropriate Assessment: Note on Appropriate Assessments for the purposes of the Waste Water Discharge (Authorisation) Regulations, 2007 (S.I. No. 684 of 2007). EC (2000) Managing Natura 2000 Sites: The provisions of Article 6 of the ‘Habitats’ Directive 92/43/EEC. EC (2001) Assessment of plans and projects significantly affecting Natura 2000 sites: Methodological guidance on the provisions of Article 6(3) and (4) of the Habitats Directive 92/43/EEC. Guidance document on Article 6(4) of the ‘Habitats Directive’ 92/43/EEC.

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3. STAGE 1 - SCREENING Screening is the process of deciding whether or not an AA is required for the project or plan. Screening only requires sufficient information to determine if there is a likely significant effect on a Natura 2000 site and does not require the detailed information needed for the AA. The following Stage 1 Screening was undertaken according to the Department of Environment, Heritage and Local Government Circular L8/08 and EC Methodological guidance on the provision of Article 6 (3) and (4) of the Habitats Directive 92/443/EEC. This Screening is used below to ascertain if an AA is required.

3.1 – Description of the Project

The Wastewater discharge application is for the licencing of 5 No. discharges from the existing Sewerage Scheme that serves Achill agglomeration. Achill Island Central Wastewater Treatment Plant (WWTP) was built in 1991 and consists of inlet works with screening, disintegration and grit removal. The treatment process consists of two aeration tanks followed by two final settlement tanks. Sludge is stored in a sludge holding tank prior to dewatering for final removal from the site. The WWTP has a capacity of 4,000 P.E. while the average input is 2,500 P.E. Emissions from the WWTP are discharged into the Atlantic ocean via rocky shoreline through a primary discharge point at SW1 (see Figure 3.1 below). There is also a storm water overflow at this point (SW5) which discharges all flows in excess of 3 DWF via the same discharge pipe. There are 3 No. secondary discharge points (labeled SW2, SW3 and SW4; see Figures 3.2 and 3.3 below). These are emergency overflows at the pump houses. These secondary discharges are provided in case of difficulties, such as power cuts at the pumping plant and excessive rainfall. To protect Keel strand there is no storm-water overflow at the Keel Pumping Station. There is, however, a Balancing Tank and standby generator. To protect Dooagh Strand the total pumping capacity at the main Dooagh Pumping Station is 12 D.W.F. (dry weather flow).

Final effluent is treated to a level of less For inspection than 20mg/l purposes only. BOD and 30mg/l Suspended Solids. The Consent of copyright owner required for any other use.3 average volume currently discharge from the WWTP is 562.5m /day, equivalent to an average discharge of 162kg BOD/day.

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Figure 3.1 – Location of Primary & Storm water Discharges (SW1P & SW5)

For inspection purposes only. Consent of copyright owner required for any other use.

Figure 3.2 – Location of Secondary Emergency Discharges (SW2 & SW4) at Dooagh Strand.

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Figure 3.3 – Location of Secondary Emergency Discharge (SW3) into Gallagher’s River, approximately 1.4km upstream of Keel Beach.

3.2 – Description of Natura 2000 Site

Name: Achill Head SAC (Site Code 002268) (see Appendix A for site synopses) Achill Head is the most westerly point of Achill Island in Co. Mayo. It comprises an area of approximately 7165ha. The Site is designated for three Annex 1 habitats as follows: For inspection purposes only. - Large shallow inlets and baysConsent (Habitat of copyright Code owner 1160) required (approx for any other 20% use. of the site).

- Reefs (Habitat Code 1170) (approx. 40% of the site). - Mudflats and sand flats not covered by seawater at low tide (Habitat Code 1140) (approx. 1% of the site). The site contains excellent examples of reef communities, including some characterised by Axinellid sponges and one which supports large numbers of the rare brachiopod, Neocrania anomala. Extensive areas of shallow bays and inlets and the beaches at Keem Bay and Tramore are also included in the site providing good examples of shallow water bay communities and mudflats and sand flats not covered by seawater at low tide. These habitats both support diverse communities of characteristic plants and animals as well as some more unusual species. Achill Head is considered of high conservation value.

Name: Keel Machair/Menaun Cliffs SAC (Site Code 001513) (see Appendix A for site synopses) This site is located along the southern coast of Achill Island and comprises an area of approximately 1616ha. The northern part of the site consists of a low-lying, flat coastal

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EPA Export 26-07-2013:14:27:59 Achill Island Central Wastewater Discharge Licence Application – Appropriate Assessment grassland, or machair, which is backed by Keel Lough. Southeast of the machair, the ground rises steeply to 466m, and the shoreline changes from a flat, sandy beach to impressive sea- cliffs. The site also extends inland, past Menaun Heights (403m). The Site is designated for three Annex I habitats and one Annex 2 species as follows: - Perennial vegetation of stony banks (Habitat Code 1220) (approx. 1% of site) - Machair (Habitat Code 21A0) (approx. 6% of site) - Alpine and Boreal heaths (Habitat Code 4060) (approx. 12% of site). - Petalophyllum ralfsii (Species code 1395) A number of rare and scarce species have been recorded in damp hollows in the dunes and machair. The NPWS have records of two Flora Protection Order Species on Keel Beach, Sea Pea (Lathyrus japonicus) and Penny Royal (Mentha pulegium), the latter characterized as vulnerable in the IUCN Red Data Book. The NPWS also have records of Slender Naiad (Najas flexilis) at Keel Lough (within the SAC), this species is also a Flora Protection Order Species, which is considered rare (according to the IUCN Red Data Book) and is listed on Annex II and Annex IV of the Habitats Directive. This site has a good diversity of coastal and montane habitats including a small, though significant example of alpine heath. The machair is a good example of a habitat which is increasingly rare in Europe, and which receives priority status on Annex I of the European Habitats Directive. A remarkable feature of the site is its rich moss and liverwort flora, which is of international significance and includes an Annex II species. The ornithological importance of the site enhances the conservation value of this site.

Name: Croaghaun/Slievemore SAC (Site Code 001955) (see Appendix A for site synopses) For inspection purposes only. Consent of copyright owner required for any other use. This site is located on the north-western side of Achill Island, in north-west Mayo and comprises an area of approximately 3295.2ha. The site consists mainly of two mountains, Croaghaun and Slievemore, both over 650m O.D. It is dominated by cliffs which can exceed 300m, with scree mantling the slopes above the vertical cliffs. From the high cliffs around Croaghaun towards the northern cliff edge is a group of five cirques perched at various levels above the sea. In these corries some very old and degraded moraines are found. The Site is designated for seven Annex 1 habitats as follows: - Alpine and Boreal Heaths (Habitat Code 4060) (approx. 9% of the site) - Vegetated sea cliffs of the Atlantic and Baltic coasts (Habitat Code 1230) (approx. 10% of site) - Northern Atlantic wet heaths with Erica tetralis (Habitat Code 4010) (approx.18% of site) - Blanket bog (habitat Code 7130) (approx. 12% of site) - Oligotrophic to mesotrophic standing waters with vegetation of the Littorelletea uniflorea and/or of the Isoeto-Nanojuncetea (Habitat Code 3130) (approx 1% of site)

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- Oligotrophic waters containing very few minerals of sandy plains (Littorelletelia uniflorae) (Habitat Code 3110) (approx. 2% of site) - European Dry Heaths (Habitat Code 4030) (approx. 10% of site. This site is of ecological interest for its excellent quality heath, supporting a range of rare species of vascular plant and bryophyte. The presence of a number of other typical coastal and upland habitats adds habitat diversity to this scenic site.

3.3 – Other projects and plans to be considered ‘in combination’. There have been 187 planning applications since 2003 within the Agglomeration serviced by the Achill Island Central WWTP, 158 of which were granted permission (none of which have received a commencement notice). None of these planning applications were for significant projects or plans that would impact on sites of nature conservation importance, or that would have an impact ‘in combination’ with the Achill Island Central WWTP and associated discharges. Planning applications related to residential or ancillary works. There is currently no Local Area Plan for the study area in question. Conclusion: There are no other projects and plans that need to be considered in ‘combination’.

3.4 – Assessment Criteria

3.4.1 – Is the development in or on the boundary of the aforementioned nature conservation sites? Yes, the primary discharge point (SW1P), two of the secondary discharge points (SW2 & SW4) and a storm water discharge point (SW5) discharge directly into Achill Head SAC. One of the secondary discharge points (SW3) is located approximately 90m upstream of the Keel Machair/Menaun Cliffs SAC.

Discharge points are located within 3km For inspectionof the purposesCroaghaun/Slievemore only. SAC but do not directly Consent of copyright owner required for any other use. impact on this site.

3.4.2 – Will nationally protected species be directly impacted? Wildlife Acts (1976 and 2000), Flora Protection Order (S.I. 94 of 1999)? There will be no direct impact on nationally protected species that come under the Wildlife Acts. The Irish Whale and Dolphin Group (IWDG) have recorded a number of dolphin, porpoise, whale and other cetacean sightings (species listed in the Fifth Schedule of the Wildlife Act) within the wider bay south of the study area, including 2 killer whale sightings off Achill Head in April 2009, 22 basking shark sightings in May and June of 2008 and bottlenose dolphin sightings in April and May 2008 (See Figure 3.4 below). It is noted that while three Flora Protection Order Species are located in the Keel Machair/Menaun Cliffs SAC within 3km of one of the secondary discharge points (SW3), none of these are located within the watercourse or marine aquatic environment downstream of this discharge point and would not be impacted either directly or indirectly. Achill Head SAC is designated for marine habitats and is discussed under item 3.4.7 below.

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Figure 3.4 – Marine mammal sightings by the IWDG. Note: All records are validated and available on www.iwdg.ie

3.4.3 – Is the development a surface water discharge or abstraction in the surface water catchment or immediately downstream of a nature conservation site with water dependant qualifying habitats/species? No. For inspection purposes only. The Keel/Menaun Cliffs SAC is Consentdesignated of copyright for owner th reerequired Annex for any other1 habitats use. ‘Perennial vegetation of stony banks’, ‘Alpine and Boreal heaths’ and ‘machair’, which are habitats found above the high tide mark, and thus not dependent on water nor considered at risk from surface water discharges from the Achill WWTP. The site is also designated for the species Petalophyllum ralfsii (Petalwort), found in dune slacks. The UK Biodiversity Action Plan (www.ukbap.org.uk/UKPlans.aspx?ID=509) cited factors contributing to loss or decline of this species as drainage, recreation, botanical collection and construction of golf courses. It is considered that surface water discharges from the WWTP will not impact on this species.

