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October 2010

Appropriate Assessment Screening WWTP

Submitted to: Paul Hickey Water Services Section County Council Aras Chill Dara Devoy Park Co.Kildare

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Report Number. 10507190132

Distribution: REPORT Kildare County Council Golder Associates Ireland

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Table of Contents

1.0 INTRODUCTION ...... 1

1.1 Terms of Reference...... 1

1.2 Methods...... 1 1.2.1 Stage 1: Screening ...... 1

1.2.2 Stage 2: Appropriate Assessment ...... 3 1.2.3 Stage 3: Assessment of alternative solutions ...... 3

1.2.4 Stage 4: Assessment where adverse impacts remain ...... 3

1.3 Brief description of project ...... 3

2.0 WATER QUALITY ...... 4 2.1.1 Assimilative Capacity ...... 4

2.1.1.1 Introduction ...... 4

2.1.1.2 Methods ...... 4

3.0 STAGE 1: SCREENING...... 7

4.0 DATA COLLECTION ...... 7

5.0 CONSULTATIONS ...... 8

TABLES For inspection purposes only. Consent of copyright owner required for any other use. Table 1: Assimilative Capacity Calculations ...... 5 Table 2: Guidance emission limit values of effluent discharge from Industrial, Commercial Developments and Communal Housing Developments to receiving waters (Wexford County Council)...... 6 Table 3: EPA Surface Water Quality data ...... 6 Table 4: Consultations ...... 8 Table 5: SERBD Response ...... 8

FIGURES Figure 1 Screening Flow Chart (DOE, 2008) ...... 2 Figure 2: EPA Water Quality Information ...... 6

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1.0 INTRODUCTION 1.1 Terms of Reference This report is an Appropriate Assessment Screening of the waste water discharges from Calverstown WWTP, Co. Kildare, in accordance with the requirements of the EU Habitats Directive (Directive 92/43/EEC). Articles 6(3) and 6(4) of this Directive state the following: 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 thereon, 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. 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 a social or economic nature, the Member State shall take all compensatory measures necessary to ensure that the overall coherence of Natura 2000 is protected. It shall inform the Commission of the compensatory measures adopted.

Where the site concerned hosts a priority natural habitat type and/or priority species, the only considerations which may be raised are those relating to human health or public safety, to beneficial consequences of primary importance for the environment or, further to an opinion from the Commission, to other imperative reasons of overriding public interest. 1.2 Methods This report has been prepared with reference to the following documents:  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 (European Communities, 2002) For inspection purposes only. Consent of copyright owner required for any other use.

 Managing Natura 2000 sites: the provisions of Article of the „Habitats Directive‟ 92/43/EC  Circular L8/08 „Water Services Investment and Rural Water Programmes – Protection of Natural Heritage and National Monuments‟ Department of Environment, Heritage and Local Government, 2008.  Notes on Appropriate Assessment for the purposes of the Waste Water Discharge (Authorisation) Regulations, 2007 (S.I. 684 of 2007) Environmental Protection Agency (www.epa.ie)

Appropriate Assessment is carried out in stages, as recommended by the Guidance Documents. There are four stages as follows: 1.2.1 Stage 1: Screening This initial stage aims to identify the likely impacts of the project on a Natura 2000 site, either alone or in combination with other projects or plans. The impacts are examined to establish whether these impacts are likely to be significant. Assessment of the significance of effects is carried out in consultation with the relevant nature agencies. The following flow diagram from Circular L8/08 referred to above and shown in Fig 1 below will be completed as part of the screening process.

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Figure 1 Screening Flow Chart (DOE, 2008)

