Aquatic Assessment of the Derry and Slaney Rivers

For inspection purposes only. Prepared byConsent Triturus of copyright Environmental owner required for any other Ltd. use. for AWN

on behalf of Duffy Meats T/A Kerry Foods

25th September 2019

______

Please cite as: Triturus Environmental Ltd. (2019) Biological Water Quality Assessment of the Derry & Slaney Rivers. Unpublished report prepared for Duffy Meats trading as Kerry Foods.

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Contents

Introduction ...... 3

Methodology ...... 6

Site Descriptions ...... 10

Results ...... 21

Discussion & Conclusions ...... 32

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

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1. Introduction

1.1 Project background

Triturus Environmental Ltd. were contracted by AWN consulting on behalf of Duffy Meats (T/A Kerry Foods) to undertake a water quality and aquatic assessment of the Derry and Slaney Rivers. Duffy Meats Ltd. is located approximately 0.5 km south of Shillelagh Village in Co. Wicklow.

1.2 Licensing Requirements

The Kerry Foods plant is licensed for ‘treatments or processes for the purposes of the production of food products from animal raw materials (other than milk) with a finished product production capacity greater than 75 tonnes per day’ under license no. PO804-02. The plants emissions to the Derry River are via treated surface water effluent from its biological treatment plant.

The current water quality and aquatic assessment was required in light of Kerry Foods industrial emissions licenses (IED) or Integrated Pollution Prevention & Control (IPPC) License. The Aquatic Assessment & Q Sampling was compiled as a requirement under the IED licence, as follows: Schedule C.6 ‘Receiving Water Monitoring’. Under such requirements the license specifically requests that annual Q sampling be undertaken as agreed by the Environmental Protection Agency.

1.3 Site description and fisheries asset

The Slaney River rises at Lugnaquilla Mountain and flows 117km to Wexford Harbour, where it enters the Irish Sea. It flows through the towns of Baltinglass, Rathvilly, Tullow, Bunclody, Enniscorthy before discharging into Wexford Harbour at Wexford town. The river is situated in the Slaney catchment (Hydrometric Area 12) and has a catchment area of 1750km2. The Slaney is an important Atlantic salmon river, ranked 7th nationally in terms of the total fluvial habitat accessible to the species (4.38% of national area; McGinnity, 2003). The ForRiver inspection Slaney purposes is aonly. designated Salmonid Water under the first Consent of copyright owner required for any other use. Schedule of the European Communities (Quality of Salmonid Waters) Regulations, 1988 (SI 293 of 1988). The River Slaney is primarily a spring salmon fishery (March – May), the Slaney is regarded as one of the top rivers in Ireland for early season fishing, although in 2018 the river was only open on a catch and release basis due to conservation concerns. This management action has been enforced on numerous occasions in recent times and the general consensus is that the river has never fully recovered from an outbreak of ulcerative dermal necrosis (UDN) disease in the 1960s (Johnston, 2002). The Slaney is also augmented by a small number of grilse and a fair run of sea trout in late June /early July period (Cronin et al., 2013) although the proportion of multi-sea winter (MSW) salmon to grilse is much higher than most other Irish rivers (TEGOS, 2018). The upper Slaney and tributary headwaters are very important for salmonid spawning in the catchment (NPWS, 2011; Macklin & Brazier, 2018).

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The following aquatic species and habitats are listed as conservation objective species for the Slaney River Valley SAC;

• [1029] Freshwater pearl mussel (Margaratifera margaritifera) • [1095] Sea lamprey (Petromyzon marinus) • [1096] Brook lamprey (Lampetra planeri) • [1099] River lamprey (Lampetra fluviatilis) • [1103] Twaite shad (Alosa fallax) • [1106] Atlantic salmon (Salmo salar) (only in fresh water) • [1355] Otter (Lutra lutra) • [1365] Harbour seal (Phoca vitulina) • [3260] Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho Batrachion vegetation (‘floating river vegetation’)

The Derry River tributary of the Slaney River which receives discharge from the Kerry Foods Plant is also included in the Slaney River Valley SAC. The Derry River flows from its source north of Tinahely for 33.8km to it’s confluence with the River Slaney at Killdavin and has a catchment area of 246km2.