3.4.4 – Is the development a groundwater discharge or abstraction in the ground water catchment or within 5km of a nature conservation site with water-dependant qualifying habitats/species? No.

3.4.5 - Is the development in the surface water or groundwater catchment of salmonid waters? No.

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3.4.6 – Is the treatment plant in an active or former floodplain or flood zone of a river, lake etc.? No.

3.4.7 – Is the development of a surface discharge or abstraction to or from marine waters and within 3km of a marine nature conservation site? Yes, the Achill Head SAC is located directly adjacent to and downstream of discharges points associated with the Achill WWTP. This SAC is designated for three Annex 1 habitats as detailed under section 3.2 above. Habitats and species within the other two SACs detailed above (Croaghaun/Slievemore SAC and Keel Machair/Menaun Cliffs SAC) do not fit into this category.

3.4.8 –Will the project in combination with other projects (existing and proposed) or changes to such projects affect the hydrology or water levels of sits of nature conservation interest or the habitats of protected species? No.

3.4.9 - Conclusion: It is considered that an Appropriate Assessment is required to assess the impacts of wastewater discharges to the Achill Head SAC (Site Code 002268).

4. FINDINGS OF SIGNIFICANT EFFECTS REPORT MATRIX

4.1 – Name of project or plan Achill Island Central Wastewater Treatment Plant Discharge Licence Application

4.2 - Name and location of Natura 2000 For inspectionsites purposesAchill only. Head Special Area of Conservation (Site Consent of copyright owner required for any other use. Code 002268); Keel Machair/Menaun Cliffs Special Area of Conservation (Site Code 001513); and Croaghaun/Slievemore SAC (Site Code 001955)

4.3 - Description of the project or plan As 3.1 above.

4.4 - Is the project or plan directly No. connected with or necessary to the management of the site (provide details)?

4.5 - Are there other projects or plans that No. together with the project or plan being assessed could affect the site (provide details)?

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5. – THE ASSESSMENT OF SIGNIFICANCE OF EFFECTS

5.1 - Describe how the project or plan (alone or in combination) is likely to affect the Natura 2000 site.

L8/08 states that if the screening process under section 3 above is to “Assess Impacts” then the project must be referred to the DEHLG Development Applications Unit (DAU). This Screening and Appropriate Assessment Report will be forwarded to the DAU along with the EPA. Impacts are summarized below based on Figure 1: Screening Matrix of the EC Guidance (2001). Likely Impacts of project: - Size & Scale: The relative small scale of the WWTP ( 562.5m3/day, equivalent to an average discharge of 162kg BOD/day) compared with the open dispersive nature of the receiving waters reduces the likelihood of impact; - Land-take: The WWTP does not require any land take from the SAC; - Distance from Nature 2000 Site or key features of the site: The WWTP discharges directly into the Achill Head SAC; - Resource Requirements: None (water abstraction etc.); - Emissions: It is considered that the potential impacts of the Achill WWTP and associated discharges relate to impacts from emissions to water and indirect impacts on marine species and habitats from these emissions; - Excavation Requirements: None; - Duration of Construction, Operation, and Decommissioning: No construction or decommissioning anticipated in the near future, while the operation of the WWTP and associated discharges are considered long-term. For inspection purposes only. Likely changes to site: Consent of copyright owner required for any other use.

- Reduction of habitat area: No impact likely; - Disturbance to key species: Possible indirect impact, details given in Appropriate Assessment below; - Habitat or species fragmentation: No impact likely; - Reduction in species density: Possible impact, details given in Appropriate Assessment below; - Changes in key indicators of conservation value (water quality etc.): Possible impact, detailed in Appropriate Assessment below; - Climate Change: No impact likely. - Indicators of significance: change to key elements of the site (i.e. water quality).

5.2 - Explain why these effects are not considered significant.

While it is considered that the impacts of the WWTP and associated discharges are unlikely to

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EPA Export 26-07-2013:14:27:59 Achill Island Central Wastewater Discharge Licence Application – Appropriate Assessment have a significant impact on the SAC, the precautionary principle dictates that an Appropriate Assessment is required. Further details contained within Appropriate Assessment below.

5.3 - List of Agencies Consulted: Provide contact name and telephone or e-mail address:

1. Naomi Kingston/ Rebecca Jeffrey, National Parks and Wildlife Service, e-mail: [email protected], [email protected] 2. Trevor Alcorn, Data Analyst, Marine Institute, e-mail: [email protected] Any available data was assessed from the following websites, WFD , Western RBD, National Biodiversity Data Centre, Department of Environment Heritage and Local Government, and National Parks and Wildlife.

5.4 - Response to Consultation

Received existing marine data for the study area from the Marine Institute (the only available data was for sea temperature and partial fish census on fishing activities). There are no conservation plans for the SACs in question but the NPWS sent on draft conservation objectives based on the qualifying interests for these sites.

DATA COLLECTED TO CARRY OUT THE ASSESSMENT SCREENING

Who carried out the Appropriate Assessment Screening?

Louise Collier, GIS Section, Mayo County Council

Sources of data

Any available data was assessed from the following websites, WFD Ireland, Western RBD, National Biodiversity Data Centre, Department For inspection of purposes Environment only. Heritage and Local Government, Consent of copyright owner required for any other use. and National Parks and Wildlife. See References/Sources of report.

Level of Assessment

Desk top study, site walkover survey by marine/freshwater ecologist (Louise Collier).

Where can the full results of the Assessment Screening be accessed and viewed?

Water Services Capital Works Section, Mayo County Council.

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STEP 2 – APPROPRIATE ASSESSMENT 6.1 Introduction The impact of the project or plan (either alone or in combination with other projects or plans) on the integrity of the Achill Head SAC is assessed below, with respect to the conservation objectives of the site and to its structure and function. In this case, the project or plan is considered to the existing sewage effluent discharges at Achill Island Central WWTP. 6.2 Description of the plan likely to give rise to significant effects on the site The description of the plan is given in Section 3.1 above. The likely significant effects on the site are deterioration in water quality which could have an indirect impact on the water dependent habitats and species within the SAC. 6.3 Qualifying Interests for Achill Head cSAC . Large shallow inlets and bays; . Reefs; . Mudflats and sand flats not covered by seawater at low tide. 6.4 Conservation Objectives for the Achill Head cSAC European and national legislation places a collective obligation on Ireland and its citizens to maintain at favourable conservation status areas designated as candidate Special Areas of Conservation. The Government and its agencies are responsible for the implementation and enforcement of regulations that will ensure the ecological integrity of these sites. According to the EU Habitats Directive, favourable conservation status of a habitat is achieved when: • Its natural range, and area it covers within that range, is stable or increasing, and • The ecological factors that are necessary for its long-term maintenance exist and are For inspection purposes only. likely to continue to existConsent for theof copyright foreseeable owner required future, for any andother use.

• The conservation status of its typical species is favourable as defined below. The favourable conservation status of a species is achieved when: • Population data on the species concerned indicate that it is maintaining itself, and • The natural range of the species is neither being reduced or likely to be reduced for the foreseeable future, and • There is, and will probably continue to be, a sufficiently large habitat to maintain its populations on a long-term basis. Objective 1: To maintain the Annex I habitats for which the cSAC has been selected at favourable conservation status: Mudflats and sand flats not covered by seawater at low tide; Large shallow inlets and bays; Reefs. Objective 2: To maintain the extent, species richness and biodiversity of the entire site.

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Objective 3: To establish effective liaison and co-operation with landowners, legal users and relevant authorities. The specific Habitat Conservation Objectives for these three Annex 1 habitats are as follows: Mudflats and Sand flats not covered by seawater at low tide The total national resource of mudflats and sand flats must be maintained at, or restored to, favourable conservation status. This may be achieved through the following objectives: . Maintain the range of mudflats and sand flats as stable within Ireland and prevent the equivalent of a 1% loss per annum, and no more than 10% loss in total; . Maintain the distribution of mudflats and sand flats as stable across the national range and prevent significant changes in its distribution pattern; . Prevent the equivalent of a 1% loss in surface area per annum, and no more than 10% loss in total; . Prevent any reduction in the diversity of floral and faunal species arising from human activities; . Ensure there is no reduction in area or disturbance of intertidal sea grass or biogenic communities; . Ensure individual operations or activities, in combination with other operations or activities, do not cause a change in typical species composition in more than 25% of the area occupied by each of the principal sediment community types; . Ensure the water quality in tidal mudflats and sand flats is of sufficient quality to maintain the integrity of the principal community types; and . Ensure that there is a sufficiently large habitat of suitable quality available to support the long term survival of species associated For inspection purposeswith this only. habitat. Consent of copyright owner required for any other use.

Large Shallow Inlets & Bays The total national resource of large shallow inlets and bays must be maintained at, or restored to, favourable conservation status. This may be delivered through the following objectives: . Maintain the range of inlets and bays as stable within Ireland and prevent the equivalent of a 1% loss per annum, and no more than 10% loss in total; . Maintain the distribution of inlets and bays as stable across the national range and prevent significant changes in its distribution pattern; . Prevent the equivalent of a 1% loss in surface per annum, and no more than 10% loss in total; . Prevent any reduction in the diversity of floral and faunal species arising from human activities; . Ensure there is no deterioration of communities that are nationally rare, internationally threatened and/or in decline including inter alia

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o Zostera marina communities, o Limaria hians reefs, o Maërl communities, o Pachycerianthus beds, o Lanice conchilega communities, o Sea pen communities, o Sabella pavonina communities, o Neopentadactyla mixta beds, o Serpula vermicularis reefs, o Edwardsia delapiae communities, o Ostrea edulis reefs,

. Ensure individual operations or activities, in combination with other operations or activities, does not cause a change in the integrity of the principal community types; . Ensure the water quality in large shallow inlets and bays is of sufficient quality to maintain the integrity of the principal community types; and . Ensure that there is a sufficiently large habitat of suitable quality available to support the long term survival of species associated with this habitat. Reefs The total national resource of reefs must be maintained at, or restored to, favourable conservation status. This may be delivered through the following objectives: . Maintain the range of reefs as stable within Ireland and prevent the equivalent of a 1% loss per annum, and no more than 10% loss in total; . Maintain the distribution of reefs as stable across the national range and prevent significant changes in its distribution pattern; . Prevent the equivalent of a 1% loss in surface area per annum, and no more than 10% loss in total;

. Prevent any reduction in the Fornumber inspection of purposes floral only. and faunal species arising from human Consent of copyright owner required for any other use. activities; . Ensure individual operations or activities, in combination with other operations or activities, does not cause a change in the integrity of the principal community types; and . Ensure that there is a sufficiently large habitat of suitable quality available to support the long term survival of species associated with this habitat.