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The remaining 3 stages of the AA process do not form part of this project but are outlined briefly below. 1.2.2 Stage 2: Appropriate Assessment The aim of this stage is to identify the conservation objectives of the site and to assess whether or not the project, either alone or in combination with other projects or plans will result in adverse effects on the integrity of the site, as defined by the conservation objectives and status of the site. Stage 2 is carried out in consultation with the relevant nature agencies. Where it cannot be demonstrated that there will be no adverse effects on the site, it is necessary to devise mitigation measures to avoid, where possible, any adverse effects. 1.2.3 Stage 3: Assessment of alternative solutions This stage examines alternative ways of implementing the project that, where possible, avoid any adverse impacts on the integrity of the Natura 2000 site. If alternative solutions have been identified that will either avoid any adverse impacts or result in less severe impacts on the site, it will be necessary to assess their potential impact by recommencing the assessment at Stage One or Stage Two as appropriate. However, if it can be reasonably and objectively concluded that there is an absence of alternatives, it will be necessary to proceed to Stage Four of this assessment methodology. 1.2.4 Stage 4: Assessment where adverse impacts remain For sites that host priority habitats and species, it is necessary to consider whether or not there are human health or safety considerations or environmental benefits flowing from the project. If such considerations do exist, then it will be necessary to carry out the Stage Four assessments of compensatory measures. If no such considerations exist, then establish whether there are other imperative reasons of overriding public interest (IROPI) before carrying out the Stage Four assessments. Where IROPI exist, an assessment to consider whether compensatory measures will or will not effectively offset the damage to the site will be necessary before the project or plan can proceed.

1.3 Brief description of project

Calverstown WWTW is situated in Calverstown, For inspection a small purposes villageonly. approximately 7 km west of in Consent of copyright owner required for any other use. . Calverstown WWTW was constructed in 2001 to serve the Calverstown agglomeration. It was designed to have a capacity of 300 PE (Population Equivalent). Calverstown WWTW receives domestic sewage only. The Calverstown WWTW is a Bord Na Móna Aeration System. It consists of the following: 1. Inlet foul pumping station

2. Primary settlement tanks x 4 3. Aeration tanks x 2 4. Humas Tank

5. Sludge return to the primary settlement tanks 6. Sampler on outfall 7. Outfall

A planning search by Kildare County Council has determined that there are 19 houses to be connected to the Calverstown WWTP which equates to an additional 57PE. This would result in the Calverstown WWTP operating at close to its design capacity of 300PE.

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There is an overflow from the wet well of Foul Pumping Station 2 at Calverstown WWTW to the adjacent stream which is activated at times of high flows where the capacity of the foul pumping station is exceeded or in the event of pump breakdown or failure. There is no information available in relation to the frequency and duration of emergency overflows to the receiving waters. This overflow does not comply with the DoEHLG „Procedures and Criteria in Relation to Storm Water Overflows‟, 1995. There are no proposals at present in relation to decommissioning this overflow.

A developer has been conditioned through planning to construct a new 600PE WWTW adjacent to the existing WWTW which will replace the existing Calverstown WWTW (Planning Ref. 08-1193 – Judge Construction). This planning permission was granted by Kildare County Council on 11 March 2009. A recent planning application has been received by Kildare County Council (Planning Ref. 00/754 – Paddy White) which proposes a 1,000PE WWTW along with a new outfall to larger receiving waters, the Finnery River. This planning application is still under consideration. A request for further information was recently made by Kildare County Council. Kildare County Council has recently prepared a Needs Assessment (Oct 2009) and this list of priority Water Services Capital projects has been submitted to the Water Services Section of the Department of the Environment Heritage and Local Government (DEHLG) for inclusion in the National Water Services Investment Programme 2010 – 2012. Calverstown has been included in the list of projects for which funding is being sought, under the heading “South Kildare Bundled Sewerage Scheme”. The project description is taken from Kildare County Council documents.

2.0 WATER QUALITY The assimilative capacity of the receiving waters is calculated for certain chemical parameters in order to identify the potential effects that the discharge from Calverstown WWTP has on the water quality of the Finnery. The information is provided by Kildare County Council. The results of the biological assessment carried out in 2007 indicate that the effluent from the WWTP at Calverstown is having a significant negative impact on the water quality of the stream immediately downstream of the effluent discharge point (Appendix A). For inspection purposes only. Consent of copyright owner required for any other use. 2.1.1 Assimilative Capacity 2.1.1.1 Introduction The Waste Assimilative Capacity (WAC) is the capacity of the receiving waters to accept discharge of final effluent. The capacity for waste assimilation provides the link between existing water quality standards and effluent discharge limits and thereby determines the level of treatment required before a discharge can be allowed into the receiving waters. The assimilative capacity of receiving waters is calculated to determine if the stream or river can take the waste water discharge and still comply with the relevant legislation and water quality objectives. The most recent legislation in relation to surface waters is the Surface Water Regulations, 2009. The environmental quality standards specified for surface waters in the Surface Water Regulations, 2009. 2.1.1.2 Methods Assimilative capacity calculations are based on mass balance, which looks at the natural self-purification capacity of a stream/river to assimilative a waste discharge. Based on the calculations, the total amount of waste water (and quality) which can be discharged into receiving waters without deteriorating the existing/future water quality can be determined.