1.4 Existing Biological Water Quality (Slaney & Derry Rivers)

According to the EPA there are two municipal wastewater treatment plants discharging to the Derry River upstream of the Kerry Foods outfall at Tinahely and Shillelagh. The closest upstream is the Shillelagh Wastewater Treatment Plant (Emission ID TPEFF3400A0542SW001). This plant provides treatment to cater for a PE of 800 (Panther Ltd., 2018). The outfall for this WWTP is located 200 metres upstream of the Kerry Foods effluent discharge outfall and is situated on the west bank of the Derry For inspection purposes only. River approximately 100m downstreamConsent ofof copyright Shillelagh owner requiredBridge for. any other use.

The recent European Union Environmental Objectives (Surface Waters) (Amendment) Regulations (S.I. No. 77, 2019) provide for the classification of surface water bodies by the EPA for the purposes of the Water Framework Directive (2000/60/EC). These very recent regulations amend the European Communities Environmental Objectives (Surface Waters) Regulations 2009 ( S.I. No 272 of 2009) by substituting tables 8 and 9 under schedule 5. The Q sampling EQR targets for the ‘High’ and ‘Good’ boundaries remain the same at 0.85 and 0.75 respectively. As with the previous surface water regulations all rivers in “high” or “good” status (as prescribed under the Water Framework Directive 2000/60/EC) should be maintained at their current level, and those surface waters which have been classified as less than “good” status should be improved to at least good status.

The most recent biological water quality collected by the EPA during 20161 at Shillelagh Bridge (RS12D020500)2 has specified that water quality is currently Q3-4 (i.e. moderate status) slightly polluted water. The EPA historically collected water quality downstream of Shilleleagh Bridge in the

1 Data accessed from the EPA web mapper on the 10th September 2019; gis.epa.ie/EPAMAPS/ 2 EPA station RS12D020500 at Shillelagh Bridge is at the same location as survey site 3 of this report

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upstream and downstream vicinity of the outfall but this data is more than 10 years old and therefore is not of value to the current assessment. The next nearest downstream station is at Balisland Bridge (RS12D020700)3. The most recent Q rating collected in 2016 was recorded as Q3-4 (i.e. moderate status) slightly polluted water as with Shillelagh Bridge upstream.

The nearest EPA site with data less than 10 years old downstream of the River Derry confluence with the River Slaney was recorded circa. 8km downstream at Slaney Bridge Bunclody (RS12S021800). The biological water quality was recorded as Q4 (good status, unpolluted water quality) at the site during 2016. The nearest upstream biological water quality was recorded at Kilcarry Bridge (RS12S021600)4, circa. 3.5km upstream of the Derry River confluence. A Q rating of Q3-4 (i.e. moderate status) slightly polluted water was recorded by the EPA at this location during 2016.

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

3 EPA station RS12D020700 at Balisland Bridge is at the same location as survey site 9 of this report 4 EPA station RS12S021600 at Kilcarry Bridge is at the same location as survey site 10 of this report

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2. Methodology

2.1 Description of Monitoring Locations

The annual environmental reporting for biological water quality (Q sampling) has been collected at eleven sampling locations, nine situated on the Derry River and two situated upstream and downstream of its confluence with the River Slaney. These are summarised on Table 2.1 and Figure 2.1 below and were also the locations used during the current 2019 reporting.

Table 2.1 Location of Q sampling sampling sites on the Rivers Derry and Slaney (June 2019)

Easting Northing Site no. Location (Irish Grid) (Irish Grid) 1 Derry River (Greenhall Bridge) 302132 170693

2 Derry River (Deegins Bridge) 301053 168969 Derry River (Shillelagh Bridge, 50m u/s WWTP outfall 3 299101 168011 (not Kerry Foods) 4 Derry River (25m d/s Kerry Foods outfall) 299072 167640

5 Derry River (200m d/s Kerry Foods outfall) 299027 167408 Derry River (600m d/s Kerry Foods outfall) 6 298850 167116 Derry River (1km d/s Kerry Foods outfall) 7 298843 166766

8 Derry River (2.5km d/s Kerry Foods outfall) 298730 165651

9 Derry River (Balisland Bridge) For inspection purposes only. 297795 164487 Consent of copyright owner required for any other use.