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STEP 3 - APPROPRIATE ASSESSMENT – ASSESSING THE IMPACTS The likely significant effects on all three Annex 1 habitats are deterioration in water quality which would have an impact on the water dependent habitats and species described above. 7.1 – Assessment Methodology A desktop study was undertaken of existing data on the study area. Existing species/habitat data was assessed against the best available information on the sensitivity of these habitats/species to changes in water quality. The only marine benthic species and habitat data available for the study area was from the BioMar survey (Picton & , 1998) undertaken between 1993 and 1996, which provided detailed species/habitat data for 18 sites within the vicinity of the study area (out of a total of 900 sites surveyed around Ireland). A walkover survey was undertaken of the intertidal (littoral) on the 25th June 2009 at mid-low tide to identify key habitats/species (see Appendix B for plates & Appendix D for further information on habitats). Approximate Information on water depth was extracted from the raster admiralty chart available for the study area and interpolated using MapInfo Vertical Mapper (using Inverse Distance Weighting) to derive an approximate map of water depth for the study area (interpolation was based on 330 points). Wave exposure data was extracted from BioMar sites and overlaid onto this map to assist with assessment of likelihood of dispersion of effluent from discharge points (see Figure 7.1). Limited substrata information that was available from the raster admiralty chart available for the study area and for BioMar sites was interpolated (based on 43 points throughout the study area) using MapInfo Vertical Mapper (using Inverse Distance Weighting where point substrata data were allocated numbers on an arbitrary scale from 1 to 6 for interpolation purposes)1 to derive an approximate map of substrata for the study area (see Figure 7.2). For inspection purposes only. Biomar species/biotope data wereConsent assessed of copyright agai ownernst required species for any otherand use. habitat sensitivity data currently available through a number of key on-line resources (MarLin – Marine Life Information Network, JNCC Habitat Classification, the UK Marine SACs project, Habitas - Encyclopaedia of Marine Life of Britain and Ireland). Specific references used in this report are cited at the end of the report. MarLin has derived 7 different sensitivity ratings, from Not Relevant/Not Sensitive to Very High Sensitivity (www.marlin.ac.uk). Further details are provided in Appendix C of this report. Each site was allocated a sensitivity rating to (a) Increased Suspended Solids, (b) Changes in nutrient levels, (c), Changes in oxygenation and (d) Introduction of microbial pathogens/parasites, as these were considered the key likely sources of impact from discharges from Achill WWTP and was amongst the sensitivity categories available on the MarLin website (see Appendix D for further details). Where a sensitivity rating was available based on specific habitats this was used, and where this data was not available, then sensitivity was assessed based on key species found within these sites.

1 Rock = 6, Mixed Substrata = 5, Gravel = 4, Shingle = 3, Sand = 2, Mud = 1)

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7.2 – Physical Characteristics of the Study Area The nature of marine habitat and species assemblages are largely determined by water depth, wave exposure and substrata. Based on the extrapolation of available information on the study area (as per methodology above), the study area is very wave exposed and open, with most of the area characterised by deep water (up to 45m depth) as illustrated in Figure 7.1. This would indicate a high capacity for dilution and dispersion of any discharges into the site, particularly along the western part of the coastline.

For inspection purposes only. Consent of copyright owner required for any other use.

Figure 7.1 – Interpolated approximate water depth and wave exposure levels south of Achill.

From interpolation of the sparse substrata data available, the eastern part of the site is characterised by sand/shingle substrata, with rock dominating towards the more exposed areas, particularly along the western part of the site (see Figure 7.2).

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Figure 7.2 – Interpolated substrata south of Achill.

7.3 –Chemical Characteristics of the Study Area (i.e. water quality) Water quality data is available for Keem and Keel beaches (both Blue Flag Beaches) collected as part of the Quality of Bathing Waters Regulatio For inspectionns, purposes 1992 only. (S.I. 155 of 1992). In addition, effluent Consent of copyright owner required for any other use. quality is monitored at the primary discharge point from Achill WWTP. The location of the Blue Flag Beaches and wastewater sampling points are shown on Figure 7.3 below. Both Keel and Keem beaches are in compliance with the Guide values and well within the Mandatory values for the Quality of Bathing Water Regulations, from water quality data assessed between 2005 and 2009. The only non-compliance at Keel was one sample in 2007 that was above the guide value (but well below the mandatory values) for total coliforms and faecal coliforms. Keem is considered outside the zone of impact; however bathing water quality was assessed here, with only two non-compliances with the mandatory values in 2005 and 2007. It must be noted that compliance is required for 95% of samples for these two parameters. On the basis of these data, it is considered that the WWTP and associated discharges do not impact on pathogen/microbial levels in receiving waters of concern.

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Figure 7.3 – Location of water quality sites

A summary of effluent quality for key parameters for Achill is presented in Table 7.2 below. Table 7.2 – Summary of key effluent data for Primary Discharge at Achill WWTP.

For inspection purposes only. Dissolved DissolvedConsent of copyrightBOD owner requiredOrtho- for any other use.Total Total Total Oxygen Oxygen (mg/l) phosphate Oxidized Nitrogen Phosphorus (% Sat) (mg/l) (mg/l) Nitrogen (mg/l) (mg/l) (mg/l) No Samples 25 17 49 49 49 49 48 Average 2009 59.4 1.3 4.2 0.75 15.22 21.1 0.94 Max 2009 73.0 6.4 9 2.45 57.66 60.3 2.77 Average 2005- 60.8 0.7 6.97 0.76 6.54 8.1 0.95 2009 Min 2005-2009 32.0 1.0 0.0 0.1 0.0 0.1 Max 2005-2009 104.0 6.4 37 5.40 57.66 60.3 7.10

Water quality objectives for marine waters are relatively poorly defined, compared with freshwaters. The EPA assesses the Trophic Status of Irish estuaries, bays and near shore coastal waters. Under this Trophic Status Assessment Scheme (TSAS), dissolved oxygen concentrations in full salinity waters should be maintained between 80 and 120%, median dissolved inorganic nitrogen concentrations should not exceed 0.25mg/l nor ortho-phosphate exceed 0.04mg/l. In addition, good practice would indicate that marine waters should comply with Shellfish Waters Directive water quality standards (i.e. should not exceed guideline value of 300 faecal coliforms/100ml). Water quality at Keem and Keel beaches were well below 300 faecal

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EPA Export 26-07-2013:14:27:59 Achill Island Central Wastewater Discharge Licence Application – Appropriate Assessment coliforms/100ml in samples collected between 2005 and 2009 with the exception of one sample at both Keel and Keem beaches in 2007. While there is no receiving water data downstream of the primary discharge point, the open and exposed nature of the coastline at the discharge point and surrounding area ensure that there is a very high dispersion capacity for discharges, and that a discharge volume of 55m3/day from Achill Central WWTP is easily assimilated by receiving waters. It is considered that pollutant levels within the SAC will be diluted to insignificant levels based on the effluent characteristics in Table 7.2 above when compared with recommended water quality values for the TSAS (see above) and other water quality objectives. 7.4 –Marine Habitats/Species (and their Sensitivity to Wastewater inputs) A summary of the sensitivity and characteristics habitats/species found in a littoral site survey on the 25th June 2009 and for BioMar habitats in the wider study area is included in Appendix D and the assessment below is based solely on this data. The site survey confirmed that the location of the primary and storm water discharge point (SW1p/SW5) is very exposed, with likely high dispersion of treated effluent from the outfall. There was no evidence of an impact from a visual survey of the site. The site was characterised by boulders and bedrock, supporting predominantly very sparse lichens and bare rock on the upper shore, barnacles and the mussel Mytilus edulis on the mid to lower shore, with patches of red algae (predominantly Mastocarpus stellatus). There were a number of rock pools of varying size, characterised by coralline algae (particularly Corallina officinalis) and the sea anemone, Actinia equina. The sublittoral fringe was characterised by thongweed, Himanthalia elongata. The habitats and species present at the site are characteristic of the wider area as a whole. The secondary discharge point, SW2 enters a small stream which discharges onto the rocky foreshore, consisting of similar habitats to those at SW1. There was no evidence of any discharge from SW2. The secondary discharge point, SW4 percolates through upper shore barren boulder/cobble substrata onto Dooagh Strand, which is characterised by tide swept coarse sand with the only the isopod, Eurydice pulchra observed in small numbers from digs undertaken For inspection purposes only. during the site survey. Again Consentthere of was copyright no owner evidence required for ofany anyother use.discharge from the secondary discharge point, SW4. The secondary discharge SW3 is located on a small stream that ultimately discharges to Keel Beach. There was no evidence of any discharge from this location, and it is considered that discharges are so infrequent and minor from these secondary outfalls, as to have an insignificant impact on receiving environments. Sensitivity of existing habitats/species assemblages to key water quality parameters relevant to discharges from Achill WWTP are shown below in Figures 7.4 to 7.7 respectively and impacts within 3km of discharge points are detailed further below. . Sensitivity to Increased Suspended Solids loadings: Marine biotopes/species assemblages located within 3km of discharge points at Achill WWTP are not sensitive or of low sensitivity to increased suspended solids loading (see Figure 7.4). . Sensitivity to nutrient inputs: Marine biotopes/species assemblages within 3km of the discharge points at Achill WWTP are generally of low sensitivity to increased suspended solids (see Figure 7.5). The only habitats of moderate/high sensitivity within 3km are the supralittoral habitats, Pelvetia canaliculata on supralittoral rock (White, 2008) and yellow and grey lichens on supralittoral rock (Tyler-Walters, 2008), which are located

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at the high tide mark, and thus only subject to potential impacts at high tide. In addition these species poor habitats are present along all coasts of Ireland and are not of nature conservation importance. In addition, the habitat, Burrowing amphipods and Eurydice pulchra in well-drained clean sand shores, present on Dooagh Strand downstream of the secondary discharge points SW2 and SW4 is moderately sensitive to changes in nutrient inputs (Budd, 2008). This habitat and species contained within are common, and it is considered that the secondary discharges are not impacting on this beach. . Sensitivity to changes in oxygenation levels: Marine biotopes/species assemblages within 3km of the discharge points at Achill WWTP are of low to moderate sensitivity to changes in dissolved oxygen content (see Figure 7.6) although the moderately sensitive sites are not within 3km of the primary discharge, with the exception of the habitat, Burrowing amphipods and Eurydice pulchra in well-drained clean sand shores, present on Dooagh Strand downstream of the secondary discharge points SW2 and SW4. Impacts of these secondary discharges are considered not significant, as detailed above. . Sensitivity to Introduction of Microbial pathogens/parasites: Marine biotopes/species assemblages located within 3km of discharge points at Achill WWTP are not sensitive or of low sensitivity to an introduction of microbial pathogens although it must be noted that insufficient information is available to assess sensitivity for many biotopes (see Figure 7.7). Biotopes within 3km of the primary discharge point are not sensitive, with the exception of Pelvetia canaliculata on supralittoral rock (see comments under sensitivity to nutrient inputs above), and rock pools containing the purple sea urchin and coralline algae – whereby the constituent species are considered common (purple sea urchin) / widespread (Corallina officinalis) along the west coast of Ireland (Pizzolla, 2008; Tyler-Walters, 2008) and are not of nature conservation importance.