-1 The Waste Assimilative Capacity (WAC) = (Cmax-Cback) x F95x86.4 kg BOD day

Where Cmax =Maximum concentration (generally given as 3 mg/l BOD)

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Cback = Background concentration F95 = 95th percentile flow (m3/s)

The assimilative capacity calculation can be developed to determine the concentration of a pollutant downstream of the discharge, as follows:

Conc. of pollutant downstream = F1(C upstream) +F2(C discharge) F1 + F2

Where F1 =River Flow upstream (m3/d) Cupstream=Concentration of pollutant upstream (mg/l) F2 =Discharge flow (m3/d)

Cdischarge=Concentration of pollutant in discharge (mg/l) (Gray, N. 2005) These calculations are used as part of this assessment.

Therefore, the parameters required for this assessment include the flow rate of the receiving waters, the proposed discharge from the wastewater treatment plant into the receiving waters, the proposed discharge standards and the current water quality parameters from upstream of the proposed point of discharge. The parameters relevant to this report are displayed in Table 1. Table 1: Assimilative Capacity Calculations BOD SS Ammonia Orthophosphate Parameters Formg inspection O2/l purposesmg/l only. mg/l mg/l Consent of copyright owner required for any other use. Discharge Concentration (C dis)1 80 83 42.2 6.051

Background Concentration (C up)2 2 3 0.23 0.002

Flows m3 m3 m3 m3

Discharge Flow (F2) 99.2 m3 99.2 m3 99.2 m3 99.2 m3

Stream Flow (F1) -estimated Unknown Unknown Unknown Unknown

New Concentration Unknown Unknown Unknown Unknown

The assimilative capacity cannot be calculated as there are gaps in the information for the receiving waters. However if we compare the parameters of the current effluent discharge with the limit values outlined in Table 2 below, it can be shown that the current effluent discharge exceeds all the guidance limits for Suspended solids, BOD, Ammonia and Orthophosphate parameters.

1 Max Daily Average from 24hr composite sampling 2 Grab sample

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Table 2: Guidance emission limit values of effluent discharge from Industrial, Commercial Developments and Communal Housing Developments to receiving waters (Wexford County Council). Calverstown Effluent Parameter Emission Limit Value Discharge3

BOD 10 mg/l 80

Suspended solids 10 mg/l 83

Orthophosphate 1.5 mg/l P (4.6 mg/l PO4) 6.051 Total Ammonia ≈ 4 mg/l as N 42.2 More stringent values to be applied at pH > 7.5 & Temp>150C

The status of Finnery is currently rated as Moderate under the Water Framework Directive reports (website www.wfdireland.ie) with the nearest EPA monitoring location described as Moderate downstream of Calverstown on the Tully Stream as shown in Figure 2 and Table 3. Table 3: EPA Surface Water Quality data River EPA Code Location Water Quality Status Description Tully Stream 14T020600 Cloney Bridge 3-4 Moderate Downstream

Figure 2: EPA Water Quality Information

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3 Max Daily Average from 24hr composite sampling

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3.0 STAGE 1: SCREENING This section follows the screening flow chart presented in Figure 1. Q1. Is the development in a nature conservation site? No Q2a. Is the development in the surface water catchment of a nature conservation site (or part of such a site)? No, the SAC is at least 10 km from the discharge. Q.3. If yes, are the qualifying habitats and species of the site water dependent? N/A Q4. Is the development in the surface or groundwater catchment of other water dependent Annex II species, other rare or protected species or salmonid waters? Yes, the development is located in the surface water catchment of Finnery, a tributary of the River Barrow. This area is noted for Atlantic Salmon, Brown Trout and other water dependant Annex II species (SERBD).