10 Slaney River (Kilcarry Bridge) 289263 162465

11 Slaney River (New Bridge) 289902 159661

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Figure 2.1 Map of sampling areas on the Slaney & Derry Rivers relative to the Kerry Foods outfall location

2.2 EPA Q Sampling

The aquatic Q-sampling of the Derry and Slaney River was undertaken following the standard EPA methodology. Macro-invertebrate samples were converted to Q-ratings as per Toner et al. (2005). All riverine samples were taken with a standard For inspection kick sampling purposes only. hand net (250mm width, 500µm mesh size) Consent of copyright owner required for any other use. from areas of riffle/glide utilising a two-minute sample. Large cobble was also washed at each site where present and samples were elutriated and fixed in 70% ethanol for subsequent laboratory identification. Any rare invertebrate species were identified from the NPWS Red List publications for beetles, stoneflies, mayflies and other relevant taxa. Table 2.1 below shows the standard reference categories for Q sampling.

Table 2.1 Standard reference categories for EPA Q Ratings (Q1 to Q5)

Q Value WFD Status Pollution Status Condition

Q5 or Q4-5 High Status Unpolluted Satisfactory

Q4 Good Status Unpolluted Satisfactory

Q3-4 Moderate Status Slightly polluted Unsatisfactory

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Q Value WFD Status Pollution Status Condition

Q3 or Q2-3 or Q2 Poor Moderately polluted Unsatisfactory

Q1-2 or Q1 Bad Seriously polluted Unsatisfactory

The Ecological Quality Ratio (EQR) allows for the conversion of a Q rating class to a numerical value and intercalibration with EQR’s across Europe that utilise different biological water quality metrics (EPA, 2006). All can then compare with targets under the Water Framework Directive (2000/60/EC). For example, the rating can be compared to standards specified in EU legislations i.e. the European Communities Environmental Objectives (Surface Water) Regulations (S.I. No. 272 of 2009) as amended by the S.I. No. 77/2019 - European Union Environmental Objectives (Surface Waters) (Amendment) Regulations 2019. An EQR Ratio is expressed by a numerical value between 0 and 1 in the case of Q sampling by dividing the recorded Q rating by the maximum reference value (i.e. Q5 or 1.0 when converted to a numerical value). In the case of the Surface Water Regulations 2019, minimum targets are specified as 0.75 for Good Status (equivalent Q4) and 0.85 for High status (equivalent Q 4-5).

Table 2.2 Ecological Quality Ratio (EQR) at respective EPA Q ratings including intermediate classes in Ireland

Biotic Index EQR Surface Water Regs 2019 EPA Quality Status WFD Status EQR

Q5 1.0 0.85 Unpolluted High

Q4-5 0.9 0.85 Unpolluted High

Q4 0.8 0.75 For inspection purposes only.Unpolluted Good Consent of copyright owner required for any other use.

Q3-4 0.7 Below Target Q4 or EQR Slightly Polluted Moderate of 0.75

Q3 0.6 Below Target Q4 or EQR Moderately Polluted Poor of 0.75

Q2-3 0.5 Below Target Q4 or EQR Moderately Polluted Poor of 0.75

Q2 0.4 Below Target Q4 or EQR Seriously Polluted Bad of 0.75

Q1-2 0.3 Below Target Q4 or EQR Seriously Polluted Bad of 0.75

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Biotic Index EQR Surface Water Regs 2019 EPA Quality Status WFD Status EQR

Q1 0.2 Below Target Q4 or EQR Seriously Polluted Bad of 0.75

2.3 Physiochemical Sampling

Surface water samples were collected for physiochemical measurements at each of the eleven sampling locations. These were analysed by the Aquatic Services Unit of University College Cork for BOD, orthophosphate and pH following refrigeration and delivery to the laboratory. Dissolved oxygen was measured in situ with an Oxiguard dissolved oxygen meter.

2.4 Biosecurity

Strict biosecurity protocol was employed during the survey including checking, cleaning and the thorough drying (UV exposure) after completion of the surveys. Disinfection of all equipment before and after use with Virkon® was also undertaken to prevent the transfer of pathogens. Particular cognisance was given to the potential spread of crayfish plague (Aphanomyces astaci) given recent outbreaks across Ireland including most recently in the River Nore.