For inspection purposes only. Consent of copyright owner required for any other use.

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Figure 7.4 - Habitat Sensitivity to Increase in Suspended Solids

For inspection purposes only. Consent of copyright owner required for any other use.

Figure 7.5 - Habitat Sensitivity to Change in Nutrient Levels

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Figure 7.6 - Habitat Sensitivity to Change in Oxygenation

For inspection purposes only. Consent of copyright owner required for any other use.

Figure 7.7 - Habitat Sensitivity to Introduction of Microbial Pathogens/Parasites

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7.5 – Impact Prediction & Conservation Objectives One of the key objectives of the Annex 1 Habitat Large shallow inlets and bays is to ensure there is no deterioration of communities that are nationally rare, internationally threatened and/or in decline, particularly the list of habitats below. Available data on marine species and habitats in the study area (i.e. from littoral site survey and existing BioMar data) was assessed for presence of these key communities and is summarized below: . Zostera marina communities – not present at any of the BioMar Sites; . Maërl communities – Corallinacea species present within 20 of the BioMar habitats located within the study area and was common at many of these sites. However, none of the sites were specifically characterised by maerl species with the algae comprising a minor part of these habitats. It must also be noted that MarLin have found Corallina officinalis to be of low sensitivity to increases in suspended sediment, changes in nutrient levels and introduction of microbial pathogens/parasites (Tyler-Walters, 2008). . Lanice conchilega communities – Lanice was present within 5 of the BioMar habitats within the study area, but not as a ‘community’, but rather small numbers in other habitats; . Sabella pavonina communities – not present in any of the BioMar sites; . Serpula vermicularis reefs – not present in any of the BioMar sites; . Ostrea edulis reefs – not present in any of the BioMar sites; . Limaria hians reefs – not present in any of the BioMar sites; . Pachycerianthus beds – not present in any of the BioMar sites; . Sea pen communities – not present in any of the BioMar sites; . Neopentadactyla mixta beds – not present in any of the BioMar sites;

. Edwardsia delapiae communities For inspection– not present purposes only. in any of the BioMar sites. Consent of copyright owner required for any other use.

The key concern from the Conservation Objectives for all three Annex 1 habitats present within the SAC is to ensure the water quality in large shallow inlets and bays is of sufficient quality to maintain the integrity of the principal community types. As detailed under Section 7.4 above (see also Appendix D for further details on habitats), the key habitats and species present within the study area and potential zone of impact are generally not sensitive to increases in suspended solids, nutrients or microbial pathogens. While a small number of habitats and species within the 3km potential zone of impact are of moderate to high sensitivity to changes in nutrient and dissolved oxygen levels, based on the evidence presented in sections 7.2 to 7.4 above, it is considered that the open, exposed nature of the coastline, and large water depths are more than adequate to disperse discharged treated effluent to insignificant levels, and keep oxygenation levels high so that there is no risk to the species or habitats within the SAC. In addition the species and habitats present within 3km of discharge points that had a moderate to high sensitivity were common/widespread and were not of nature conservation importance, or key habitats/species for which the SAC is designated.

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Thus it is considered that the Achill Island Central WWTP and associated discharges are not having any significant impact on marine communities of nature conservation value and are not at risk of compromising the Conservation Objectives of the Achill Head SAC. STEP 4 - Mitigation Measures / Need for Alternatives It is recommended that ambient water quality monitoring be undertaken in the bay downstream of the Primary Discharge Point (SW1P). The exact nature and content of this sampling/monitoring program should be agreed with the EPA. REFERENCES Budd, G.C. 2008. Burrowing amphipods and Eurydice pulchra in well-drained clean sand shores. Marine Life Information Network: Biology and Sensitivity Key Information Sub-programme [on- line]. Plymouth: Marine Biological Association of the . [cited 18/06/2009]. Available from: Budd, G.C. 2008. Alcyonium digitatum. Dead man's fingers. Marine Life Information Network: Biology and Sensitivity Key Information Sub-programme [on-line]. Plymouth: Marine Biological Association of the United Kingdom. [cited 18/06/2009]. Available from: Budd, G.C. 2008. Asterias rubens. Common starfish. Marine Life Information Network: Biology and Sensitivity Key Information Sub-programme [on-line]. Plymouth: Marine Biological Association of the United Kingdom. [cited 22/06/2009]. Available from: Budd, G.C. 2008. Corallina officinalis and coralline crusts in shallow eulittoral rock pools. Marine Life Information Network: Biology and Sensitivity Key Information Sub-programme [on-line]. Plymouth: Marine Biological Association of the United Kingdom. [cited 18/06/2009]. Available from: Budd, G.C. 2008. Foliose red seaweeds on exposed or moderately exposed lower infralittoral For inspection purposes only. rock. Marine Life Information Network:Consent of copyrightBiology owner an requiredd Sensitivity for any other Key use. Information Sub-programme [on-line]. Plymouth: Marine Biological Association of the United Kingdom. [cited 23/06/2009]. Available from: Budd, G.C. 2008. Himanthalia elongata and red seaweeds on exposed lower eulittoral rock. Marine Life Information Network: Biology and Sensitivity Key Information Sub-programme [on- line]. Plymouth: Marine Biological Association of the United Budd, G.C. 2008. Ulva spp. on freshwater-influenced or unstable upper eulittoral rock. Marine Life Information Network: Biology and Sensitivity Key Information Sub-programme [on-line]. Plymouth: Marine Biological Association of the United Kingdom. [cited 25/06/2009]. Available from: Department of Environment, Heritage and Local Government (2008) Circular L8/08. Water Services Investment and Rural Water Programmes – Protection of Natural Heritage and National Monuments. EPA (2008) Wastewater Discharge Licensing Appropriate Assessment: Note on Appropriate Assessments for the purposes of the Waste Water Discharge (Authorisation) Regulations, 2007 (S.I. No. 684 of 2007).

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EC (2000) Managing Natura 2000 Sites: The provisions of Article 6 of the ‘Habitats’ Directive 92/43/EEC. EC (2001) Assessment of plans and projects significantly affecting Natura 2000 sites: Methodological guidance on the provisions of Article 6(3) and (4) of the Habitats Directive 92/43/EEC. Guidance document on Article 6(4) of the ‘Habitats Directive’ 92/43/EEC. Hill, J.M. 2008. Antedon bifida. Rosy feather-star. Marine Life Information Network: Biology and Sensitivity Key Information Sub-programme [on-line]. Plymouth: Marine Biological Association of the United Kingdom. [cited 18/06/2009]. Available from: Hill, J.M. 2008. Antedon spp., solitary ascidians and fine hydroids on sheltered circalittoral rock. Marine Life Information Network: Biology and Sensitivity Key Information Sub-programme [on- line]. Plymouth: Marine Biological Association of the United Kingdom. [cited 18/06/2009]. Available from: Hill, J.M. 2008. Barnacles and Patella spp. on exposed or moderately exposed, or vertical sheltered, eulittoral rock. Marine Life Information Network: Biology and Sensitivity Key Information Sub-programme [on-line]. Plymouth: Marine Biological Association of the United Kingdom. [cited 18/06/2009]. Available from: Hill, J.M. 2008. Echinocardium cordatum and Ensis spp. in lower shore or shallow sublittoral muddy fine sand. Marine Life Information Network: Biology and Sensitivity Key Information Sub- programme [on-line]. Plymouth: Marine Biological Association of the United Kingdom. [cited 18/06/2009]. Available from: Hill, J.M. 2008. Echinocardium cordatum. Sea potato. Marine Life Information Network: Biology and Sensitivity Key Information Sub-programme For inspection purposes only.[on-line]. Plymouth: Marine Biological Consent of copyright owner required for any other use. Association of the United Kingdom. [cited 18/06/2009]. Available from: Hiscock, K. & Wilson, E. 2008. Metridium senile. Plumose anemone. Marine Life Information Network: Biology and Sensitivity Key Information Sub-programme [on-line]. Plymouth: Marine Biological Association of the United Kingdom. [cited 18/06/2009]. Available from: Hiscock, K. 2008. Laminaria hyperborea forest with a faunal cushion (sponges and polyclinids) and foliose red seaweeds on very exposed upper infralittoral rock. Marine Life Information Network: Biology and Sensitivity Key Information Sub-programme [on-line]. Plymouth: Marine Biological Association of the United Kingdom. [cited 18/06/2009]. Available from: Hiscock, K. 2008. Laminaria saccharina and/or Saccorhiza polyschides on exposed infralittoral rock. Marine Life Information Network: Biology and Sensitivity Key Information Sub-programme [on-line]. Plymouth: Marine Biological Association of the United Kingdom. [cited 18/06/2009]. Available from: http://www.ukmarinesac.org.uk/communities/subtidal-brittlestar/bs5.htm