NPWS have provided information on other water dependent Annex II and protected species in the area, however they have stated that the information is not complete. It is likely that once the water quality standards are achieved for Surface Waters Regulations, then compliance will ensure the water quality requirements for all water dependent Annex II and rare or protected will be met. Q.7 Is Further Action Required The discharge is not located within or near a Natura 2000 site. However, the receiving water is noted for Atlantic Salmon, Brown Trout and Annex II species. The status of the receiving waters is currently assessed as Moderate. The results of the biological assessment carried out in 2007 indicate that the effluent from the WWTP at Calverstown is having a significant negative impact on the water quality of the stream immediately downstream of the effluent discharge point (Appendix A).

As the Calverstown WWTP is within surface Forwater inspection systems purposes notedonly. for Atlantic Salmon, Brown Trout and other Consent of copyright owner required for any other use. water dependant Annex II species (SERBD), further action is required and an Assessment of Impacts along with mitigation measures should be carried out.

4.0 DATA COLLECTION The assessment was carried out by:  Senior Ecologist – Anne Murray, Golder Associates Ireland Sources of Data:  Existing information from NPWS  EPA Waste Water Discharge Application files  WFD sub-basin plan Level of assessment completed:  Desktop study and Screening report

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5.0 CONSULTATIONS Table 4: Consultations Name Date Organisation Contact details Response Karen Creed 15/06/10 EPA Phone calls and Response on 01/07/10. EPA email suggested the use of Q values for 18/06/10 areas where data is lacking in relation to assimilative capacity.

D McInerney 16/06/10 SRFB Email via Brian Response See Table 4 Beckett 07/07/10 Phone call

Ciara Flynn 16/06/10 NPWS Phone call Referred to Aine O‟ Conor District Conservation Officer, Kildare

Aine O‟Conor 17/06/10 NPWS HQ Phone calls NPWS suggested that the Q values Freshwater for each receiving waters would be 21/06/10 Biologist most useful in determining significant impacts where information for Assimilative capacity calculations are not available

Naomi 18/10/10 NPWS HQ Phone calls and Data files received 23/06/10 Kingston email. Data coordinator Data request form for protected species was For inspection purposescompleted only. and Consent of copyright owner required for any other use. emailed

Table 5: SERBD Response Agglomeration Receiving water River / *Atlantic *Brown **Other identified stream salmon trout Annex II sp. Yes Greese Yes Yes Yes

Calverstown No Finnery Yes Yes Yes 01 Yes Tully stream Yes* Yes* Kildangan 02 Yes Tully stream Yes* Yes* Kilkea Yes Greese Yes Yes Yes No Trib of No Yes ? clogorrow bog stream

Nurney Yes Tully Yes*** Yes*** Yes***

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Milltown (Fenview) Yes Pollardstown Yes Yes Yes fen stream Castleroe West No Greese Yes Yes Yes Kilberry No Barrow Yes Yes Yes

Ticknevin Yes Cushaling Yes*** Yes*** Yes*** No Botkoge Yes Yes Yes

* These columns denote possibility of Atlantic salmon and Brown trout in the relevant surface water systems at the listed locations. A number of these locations may not currently support these species due to poor water quality but would likely support such species if water quality improved e.g. Tully at Nurney ** This column denotes the likelihood of other Annex II species (freshwater crayfish, lamprey species) that we would be anecdotally aware of in the systems

*** A number of these locations may not currently support these species due to poor water quality but would likely support such species if water quality improved e.g. Tully at Nurney, Cushaling at Ticknevin NB The exact location of the outfalls from the treatment systems is not necessarily known and therefore the nearest stream/river is assumed to receive the discharges

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Report Signature Page

GOLDER ASSOCIATES IRELAND LIMITED

Anne Murray Conor Wall Senior Ecologist Principal

AM/CW/am

Registered in Ireland Registration No. 297875 Town Centre House, Dublin Road, Naas, Co. Kildare, Ireland Directors: M. Gilligan, M. L. J. Maher, A. Harris (British) VAT No.: 8297875W

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APPENDIX A Calverstown Report

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October 2010 Report No. 10507190132