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

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3. Site Descriptions

Site 1 Derry River (Greenhall Bridge)

The River Derry at site 1 (Greenhall Bridge) was a lowland depositing watercourse that had a semi natural profile. The river was 7m wide and 0.2-0.3m deep and had some localised boulder protection works. The channel form was dominated by riffle and glide habitat with very localised pool. Good nursery and spawning area for salmonids existed, albeit the gravels were partially bedded with silt plumes underfoot (moderate siltation). Localised beds of water crow-foot (Ranunculus penicillatus) were present in riffle areas (5% cover) amongst extensive coarse and medium gravel beds. Emergent stands of emergent hemlock water-dropwort (Oenanthe crocata) were also present instream (5% cover). The generalist moss species Fontanalis antipyretica was present very locally on cobble (1% cover). Banks comprised mature treelines and heavy invasive scrub encroachment (Gunnera species and bamboo). Algae cover was low at < 1% due to heavy shading.

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Plate 3.1 Survey site 1 at Greenhall Bridge

Site 2 Derry River (Deegins Bridge)

The River Derry at site 2 (Deegins Bridge) was a lowland depositing watercourse that had a semi natural profile. The river was 13m wide 0.2m deep. The channel form was dominated by riffle and glide habitat and very localised pool. Excellent nursery and spawning area for salmonids were present with light siltation. Localised beds of Ranunculus penicillatus (10% cover) were present instream with more extensive stands of emergent Oenanthe crocata (20% cover). Other macrophyte species recorded included common water starwort (Callitriche stagnalis) (1% cover), watercress (Rorripa

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nasturtium aquaticum) (1% cover) and water pepper (Persicaria hydropiper) (1% cover). The generalist moss species Fontanalis antipyretica was present very locally on cobble (1% cover). Banks comprised mature treelines of Ash (Fraxinus excelsior), willow (Salix cinerea), Gunnera (Gunnera sp.) and Rhododendron (Rhododendron ponticum). Algae cover was low (<2%) on loose instream gravels.

Plate 3.3 Survey site 2 (Deegins Bridge)

Site 3 Derry River (Shillelagh Bridge ) For inspection purposes only. Consent of copyright owner required for any other use.

The River Derry at Shillelagh Bridge 50m u/s of the town municipal WWTP was a lowland depositing watercourse situated in a semi-natural channel. The river profile was dominated by deeper glide habitat with more localised riffle and pool. The channel was 7m wide and 0.3-0.5m deep. The river channel had evidently been deepened historically and was more U shaped with boulder scour protection. Nonetheless, good nursery and spawning areas for salmonids existed with the riverine gravels mostly unbedded with low to moderate levels of siltation. Heavy moss cover of Fontanalis antipyertica (5-10%) due to abundant boulders was present. Low levels of algae cover <2% were observed due to heavier shade. The shading resulted from an over deepened channel that supported a well developed and mature riparian zone comprising sycamore (Acer pseudoplatanus), ash (Fraxinus excelsior) and willow (Salix sp.).

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Plate 3.3 Survey site 3 at Shillelagh Bridge

Site 4 Derry River (25m d/s outfall)

Site 4 on the Derry River was situated 25m downstream of the Kerry Foods outfall. The channel was approximately 10m wide and 0.6m deep in this area. The channel had a semi natural profile that was dominated by deeper glide habitat with localised pool. Moderate nursery and spawning area for salmonids existed given the abundant gravels present. However, this was reduced as the gravels were For inspection purposes only. Consent of copyright owner required for any other use. more bedded in clay and silt with moderate to heavy siltation. Low levels of algae cover <2% were present due to shade. The channel was deepened and likely straightened historically. Good lamprey habitat was present due to the presence of beds of silt locally. Macrophyte species included high cover of Ranunculus penicillatus 30%; with lesser cover of Oenanthe crocata 2%, Sparganium erectum 2% and floating sweet grass (Glyceria fluitans) 1%. The very small quantities of larger substrata present (i.e. boulder and cobble) meant that moss cover (i.e. Fontalis antipyertica) was low at 1%. Mature riparian treelines were present comprising alder (Alnus glutinosa) and willow with the invasive plant Himalayan balsam (Impatiens glandulifera) present in the understories locally.