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Jackson, A. & Hiscock, K. 2008. Erect sponges, Eunicella verrucosa and Pentapora fascialis on slightly tide-swept moderately exposed circalittoral rock.. Marine Life Information Network: Biology and Sensitivity Key Information Sub-programme [on-line]. Plymouth: Marine Biological Association of the United Kingdom. [cited 18/06/2009]. Available from: Jackson, A. 2008. Neocrania anomala and Protanthea simplex on very sheltered circalittoral rock. Marine Life Information Network: Biology and Sensitivity Key Information Sub-programme [on- line]. Plymouth: Marine Biological Association of the United Kingdom. [cited 23/06/2009]. Available from: Jackson, A. 2008. Neocrania anomala. A brachiopod. Marine Life Information Network: Biology and Sensitivity Key Information Sub-programme [on-line]. Plymouth: Marine Biological Association of the United Kingdom. [cited 18/06/2009]. Available from: "Northen, K.O. and Irving, R.A. 2008. An Atlas of selected marine habitats and species listed on Section 42 of the NERC Act 2006. CCW Contract Science Report No: 833, 72pp. + appendices" Picton, B.E. and Costello M. J. 1998. The BioMar biotope viewer: a guide to marine habitats, fauna and flora in Britain and Ireland, Environmental Sciences Unit, Trinity College, Dublin. Pizzolla, P.F 2008. Paracentrotus lividus. Purple sea urchin. Marine Life Information Network: Biology and Sensitivity Key Information Sub-programme [on-line]. Plymouth: Marine Biological Association of the United Kingdom. [cited 23/06/2009]. Available from: Rayment, W.J. & Pizzola, P.F. 2008. Chondrus crispus. Carrageen. Marine Life Information Network: Biology and Sensitivity Key Information Sub-programme [on-line]. Plymouth: Marine Biological Association of the United Kingdom. [cited 18/06/2009]. Available from:

Tyler-Walters, H. 2008. Alaria esculenta For inspection on exposed purposes only. sublittoral fringe bedrock. Marine Life Consent of copyright owner required for any other use. Information Network: Biology and Sensitivity Key Information Sub-programme [on-line]. Plymouth: Marine Biological Association of the United Kingdom. [cited 18/06/2009]. Available from: Tyler-Walters, H. 2008. Corallina officinalis on very exposed lower eulittoral rock. Marine Life Information Network: Biology and Sensitivity Key Information Sub-programme [on-line]. Plymouth: Marine Biological Association of the United Kingdom. [cited 18/06/2009]. Available from: Tyler-Walters, H. 2008. Corallina officinalis. Coral weed. Marine Life Information Network: Biology and Sensitivity Key Information Sub-programme [on-line]. Plymouth: Marine Biological Association of the United Kingdom. [cited 18/06/2009]. Available from: Tyler-Walters, H. 2008. Mytilus edulis and barnacles on very exposed eulittoral rock. Marine Life Information Network: Biology and Sensitivity Key Information Sub-programme [on-line]. Plymouth: Marine Biological Association of the United Kingdom. [cited 18/06/2009]. Available from:

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Tyler-Walters, H. 2008. Mytilus edulis and Fucus vesiculosus on moderately exposed mid eulittoral rock. Marine Life Information Network: Biology and Sensitivity Key Information Sub- programme [on-line]. Plymouth: Marine Biological Association of the United Kingdom. [cited 18/06/2009]. Available from: Tyler-Walters, H. 2008. Yellow and grey lichens on supralittoral rock. Marine Life Information Network: Biology and Sensitivity Key Information Sub-programme [on-line]. Plymouth: Marine Biological Association of the United Kingdom. [cited 25/06/2009]. Available from: UK Biodiversity Action Plan; Priority Habitat Descriptions. BRIG (ed. Ant Maddock) 2008. White, N. 2008. Pelvetia canaliculata. Channelled wrack. Marine Life Information Network: Biology and Sensitivity Key Information Sub-programme [on-line]. Plymouth: Marine Biological Association of the United Kingdom. [cited 22/06/2009]. Available from:

For inspection purposes only. Consent of copyright owner required for any other use.

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APPENDIX A – SITE SYNOPSES FOR SACS

SITE NAME: ACHILL HEAD (SITE CODE: 002268) Achill Head is the most westerly point of Achill Island in Co. Mayo. The site comprises the shallow waters extending from Head north-westwards to Achill Head and north-eastwards to Gubnahinneora Point. Bedrock is metamorphic schist and gneiss alternating with metamorphic quartzite. High cliffs (650 m) on the northwest of Achill Island drop vertically into the sea forming steep sublittoral reefs. Good examples of reef communities, a habitat listed on Annex I of the EU Habitats Directive, including some characterized by Axinellid sponges and one which supports large numbers of the rare brachiopod, Neocrania anomala. Extensive areas of shallow bays and inlets and the beaches at Keem Bay and Tramore are also included in the site, both Annex I habitats. The rocky shores of Achill Island are very exposed to wave action. Sparse Pelvetia canaliculata characterizes the upper shores. Lower down, mussels (Mytilus edulis) and barnacles are dominant, with abundant Corallina officinalis and occasional Nemalion helminthoides, which is a characteristic red alga of this type of extremely exposed shore. A mosaic of Fucus vesiculosus with barnacles is present in the midshore, while pink coralline crusts are common under Himanthalia elongata on the lower shore. Shallow pools in the mid-shore contain the purple sea- urchin Paracentrotus lividus and the brown seaweed Halidrys siliquosa and mixed red algae are present in deep rock pools. These rocky shore populations of the purple sea-urchin are vulnerable to over-exploitation. Shallow subtidal reef communities of Achill Head are composed of areas that are exposed or extremely exposed to wave action and may extend to a depth of 31 m BCD. The subtidal fringe is dominated by the characteristic brown alga, Alaria esculenta, the mussel (Mytilus edulis) and the starfish (Asterias rubens). With increasing depth Alaria occurs within a forest of kelp in which anemones (Metridium senile, Sagartia elegans and Corynactis viridis) are frequent and the mussel Mytilus edulis is absent. Deeper kelp communities on bedrock are dominated by

Laminaria hyperborea and characterized For inspection by coralline purposes only.algae and a variety of foliose red algae. Consent of copyright owner required for any other use. Characterizing faunal species are sponges (Cliona celata), deadman’s fingers (Alcyonium digitatum), jewel anemones (Corynactis viridis), the top shell (Calliostoma zizyphinum), bryozoans (Parasmittina trispinosa) and the feather star (Antedon bifida). Where kelp thins to a park, the brown foliose algae, Dictyota dichotoma and Dictyopteris membranacea become more common. Reefs in shallow water composed of boulders and cobbles with sand are characterized by the opportunistic kelp Saccorhiza polyschides. In areas very exposed to wave action and at depths of about 25 m or greater the reefs of rugged bedrock with weak to moderate tidal streams are characterized by animal dominated communities. Vertical rock faces have excellent examples of communities characterized by the jewel anemone Corynactis viridis and in a number of places the anemones are mixed with feather star Antedon bifida. The more low-lying rock is covered in pink coralline crusts with the cup coral Caryophyllia smithii. The sponge community characterized by Axinella infundibuliformis and Phakellia ventilabrum is present here also. The sea urchin Echinus esculentus is common in some areas and the sea cucumber Holothuria forskali occurs at most sites. Two rare sponges, Halicnemia verticillata and Spongionella pulchella, and the brachiopod Neocrania anomala, are all recorded in low-lying circalittoral bedrock south of Dysaghy Rocks, and Aglaophenia kirchenpaueri is present on the west side on Carrickakin.

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Littoral sediment communities are very exposed at Trawmore Strand and moderately exposed at Keem Bay Strand with typical communities for these levels of wave exposure in the upper and mid-shore areas. At both sites the strand-line sandhopper community is characterized by Talitrus saltator, Talorchestia deshayesii and Orchestia gammarellus and the mid-shore areas by typical communities of the burrowing amphipod, Pontacrates and Bathyporia species in clean sand. This community extends into the low shore at Tramore strand. The sublittoral sediment around Achill Island is comprised mainly of extensive plains of rippled sand with the burrowing sea urchin Echinocardium cordatum and the bivalve molluscs Mactra stultorum and Ensis siliqua. In shallower water there is coarse mobile sand with Echinocardium cordatum and Lutraria lutraria. Achill Head is of high conservation value owing to the presence of excellent examples of reef communities and good examples of shallow water bay communities and mudflats and sand flats not covered by seawater at low tide. These habitats are listed on Annex I of the EU Habitats Directive and both support diverse communities of characteristic plants and animals as well as some more unusual species. 11.09.2001

SITE NAME: KEEL MACHAIR/MENAUN CLIFFS (SITE CODE :001513) This site is located along the southern coast of Achill Island, and extends between the villages of Keel and Dooega. The northern part of the site consists of a low-lying, flat coastal grassland, or machair, which is backed by Keel Lough. Southeast of the machair, the ground rises steeply to 466m, and the shoreline changes from a flat, sandy beach to impressive sea-cliffs. The site also extends inland, past Menaun Heights (403m). A range of coastal habitats occur at Keel. Tramore, an impressive, sandy beach, backs onto a shingle bar, behind which is a narrow band of sand dunes colonised by Marram (Ammophila arenaria). Behind the dunes is machair, For inspectionor unenclos purposesed only. coastal grassland, which lies on a sandy Consent of copyright owner required for any other use. substrate and is generally flat, but with a very gently undulating series of hummocks and low-lying damp areas. The sward is close-cropped and contains Red Fescue (Festuca rubra), Daisy (Bellis perennis), Ribwort Plantain (Plantago lanceolata), Buck's-horn Plantain (Plantago coronopus), Common Bird's-foot Trefoil (Lotus corniculatus), Lady's Bedstraw (Galium verum) and Common Mouse-ear (Cerastium fontanum). Damp hollows in the dunes and machair support low-growing mats of mosses and liverworts, from which a number of rare and scarce species have been recorded, including Bryum calophyllum (this moss has its only recent Irish record here), B. marratii, Catoscopium nigritum, Tortella inclinata (known only from West Mayo and County Down), Fossombronia fimbriata (a liverwort known only from West Mayo and County Sligo), F. pusilla (known only from West Cork and West Mayo) and F. incurva. Petalwort (Petalophyllum ralfsii), a liverwort species listed on Annex II of the European Habitats Directive, occurs in damp hollows associated with the dunes and machair at Keel. Within the site, shingle beach is best developed along middle and south-eastern parts of Trawmore strand, where it fronts the main area of machair. The shingle bank can be quite tall, reaching a height of between 4-5 m in places. Vegetation along the shingle bank is typically