EPA Export 27-07-2013:23:03:41 BIOLOGICAL MONITORING OF WATER QUALITY IN THE VICINITY OF A WASTE WATER TREATMENT PLANT AT CALVERSTOWN, COUNTY KILDARE

April 2007

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Conservation Services, Tullaha, Glenflesk, Killarney, Co. Kerry Tel/Fax 064 30130 e-mail [email protected]

EPA Export 27-07-2013:23:03:41 CONTENTS

1 INTRODUCTION ...... 3

2 METHODOLOGY...... 4 2.1 SITE LOCATIONS ...... 4 2.2 HABITAT ASSESSMENT ...... 4 2.3 INVERTEBRATE SAMPLING AND WATER QUALITY ASSESSMENT ...... 5

3 RESULTS ...... 7 3.1 SITE 1...... 7 3.2 SITE 2...... 8

4 CONCLUSIONS...... 9

5 REFERENCES ...... 10

APPENDIX 1 HABITAT AT SAMPLING SITES

APPENDIX 2 PHOTOGRAPHS

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EPA Export 27-07-2013:23:03:41 1 INTRODUCTION

As part of the monitoring of water quality in the vicinity of a WWTP at Calverstown, County Kildare, Conservation Services, Ecological & Environmental Consultants have been commissioned by Kildare County Council to carry out biological sampling and water quality assessment in accordance with EPA Q-rating methodology at two locations on the stream to which the WWTP effluent is discharged.

Sampling was carried out on 3rd April 2007.

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EPA Export 27-07-2013:23:03:41 2 METHODOLOGY

2.1 SITE LOCATIONS

Biological sampling and water quality assessment was carried out at the following sites. Grid references were recorded at all sites using a GPS.

SITE Location Grid Reference

1 Directly upstream of effluent N8015 0435 discharge

2 c. 20m downstream of effluent N8013 0433 discharge

2.2 HABITAT ASSESSMENT

Habitat assessment was carried out at each of the sites selected for invertebrate/water quality assessment. These sites were assessed in terms of:

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 Substrate type, listing substrate fractions in order of dominance, i.e. large rocks, cobble, gravel, sand, mud etc.

 Flow type, listing percentage of riffle, glide and pool in the sampling area

 Instream vegetation, listing plant species occurring and their percentage coverage of the stream bottom at the sampling site

 Dominant bankside vegetation, listing the main species overhanging the stream

4

EPA Export 27-07-2013:23:03:41  Estimated summer cover by bankside vegetation, giving percentage shade of the sampling site

 Rating of the site as habitat for trout adult, nursery and spawning on a scale of Poor/Fair/Good/Very Good/Excellent. This rating assesses the physical suitability of the habitat; the presence/absence/density of salmonids at the site will also depend on present and historical water quality and accessibility of the site to fish.

2.3 INVERTEBRATE SAMPLING AND WATER QUALITY ASSESSMENT

A kick and stone wash invertebrate sample was taken at each site (ISO 7828:1985) using standard methodology employed by EPA. Each sample was retained in a large plastic bag at the sampling site. Sample processing and preservation was carried out under laboratory conditions within 24 hours of sampling. Mud was removed from each sample by sieving under running water through a 500μ sieve. Sieved samples were then live sorted for 30 minutes in a white plastic sorting tray under a bench lamp (ISO 5667-3:1994) and if necessary using a magnifying For inspection lens. purposes Macroinvertebrates only. were stored in 70% Consent of copyright owner required for any other use. alcohol. Preserved invertebrates were identified to the level required for the EPA Q-rating method (Clabby et al, 2001) using high-power and low-power binocular microscopes when necessary. The preserved samples were archived for future examination or verification. Based on the relative abundance of indicator species, a biotic index (Q-rating) was determined for each site in accordance with the biological assessment procedure used by the Environmental Protection Agency (Statutory Instruments No. 258 of 1998) and more detailed unpublished methodology (McGarrigle, Clabby and Lucey pers. comm.)