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Plate 3.4 Survey site 4 (25m d/s discharge point)

Site 5 Derry River (200m d/s outfall)

Site 5 on the Derry River was located 200m downstream of the Kerry Foods outfall in a semi-natural lowland depositing river channel. The channel profile was dominated by glide habitat with localised riffle and pool. Good nursery area for salmonids with abundant small salmonids visible. The substrata For inspection purposes only. Consent of copyright owner required for any other use. were dominated by small cobble, with smaller quantities of boulder and gravels. The river substrata were compacted with moderate bedding and moderate to heavy siltation. Algae cover <5% due to shading but enrichment apparent because of heavier Ranunculus cover 35%. Some good brook lamprey habitat in river margins near the Ranunculus beds where settlement of silt was visible. Oenanthe crocata covered 10% by surface area of the river bed forming emergent pockets between beds of cobble. Fontanalis antipyertica moss cover was high at 10% evidently benefiting from the abundant cobble substrata for attachment.

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Plate 3.5 Survey site 5 (200m d/s discharge)

Site 6 Derry River (600m d/s outfall)

Site 6 on the Derry River was a lowland depositing semi-natural river channel (10m wide and 0.4m deep) that was dominated by riffle and glide habitat with localised pool on meanders. The riparian zone was narrow and dominated by willow and birch (Betula sp.) trees with bramble, nettle and reed For inspection purposes only. Consent of copyright owner required for any other use. canary grass in the understory. The substrata were dominated by cobble with smaller quantities of boulder, coarse and medium gravels (given higher flows). The substrata overall were more bedded with moderate levels of siltation. Despite sub-optimal substrata quality, the Derry River at site 6 remained a good salmonid nursery area with abundant salmonids visible. Macrophytes were dominated by very abundant Ranunculus penicillatus cover at 40% cover with localised Oenanthe crocata (5% cover). Small quantities of Fontanalis antipyertica (5% cover) were present on instream cobble and boulder.

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Plate 3.5 Survey site 6 (600m d/s discharge)

Site 7 Derry River (1km d/s outfall)

Site 7 on the Derry River was located 1km downstream of the Kerry Foods outfall below a farm access bridge near Ballard House. The Derry River at site 7 was a lowland depositing watercourse in semi- natural channel 0.4m deep and up to 13m wide. The channel had evidently been deepened historically with local boulder scour protection installations visible. The channel was dominated by boulder and For inspection purposes only. Consent of copyright owner required for any other use. cobble but good proportions of coarse and medium gravel were also present. These were however, heavily bedded with moderate siltation. The channel had a mature riparian zone that was willow dominated with pockets of sycamore and ash. Ranunculus penicillatus cover was lower than upstream (5% cover) possibly due to shading. Emergent stands of Oenanthe crocata were present covering up to 10% by surface area of the channel. Filamentous algae cover was low at 2% cover.

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Plate 3.7 Survey site 5 (1km d/s discharge)

Site 8 Derry River (2.5km d/s outfall)

The Derry River at site 8 retained a good semi natural profile with meanders, dominated by riffle and glide habitat with localised pool. It was approximately 10m wide and 0.3m deep. The channel was considered an excellent nursery and spawning area for salmonids that was dominated by coarse For inspection purposes only. gravels that were unbedded with onlyConsent light of copyright siltation owner (i.e. required light for any plumes other use. underfoot but gravels loose). No algae were visible primarily due to shade but also swift flowing water. Channel appeared to be deepened and straightened historically but with very good recovery. The riparian zones comprised mature oak (Quercus sp.), ash, willow, sycamore and holly (Ilex aquifolium). Macrophyte cover was low with Ranunculus penicillatus covering <5% of the riverbed.

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Plate 3.8 Survey site 8 (2.5km d/s discharge)

Site 9 Derry River (Balisland Bridge)

The Derry River at Balisland Bridge was characterised by a lowland depositing river channel that had been deepened and straightened historically. The channel form was trapezoidal in shape and bordered by abundant reed canary grass (Phalaris arundinacea), nettle (Urtica dioica), bindweeds For inspection purposes only. (Convolvulus sp.) and scattered willowConsent ( Salixof copyright sp.). owner The required channel for any comprised other use. uniform deeper glide at 0.4-

0.5m deep in a channel 10m wide. The substrata were dominated by fine and medium gravels and sand with moderate to heavy siltation (visible accumulations of silt and silt plumes underfoot). Small quantities of boulder and cobble were present near the bridge (<5%). Macrophytes included low cover of submerged Ranunculus penicillatus (2%), Callitriche stagnalis (1%) and emergent Sparganium erectum (2%). There was low cover of Phormidium sp. algae (2%). The Derry River at Balisland Bridge was a very good salmonid nursery with abundant salmonids visible. Lamprey habitat was present locally in silt and sandy beds in the channel margins.