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EPA Export 26-07-2013:14:28:00 Achill Island Central Wastewater Discharge Licence Application – Appropriate Assessment sparse, being restricted to a handful of hardy, salt-tolerant plant species such as Buck’s-horn Plantain (Plantago coronopus), Sand Couch (Elymus farctus), Ribwort Plantain (Plantago lanceolata), Sea-holly (Eryngium maritimum) and Curled Dock (Rumex crispus). The species- poor nature of the associated vegetation is due primarily to the exposed and highly mobile nature of the habitat. The slopes of Menaun are covered by thin peat, eroded in places down to mineral soil and rock. Extensive areas of heath and some blanket bog occur here. The area around the summit of Menaun (i.e. above 350 m) supports heath vegetation corresponding to alpine and subalpine heath. This is dominated by Ling (Calluna vulgaris), Bell Heather (Erica cinerea) and the moss Racomitrium lanuginosum. Species particularly characteristic of alpine heath include Bearberry (Arctostaphylos uva-ursi), Crowberry (Empetrum nigrum), Juniper (Juniperus communis subsp. nana), Bilberry (Vaccinium myrtillus), Dwarf Willow (Salix herbacea) and Fir Clubmoss (Huperzia selago). The alpine heath merges with extensive areas of dry heath dominated by Ling at lower altitudes. Part of the heath vegetation on Menaun is unusual for its community of mosses and liverworts, known as The Northern Atlantic Hepatic Mat community, which contains a number of species with oceanic/montane affinities. On Achill, this community descends to its lowest altitudinal level in Ireland. On the sea-cliffs around Menaun, the damp rocks also support rich communities of mosses and liverworts, including Cyclodictyon laetevirens and Philonotis rigida. Two protected plant species, Sea Pea (Lathyrus japonicus) and Penny royal (Mentha pulegium) have been recorded within the site. Behind the machair lies Keel Lough, which provides habitat for some wintering waterfowl, notably Whooper Swan, a species listed on Annex I of the EU Birds Directive. Numbers up to 70, occasionally more, occur mainly in autumn and early winter. Another Annex I species, Chough, breeds on the cliffs and uses the low-lying machair areas for feeding; in 1992 six pairs were recorded within the site. A pair of Peregrine frequents the site and probably breeds within it. The sandy machair plain provides good habitat for breeding Ringed Plover, while an area of wet For inspection purposes only. marsh at Sruhillbeg Lough attractsConsent breeding of copyright Lapwowner requireding. forSeabirds, any other use. mostly Fulmars, breed on the cliffs. The site is extensively used for grazing cattle and sheep. The level of grazing and evenness of grazing pressure are critical factors in maintaining the character and species-richness of machair. Heath and blanket bog are also directly affected by high grazing pressure. The scenic qualities of this site, its proximity to Keel and ease of access make it attractive for amenity use. Uncontrolled access and development can damage coastal habitats. This site has a good diversity of coastal and montane habitats including a small, though significant example of alpine heath. The machair is a good example of a habitat which is increasingly rare in Europe, and which receives priority status on Annex I of the European Habitats Directive. A remarkable feature of the site is its rich moss and liverwort flora, which is of international significance and includes an Annex II species. The ornithological importance of the site enhances the conservation value of this site. 3.9.2001

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SITE NAME: CROAGHAUN/SLIEVEMORE (SITE CODE: 001955) This site is located on the north-western side of Achill Island, in north-west Mayo. The underlying geology is pre-Cambrian schists and gneisses at Slievemore and quartzite at Croaghaun. The site consists mainly of two mountains, Croaghaun and Slievemore, both over 650m O.D. It is dominated by cliffs which can exceed 300m, with scree mantling the slopes above the vertical cliffs. From the high cliffs around Croaghaun towards the northern cliff edge is a group of five cirques perched at various levels above the sea. In these corries some very old and degraded moraines are found. This site contains interesting alpine heath, a habitat listed on Annex I of the EU Habitats Directive. The alpine heath is found at higher altitudes in a mosaic with scree and exposed rock, patches of blanket bog and corrie lakes. The montane heath is of particular importance for its communities of oceanic bryophytes, some of which constitute what is known as The North Atlantic Hepatic Mat community, which descends on Achill to its lowest altitude. As well as the typical species for this community, a number of rarities are found including Adelanthus lindenbergianus, Bazzania pearsonii, Mastigophora woodsii, Dicranodontium unciatum, Hymenophyllum wilsonii, H. tunbrigense and Scapania nimbosa. In flushed areas, the rare moss Sphagnum warnstorfii occurs. An interesting array vascular plants are also found on the summits, including St. Patrick’s-cabbage (Saxifraga spathularis), Starry Saxifrage (S. stellaris), Dwarf Willow (Salix herbacea), Bearberry (Arctostaphylos uva-ursi), Lesser Twayblade (Listera cordata) and Stiff Sedge (Carex bigelowii). A species of Eyebright (Euphrasia frigida) is specific to Croaghaun while the scarp below Slievemore supports another scarce species, Mountain Sorrel (Oxyria digyna). On the rocky habitats of the scree slopes, gullies and cliffs around the corrie lakes of Loughs Bunnafreva and Nakeeroge, other notable bryophytes are found including Plagiothecium cavifolium, Cyclodictyon laetevirens, Andeaea rothii, Geocalyx graveolens, Anthelia juratzkana, Radula carringtonii, Marsupella sprucei and M. sphacelata. The rare moss Rhynchostegium lusitanicum has been recorded from the fast flowing streams near Keem. For inspection purposes only. Other habitats at the site includeConsent both of copyrightwet and owner dry required heaths, for any otherupland use. rivers, sea cliffs, islets and small areas of boulder and sandy beaches and some machair. The vegetation of the sea cliffs at Achill Head consists of well-developed examples of Plantain sward (Plantago association) which extends up to 150m up the cliffs. In some areas there is a dense smooth mat of Sea Plantain (P. maritima) and Buck’s-horn Plantain (P. coronopus), dotted with Thrift (Armeria,maritima), Sea-spurrey (Spergularia rupicola), Sea Pearlwort (Sagina maritima), Procumbent Pearlwort (S. procumbens), Sea Mouse-ear (Cerastium tetrandum), Allseed (Radiola linoides) and the grasses Festuca ovina, Aira praecox and Agrostis capillaris. The low sea cliffs in the north are hung with Roseroot (Rhodiola rosea). There are five corrie lakes within the site. At Bunnafreva Lough East, Quillwort (Isoetes lacustris) has been recorded, with an abundance of Water Dropwort (Lobelia dortmanna) Irish Heath (Erica erigena) has its most westerly station on the shores of Lough Nakeeroge. The plant was recorded here between 1982 and 1984. About 40 bushes were seen in a small bay on the northern lakeshore and ten plants were seen growing along a little stream that flows into the lake from the west. In Europe this plant is confined to counties and Mayo in Ireland and is also found in Spain, Portugal and western France.

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Chough, a typical and localized species of the western seaboard, breeds at this site with up to four pairs recorded during a survey in 1992. Chough is a Birds Directive Annex I species. The main land use at the site is grazing, which occurs at high densities in places, especially on the lower slopes where the vegetation is eroded down to mineral soil. Peat cutting is carried out in some areas. Other land uses are amenity management involving track development and provision of car parks, and quarrying immediately adjacent to the boundary at the south centre of the site. This site is of ecological interest for its excellent quality heath, supporting a range of rare species of vascular plant and bryophyte. The presence of a number of other typical coastal and upland habitats adds habitat diversity to this scenic site.

For inspection purposes only. Consent of copyright owner required for any other use.

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APPENDIX B – PLATES FROM SITE SURVEY (25TH JUNE 2009)

Plate 1 – Primary Discharge Point (SW1p) Plate 2 – View of Dooagh Strand from Secondary Discharge Point (SW2)

For inspection purposes only. Consent of copyright owner required for any other use.

Plate 3 – Secondary Discharge Point (SW2) Plate 4 – Secondary Discharge Point (SW4)

Plate 5 –Secondary Discharge Point (SW3)

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APPENDIX C – MARLIN SENSITIVITY RATIONALE

Further details are also available at http://www.marlin.ac.uk/sensitivityrationale.php Table B.1. - MarLin Sensitivity Ranks.

Rank Definition Very High "Very high" sensitivity is indicated by the following scenario: . The habitat or species is very adversely affected by an external factor arising from human activities or natural events (either killed/destroyed, "high" intolerance) and is expected to recover only over a prolonged period of time, i.e. >25 years or not at all (recoverability is "very low" or "none"). . The habitat or species is adversely affected by an external factor arising from human activities or natural events (damaged, "intermediate" intolerance) but is not expected to recover at all (recoverability is "none"). High "High" sensitivity is indicated by the following scenarios: . The habitat or species is very adversely affected by an external factor arising from human activities or natural events (killed/destroyed, "high" intolerance) and is expected to recover over a very long period of time, i.e. >10 or up to 25 years ("low" recoverability). . The habitat or species is adversely affected by an external factor arising from human activities or natural events (damaged, "intermediate" intolerance) and is expected to recover over a very long period of time, i.e. >10 years (recoverability is "low", or "very low"). . The habitat or species is affected by an external factor arising from human activities or natural events (reduced viability **, "low" intolerance) but is not expected to recover at all (recoverability is "none"), so that the habitat or species may be vulnerable to subsequent damage. Moderate "Moderate" sensitivity is indicated by the following scenarios: . The habitat or species is very adversely affected by an external factor arising from human activities or natural events (killed/destroyed, "high" intolerance) but is expected to take more than 1 year or up to 10 years to recover ("moderate" or "high" recoverability). . The habitat or species is adversely affected by an external factor arising from human activities or natural eventsFor inspection (damaged, purposes only. "intermediate" intolerance) and is expected to recover overConsent a long of copyright period owner of required time, for i.anye. other>5 use.or up to 10 years ("moderate"

recoverability). . The habitat or species is affected by an external factor arising from human activities or natural events (reduced viability **, "low" intolerance) but is expected to recover over a very long period of time, i.e. >10 years (recoverability is "low", "very low"), during which time the habitat or species may be vulnerable to subsequent damage. Low "Low" sensitivity is indicated by the following scenarios: . The habitat or species is very adversely affected by an external factor arising from human activities or natural events (killed/destroyed, "high" intolerance) but is expected to recover rapidly, i.e. within 1 year ("very high" recoverability). . The habitat or species is adversely affected by an external factor arising from human activities or natural events (damaged, "intermediate" intolerance) but is expected to recover in a short period of time, i.e. within 1 year or up to 5 years ("very high" or "high" recoverability). . The habitat or species is affected by an external factor arising from human activities or natural events (reduced viability **, "low" intolerance) but is expected to take more than 1 year or up to 10 years to recover ("moderate" or "high" recoverability). Very low "Very low" is indicated by the following scenarios: . The habitat or species is very adversely affected by an external factor arising from human activities or natural events (killed/destroyed, "high" intolerance) but is expected to recover rapidly i.e. within a week ("immediate" recoverability).