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EPA Export 27-07-2013:23:03:42 Biotic Index Quality Status Q5 Q4-5 Unpolluted Waters Q4 Q3-4 Slightly Polluted Waters Q3 Moderately Polluted Waters Q2-3 Q2 Q1-2 Seriously Polluted Waters Q1

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EPA Export 27-07-2013:23:03:42 3 RESULTS

3.1 SITE 1

Habitat at Site 1 is tabulated in Appendix 1 and the site is shown on Photograph 1 in Appendix 2. The macroinvertebrate fauna recorded at the site merits a Q-rating of Q3-4 indicating slightly polluted conditions.

INDICATOR GROUP TAXON Number Group A - Very Rhithrogena sp. 5 Pollution Sensitive

Group B - Moderately Sericostomatidae 6 Pollution Sensitive

Group C - Moderately Gammarus duebeni 70 Pollution Tolerant Limnephilidae 16 Tipulidae 2 Glossosomatidae 57 Chironomidae (ex. Chironomus) 11 Baetis rhodani 8

Group D - Very Asellus aquaticus 3 Pollution Tolerant

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Not assigned to any Lumbricidae 13 indicator group Ceratopogonidae 1

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EPA Export 27-07-2013:23:03:42 3.2 SITE 2

Habitat at Site 2 is tabulated in Appendix 1. The site is shown in Photograph 3 in Appendix 2. The effluent discharge point is shown on Photograph 2. The macroinvertebrate fauna recorded at the site, combined with the 60% cover of sewage ‘fungus’ observed merits a Q-rating of Q2 indicating seriously polluted conditions.

INDICATOR GROUP TAXON Number Group A - Very None Recorded Pollution Sensitive

Group B - Moderately None Recorded Pollution Sensitive

Group C - Moderately Gammarus duebeni 14 Pollution Tolerant Limnephilidae 1 Chironomidae 214

Group D - Very None Recorded Pollution Tolerant

Group E - Most Chironomus sp. 5 Pollution Tolerant

Not assigned to any Lumbricidae For inspection purposes only. 5 Consent of copyright owner required for any other use. indicator group

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EPA Export 27-07-2013:23:03:42 4 CONCLUSIONS

The results of this biological assessment indicate that the effluent from the WWTP at Calverstown is having a significant negative impact on the water quality of the stream immediately downstream of the effluent discharge point. The stream deteriorates from a Q3-4 (slightly polluted) to a Q2 (seriously polluted) between the upstream and downstream sites.

Signed on behalf of Conservation Services

______Helena Twomey BA(Mod.) PhD

Date

______

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EPA Export 27-07-2013:23:03:42 5 REFERENCES

McGarrigle, M. et al (2002) Water Quality in Ireland 1998-2000. EPA.

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EPA Export 27-07-2013:23:03:42 APPENDIX 1

HABITAT ASSESSMENT AT SAMPLING SITES

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EPA Export 27-07-2013:23:03:42 SITE 1

Site Location Upstream of effluent

Grid Ref. N8015 0435

Photograph Number 1

Channel Width (m) 4

Depth (cm) 12

Substrate (in order of Cobble, Gravel, Sand, Mud dominance)

Flow Type Riffle 80% Glide 20%

Instream Vegetation Rorippa nasturtium-aquaticum 10%

Dominant Bankside Hawthorn Vegetation

Summer Shade of Stream 20% by Bankside Vegetation

Trout Adult Habitat Fair

Trout Nursery Habitat ForGood inspection purposes only. Consent of copyright owner required for any other use.

Trout Spawning Habitat Fair

EPA Export 27-07-2013:23:03:42 SITE 2

Site Location Downstream of effluent

Grid Ref. N8013 0433

Photograph Number 3

Channel Width (m) 3

Depth (cm) 10

Substrate (in order of Gravel, Cobble dominance)

Flow Type Riffle 70% Glide 30%

Instream Vegetation Sewage ‘fungus’ 60%

Dominant Bankside Hawthorn, Elder Vegetation

Summer Shade of Stream 50% by Bankside Vegetation

Trout Adult Habitat Poor - Fair

Trout Nursery Habitat Good

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EPA Export 27-07-2013:23:03:42 APPENDIX 2

PHOTOGRAPHS

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Caption Text

Golder For inspection Associates purposes only. Ireland Consent of copyright owner required for any other use. Town Centre House Dublin Road Naas Co. Kildare Ireland T: +353 45 87 4411

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