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. The habitat or species is adversely affected by an external factor arising from human activities or natural events (damaged, "intermediate" intolerance) but is expected to recover rapidly, i.e. within a week ("immediate" recoverability). . The habitat or species is affected by an external factor arising from human activities or natural events (reduced viability **, "low" intolerance) but is expected to recover within a year ("very high" recoverability). Not sensitive "Not sensitive" is indicated by the following scenarios: . The habitat or species is affected by an external factor arising from human activities or natural events (reduced viability **, "low" intolerance) but is expected to recover rapidly, i.e. within a week ("immediate" recoverability). . The habitat or species is tolerant of changes in the external factor. Not sensitive* The habitat or species may benefit from the change in an external factor (intolerance has been assessed as "tolerant*"). Not relevant The habitat or species is protected from changes in an external factor (i.e. through a burrowing habit or depth), or is able to avoid the external factor. Insufficient information

MarLin List of Environmental Factors assessed with regards sensitivity.

Physical factors Chemical factors . Substratum loss . Synthetic compound contamination . Suspended sediment . Heavy metals contamination . Desiccation . Hydrocarbon contamination . Changes in emergence regime . Radionuclide contamination . Changes in water flow rate . Changes in nutrient levels . Changes in temperature . Changes in salinity

. Changes in turbidity For inspection purposes only.. Changes in oxygenation Consent of copyright owner required for any other use. . Changes in wave exposure Biological factors . Noise disturbance . Introduction of microbial pathogens / parasites . Visual presence . Introduction of non-native species . Physical disturbance and abrasion . Selective extraction of this species . Displacement . Selective extraction of other species

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APPENDIX D – SUMMARY OF HABITATS AND SPECIES IN THE STUDY AREA (BIOMAR & SITE SURVEY DATA)

Site Substratum Habitat Habitat Code Habitat Rarity Sensitivity to Nutrient Sensitivity to Microbial Wave No. Percent No Complex increased Sensitivity Oxygenation Sensitivity Exposure BioMar Of Suspended Solids levels Records BioMar Sites 1 Sand LGS Tal Common Not Sensitive Moderate Moderate Data Deficient Very Exposed 45 23% 1a Sand LGS Eur Common Not Sensitive Moderate Moderate Data Deficient Very Exposed 37 19% 2 Sand LGS Tal Common Not Sensitive Moderate Moderate Data Deficient Very Exposed 45 23% 2a Sand LGS Eur Common Not Sensitive Moderate Moderate Data Deficient Very Exposed 37 19% 3 Bedrock ECR CCParCar Data Deficient Not Sensitive Data Deficient High Data Deficient Very Exposed 71 10% 4 Bedrock MCR PhaAxi Common Moderate Data Deficient High Data Deficient Very Exposed 95 14%

4 Bedrock MCR AntCor Common Not Sensitive Low Low Low Very Exposed - -

5 Sand IGS Sparse Common Low Moderate Moderate Low Very Exposed - - 6 Sand IMS EcorEns Uncommon Low Low Moderate Low Exposed 19 3% 7 Mixed MIR Sac Rare Not Sensitive Not Sensitive Low Very Low Exposed 7 1% 7a Sand IGS Mob Uncommon Low Low Moderate Low Exposed 18 3% 8 Bedrock ELR MytB Common Very Low Low Not Relevant Low Very Exposed 19 10% 8a Bedrock LR CorPar Uncommon Low Low Very Low Data Deficient Very Exposed 18 9% 8b Bedrock MLR Mas Widespread Low Low Data Deficient Low Very Exposed 5 3% 9 Bedrock SLR Pel Uncommon Not Sensitive Moderate Data Deficient Data Deficient Very Exposed 18 9% For inspection purposes only. 9a Bedrock LR CorPar Common Low Consent of copyright Not owner Sensitive required for any Not other Relevant use. Low Very Exposed 18 9%

9b Bedrock ELR Bpat.Sem Widespread Very Low Low Not Sensitive Low Very Exposed 29 15% 9c Bedrock ELR Rkp Widespread Very Low Low Not Sensitive Low Very Exposed 4 2% 9d Bedrock ELR MytB Common Very Low Low Not Relevant Low Very Exposed 19 10% 9e Bedrock ELR Him Common Not Sensitive Low Low Low Very Exposed 21 11% 10 Mixed MCR PhaAxi Common Moderate Data Deficient High Data Deficient Very Exposed 95 14% 10a Mixed SCR NeoPro.CaTw Uncommon Very Low Not Relevant Low Data Deficient Very Exposed 12 2% 11 Mixed EIR LhypFa Not Sensitive Not Relevant Moderate Not Sensitive Exposed 58 8% 11a Mixed IMS EcorEns Uncommon Low Low Moderate Low Exposed 19 3% 12 Bedrock EIR LhypFa Uncommon Not Sensitive Not Relevant Moderate Not Sensitive Very Exposed 58 8%

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Site Substratum Habitat Habitat Code Habitat Rarity Sensitivity to Nutrient Sensitivity to Microbial Wave No. Percent No Complex increased Sensitivity Oxygenation Sensitivity Exposure BioMar Of Suspended Solids levels Records BioMar Sites2 13 Bedrock EIR Ala.Myt Widespread Low Low Data Deficient Very Low Very Exposed 6 1% 13a Bedrock EIR LhypFa Uncommon Not Sensitive Not Relevant Moderate Not Sensitive Very Exposed 58 8% 13b Bedrock EIR FoR.Dic Widespread Low Low Moderate Data Deficient Very Exposed 29 4% 13c Bedrock CR Ant Uncommon Very Low Low Low Low Very Exposed 29 4% 14 Bedrock CR Ant Uncommon Very Low Low Low Low Very Exposed 29 4% 15 Bedrock EIR AlaAnSC Widespread Low Low Data Deficient Very Low Very Exposed 2 0% 15a Bedrock IR CorMetAlc Common Very Low Low Moderate Insufficient Very Exposed 35 5% Information 15b Bedrock ECR CCParCar Data Deficient Not Sensitive Data Deficient High Data Deficient Very Exposed 71 10% 16 Bedrock IR CorMetAlc Common Very Low Low Moderate Insufficient Very Exposed 35 5% Information 16a Bedrock ECR CCParCar Data Deficient Not Sensitive Data Deficient High Data Deficient Very Exposed 71 10% 17 Mixed ECR CCParCar Data Deficient Not Sensitive Data Deficient High Data Deficient Very Exposed 71 36%

DATA FROM SITE SURVEY UNDERTAKEN ON 25TH JUNE 2009 SW1C Bedrock MLR MytB/MytFR Common Very Low Low Not Relevant Low Moderately 19 10% Exposed SW1D Bedrock HLR FR.Him Common Not Sensitive Low Low Low Exposed 21 11% SW1A Bedrock LR Lic.YG Widespread Not Relevant High Not Relevant Data Deficient Exposed 14 7% SW1B Bedrock LR Rkp.Cor Common Not Relevant Very Low Very Low Data Deficient Exposed 18 9% For inspection purposes only. SW2A Bedrock LR Lic.YG Widespread Not RelevantConsent of copyrightHigh owner required for anyLow other use. Low Exposed 14 7%

SW2C Bedrock SLR Pel Uncommon Not Sensitive Moderate Data Deficient Data Deficient Very Exposed 18 9% SW2B Bedrock LR EphEnt Uncommon Not Relevant Not Sensitive Data Deficient Not Relevant Exposed ? ? SW2D Bedrock MLR MytFR Common Very Low Low Not Relevant Low Very Exposed 19 10% SW2E Bedrock ELR Him Common Not Sensitive Low Low Low Very Exposed 21 11% SW4B Sediment LSA AmSco.Eur Common Not Relevant Moderate Moderate Insufficient Exposed 37 19% SW4A Sediment LCS Sh.BarSh Common Not Sensitive Low Low Low Exposed ? ?

Note: SW1 and SW5 at same location. SW3 located within stream.

2 Percentages were separated for Sublittoral and Littoral Sites (700 sites and 200 sites surveyed respectively).

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Keem Beach

, n s s y o . i e y b c m t i n e c u t r a r c r g s c s o r n d e o l i i u c s u i f i l d t n l u e i l t t s i o s o t r l o n a t a l a O n a i l e o c v r a a a m c l n u r o a e r o p R r e e S o e C e t a g o l C c e t o r p s l a r h p y e f p s % F a e n r e a i F e P a l e b m r t t m a u r n M O F o i e o e r a H r o t o

Date Lab no. T D T T p T T C S M D c °C % Saturation m pH units Hazen No/100 ml No/100 ml No/100 ml 08-Sep-08 2803483 14.7 103 >1 no 8.2 <5 <10 <10 2 no no no 01-Sep-08 2803406 16.4 102 >1 no 8.2 10 41 <10 <1 no no no 25-Aug-08 2803316 15.5 99 >1 no 8.2 6 41 <10 6 no no no 18-Aug-08 2803171 15.2 99 >1 no 8.1 <5 231 74 5 no no no 11-Aug-08 2802976 15.3 100 >1 no 8.1 <5 63 <10 2 no no no 05-Aug-08 2802890 15.8 104 >1 no 8.2 <5 52 <10 <1 no no no 28-Jul-08 2802820 17.0 102 >1 no 8.2 <5 84 41 1 no no no 21-Jul-08 2802680 14.0 100 >1 no 8.2 <5 <10 <10 <1 no no no 14-Jul-08 2802557 14.5 98 >1 no 8.2 <5 <10 <10 <1 no no no 07-Jul-08 2802425 14.6 99 >1 no 8.2 <5 31 20 <1 no no no 30-Jun-08 2802298 14.2 96 >1 no 8.1 <5 31 <10 <1 no no no 23-Jun-08 2802172 15.3 101 >1 no 8.1 <5 52 31 <1 no no no 16-Jun-08 2802035 14.1 101 >1 no 8.2 <5 <10 <10 <1 no no no 10-Jun-08 2801968 14.0 101 >1 no 8.1 <5 <10 <10 <1 no no no 03-Jun-08 2801849 14.6 100 >1 no 8.2 <5 <10 <10 <1 no no no 26-May-08 2801758 13.8 100 >1 no 8.1 <5 20 <10 <1 no no no 12-May-08 2801530 12.7 108 >1 no 8.2 14 <10 <10 <1 no no no

For inspection purposes only. Consent of copyright owner required for any other use.

Keem Beach Page 1 of 1

EPA Export 26-07-2013:14:28:00 Achill Island Central Waste Water Discharge Licence Application Regulation 18(3)(b) Response Keel Beach

s y

y b m i n

e c . r n r c r s c s o , c n o l i i o t u f c i s t u s l d i e g i l t t e o s o t r l o n a e l a O a y n l n a l c v a i o n r r u o m c l e u r t a r O r a r o e p d i C e a e o c t g e u i a C a r o r D t s l a r h p e p p s o f s T e e i e e a n l a F P t a l e b m e t t m a u r n S F a i F o t e o Date Lab no. e r R H r o o T % T M p T T C S M D c °C % Saturation m pH units Hazen No/100 ml No/100 ml No/100 ml 08-Sep-08 2803482 14.4 102 >1 no 8.2 7 <10 <10 <1 no no no 01-Sep-08 2803405 16.4 97 >1 no 8.2 9 20 <10 <1 no no no 25-Aug-08 2803315 15.4 99 >1 no 8.1 11 52 <10 <1 no no no 18-Aug-08 2803170 15.3 99 >1 no 8.1 10 228 98 1 no no no 11-Aug-08 2802975 15.5 109 >1 no 8.1 <5 <10 <10 2 no no no 05-Aug-08 2802889 15.6 103 >1 no 8.2 <5 41 20 <1 no no no 28-Jul-08 2802819 17.4 100 >1 no 8.2 <5 <10 <10 <1 no no no 21-Jul-08 2802679 14.2 99 >1 no 8.1 16 <10 <10 <1 no no no 14-Jul-08 2802556 14.6 97 >1 no 8.2 <5 <10 <10 <1 no no no 07-Jul-08 2802424 13.9 99 >1 no 8.1 10 <10 <10 <1 no no no 30-Jun-08 2802297 14.3 94 >1 no 8.1 <5 <10 <10 <1 no no no 23-Jun-08 2802171 15.1 98 >1 no 8.2 6 197 62 1 no no no 16-Jun-08 2802034 12.9 98 >1 no 8.1 <5 <10 <10 <1 no no no 10-Jun-08 2801967 15.5 99 >1 no 8.3 <5 <10 <10 <1 no no no 03-Jun-08 2801848 14.6 101 >1 no 8.3 <5 <10 <10 <1 no no no 26-May-08 2801757 13.6 96 >1 no 8.1 <5 <10 <10 <1 no no no 12-May-08 2801529 13.8 103 >1 no 8.2 <5 98 10 <1 no no no

For inspection purposes only. Consent of copyright owner required for any other use.

Keel Beach Page 1 of 1 EPA Export 26-07-2013:14:28:00 Achill Island Central Waste Water Discharge Licence Application Regulation 18(3)(b) Response Urban Waste Water Treatment (UWWT) Regulations Compliance

NT = C % ° Not Tested ) 0 n n 4 2 e e e

n H g g ) @ a y y t N ) ( h x x n e y t e t N t i e O O ( a m s v t n m a u m i m d d D e i i m t n o u e e e e o i r e y n n c i c r e t e u r v v r l i n i d l l u d o o i m u e i g o a i n m s u p n r l o r o r z u m d p o o n a d c m m e i e h s u s Station Sample Lab a D D o r r r n p m r d a t t e a s r c s s u e a m m r t a O o a O h o o y e i i a i l e Name Code M S A A A A B B B C C C C C C D D D S D ( F L M mg/l Units mg/l mg/l ug/l ug/l ug/l mg/l ug/l ug/l mg/l ug/l uS/cm ug/l ug/l mg/l ug/l % DO DO mg/l ug/l ug/l INFLOW 08032801096 01-Apr-08 NT 12 60 NT INFLOW 0880158453 21-Jan-08 1.571 25 40 71.7 INFLOW 0880173050 30-May-08 5.794 93 94 52 INFLOW 0880175257 16-Jun-08 12.206 39 97 43 INFLOW 0880178208 17-Jul-08 1.71 150 328 3.2 26 2.6 INFLOW 0880181700 21-Aug-08 24.697 49 165 29 INFLOW 0880184532 16-Sep-08 3.851 50 106 54 INFLOW 0880187513 14-Oct-08 5.899 22 70 60 INFLOW 0880190264 11-Nov-08 0.013 5 41 73.3 INFLOW 0880193557 11-Dec-08 12.256 13 39 106 INFLOW 0978207190 24-Mar-09 10.667 76 153 62 INFLOW 0980197326 27-Jan-09 2.544 14 40 64 INFLOW 0980199596 18-Feb-09 10.12 29 78 32 INFLOW 0980211340 27-Apr-09 8.161 33 73 41 INFLOW 0980213916 20-May-09 10.248 46 92 40 OUTFLOW 08032801097 01-Apr-08 <0.03 1.2 <25 NT NT For inspection purposes only. OUTFLOW 0880158454 21-Jan-08 0.049Consent of 17copyright owner required 32for any other use. 66.3 NT OUTFLOW 0880173051 30-May-08 10.709 <2 43 84 NT OUTFLOW 0880175258 16-Jun-08 19.008 <2 17 82 NT OUTFLOW 0880178209 17-Jul-08 0.022 0.029 <0.5 <0.003 37 5 14 <0.5 35 <0.5 725 1 2.3 <0.005 <1 56 5.6 0.45 <0.5 <0.05 OUTFLOW 0880181702 21-Aug-08 23.79 10 64 32 NT OUTFLOW 0880184533 16-Sep-08 5.135 <2 41 52 NT OUTFLOW 0880187512 14-Oct-08 0.573 <2 46 42 NT OUTFLOW 0880190262 11-Nov-08 2.232 <2 25 77.3 NT OUTFLOW 0880193558 11-Dec-08 <0.01 <2 29 104 NT OUTFLOW 0978207191 24-Mar-09 <0.01 9 45 49 NT OUTFLOW 0980197327 27-Jan-09 0.019 <2 21 73 NT OUTFLOW 0980199597 18-Feb-09 0.115 <2 35 63 NT OUTFLOW 0980211341 27-Apr-09 3.305 2 27 50 NT OUTFLOW 0980213917 20-May-09 0.035 6 35 62 6.4

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EPA Export 26-07-2013:14:28:00 Achill Island Central Waste Water Discharge Licence Application Regulation 18(3)(b) Response Urban Waste Water Treatment (UWWT) Regulations Compliance

e e t t

NT = a a d h h n e e Not Tested e p p s s t g ) s s d i a u ) o o o e d r n N r i i D ( N h h ) e e t o t m d n ( s t i x l s n e s e p p d l u n e h s i a y l l e - - i n N O e e o e s p t t e z g p e o o r n h p e l l l n t s u a i n a p d o Station Sample Lab k h h e e p i u a a a e c r r r m t t t e l l s l m l t t t o b l c t t l m t i r r n a i i i i H h e i u u o e o o o i o h r y i Name Code f S N N N O O ( p P S S S S S T T T T N T P T X Z Units ug/l mg/l mg/l mg/l mg/l pH units ug/l ug/l ug/l mg/l mg/l O C ug/l mg/l mg/l mg/l ug/l ug/l ug/l INFLOW 08032801096 01-Apr-08 NT 7.6 21 9.3 10 0.8 0.99 INFLOW 0880158453 21-Jan-08 0.16 7 15 9.2 5.9 1.57 0.351 INFLOW 0880173050 30-May-08 0.583 7.1 88 14.3 6.57 <0.1 4.177 INFLOW 0880175257 16-Jun-08 1.008 7.1 77 14.3 13.3 <0.1 3.598 INFLOW 0880178208 17-Jul-08 2.186 7.1 353 14.9 1.83 <0.1 6.756 INFLOW 0880181700 21-Aug-08 2.829 7.1 100 15.4 30.1 <0.1 3.835 INFLOW 0880184532 16-Sep-08 0.509 7.1 461 14.8 6.89 <0.1 0.743 INFLOW 0880187513 14-Oct-08 0.353 7.2 50 12.8 8.78 <0.1 0.956 INFLOW 0880190264 11-Nov-08 0.139 7.4 102 11.1 5.63 2.54 0.7 INFLOW 0880193557 11-Dec-08 1.685 7.3 31 9.3 18.01 0.26 1.783 INFLOW 0978207190 24-Mar-09 1.059 6.7 318 10 13.02 0.12 2.273 INFLOW 0980197326 27-Jan-09 0.306 7.2 206 8.9 6.4 0.13 0.924 INFLOW 0980199596 18-Feb-09 0.653 6.9 42 10.3 40 <0.1 1.814 INFLOW 0980211340 27-Apr-09 0.701 6.8 53 11.3 14.56 0.2 1.195 INFLOW 0980213916 20-May-09 3.031 7.1 237 12.9 16.23 0.46 5.393 OUTFLOW 08032801097 01-Apr-08 0.339 7.4 <8 9 5.5 4.2 0.35 OUTFLOW 0880158454 21-Jan-08 0.201 7 7 9.2 5 2.72 0.266 OUTFLOW 0880173051 30-May-08 1.299 For inspection 7.3 purposes only. <2 17.1 15.9 4.01 1.403 Consent of copyright owner required for any other use. OUTFLOW 0880175258 16-Jun-08 1.046 7.5 2 15.6 21.4 0.2 1.141 OUTFLOW 0880178209 17-Jul-08 2 28.023 0.097 0.044 0.047 7.3 <0.027 <0.5 0.013 71.59 3 16.6 <1 29.3 28.12 0.11 <0.02 <1 <5 OUTFLOW 0880181702 21-Aug-08 2.014 7.5 16 15 26.87 0.12 2.289 OUTFLOW 0880184533 16-Sep-08 0.018 7.3 2 15.8 12.78 4.21 0.093 OUTFLOW 0880187512 14-Oct-08 0.846 7.2 12 13 25.23 18.36 0.961 OUTFLOW 0880190262 11-Nov-08 0.219 7.5 7 10.3 4.12 0.34 0.546 OUTFLOW 0880193558 11-Dec-08 0.871 7.4 9 9.3 8.12 4.87 1.515 OUTFLOW 0978207191 24-Mar-09 0.513 7.1 <2 10 16.27 12.65 0.639 OUTFLOW 0980197327 27-Jan-09 0.169 7.4 3 10 5.2 3.12 0.278 OUTFLOW 0980199597 18-Feb-09 2.446 7.2 2 11.3 60.3 57.66 2.765 OUTFLOW 0980211341 27-Apr-09 0.346 6.9 7 12.1 7.56 2.56 0.619 OUTFLOW 0980213917 20-May-09 0.264 7.3 <2 11 16.2 <0.1 0.381

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