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Plate 3.9 Survey site 9 (Balisland Bridge)

Site 10 Slaney River (Kilcarry Bridge)

Site 10 on the Slaney River was situated in a wide section of semi-natural lowland depositing river channel. The banks were low and the channel predominantly deeper glide with localised riffle and small sections of pool habitat. The channel was up to 15m wide and between 0.5m and 0.8m deep. For inspection purposes only. Some historical modifications wereConsent evident of copyright including owner required boulder for any other reinforcement use. and baffle zones for fisheries enhancement. Excellent nursery area with visible abundant juvenile Atlantic salmon and trout. Frequent beds of Ranunculus penicillatus were present covering 15% by surface area of the channel, with more localised Sparganium erectum (5% cover) and Oenanthe crocata (2% cover). The substrata were dominated by boulders with localised cobbles, medium and finer gravels. Sands and occasional silt patches were also present. The large substrata were bedded with the finer substrata mostly loose with light to moderate siltation. Moss species included Hygroamblestgeium tenax and Fontanalis antipyretica making up over 5% by surface area of the bed. More open banks predominantly GA1 and birch plantation. The river margins were marshy with invasive Himalayan balsam encroachment.

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Plate 3.10 Survey site 10 (Kilcarry Bridge, River Slaney)

Site 11 Slaney River (New Bridge)

The Slaney River at site 11 was a lowland depositing watercourse with a semi natural profile with deep glide, localised riffle and pool sequences between baffled areas. This section of the River Slaney was considered a very good nursery area and good holding areas with visible juvenile Atlantic salmon, trout and frequent minnow. Frequent beds of Ranunculus penicillatus (15% cover) were present with For inspection purposes only. smaller quantities of Sparganium Consenterectum of copyright and ownerOena requirednthe forcrocata any other use.(1% cover of both). The substrata were dominated by boulders and cobbles with smaller quantities of coarse, medium and fine gravels. The river banks were more open banks, predominantly of improved grassland with reed swamp margins and treelines of ash and alder. Algae cover evident on boulders approximately 15%. River substrata quite bedded with moderate to heavier siltation in pool slack areas. Some good brook lamprey habitat in fine sands.

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Plate 3.11 Survey site 11 (New Bridge, River Slaney)

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4. Results

Both EPA Q samples and physiochemical water quality samples were collected at the 11 sampling sites on the Rivers Derry and Slaney. The 2019 results are presented below and also in the context of historical trends for Q ratings based on a ten-year cycle between 2010-2019. This allows for clearer interpretation of results relative to historical trends.

4.1 Physiochemical Results

The physiochemical parameters recorded included pH, BOD and ortho-p that were tested by a laboratory and dissolved oxygen that was recorded on site (see Tables 4.1 through 4.4 below). Dissolved oxygen was consistently recorded above 9mg/l across the survey sites on the Derry and Slaney Rivers. The broken flow patterns of these swift flowing rivers evidently provided well oxygenated water. Dissolved oxygen levels above 9mg/l >50% of the time conform to the standard of the Salmonid Regulations (S.I. No. 293 of 1988), of which the River Slaney is a designated watercourse. The pH levels were also stable across survey sites with an evident slight increase when moving between the Derry and Slaney Rivers, likely because of increased alkaline influences from the limestone basin of the River Slaney. The levels were within the range ≥ 6 ≤ 9 recommended by the Salmonid Regulations (S.I. No. 293 of 1988).

The ortho-p levels were low across all eleven sampling sites and recorded as between 0.03mg/l and 0.04mg/l and thus falling within the high status band ≤ 0.025 (mean) and ≤ 0.045 (95%ile) as per the Surface Water Regulations (S.I. No. 77 of 2019). However, the range specified in the Surface Water Regulations are based on annual averages and thus the results should be applied tentatively. The levels recorded were lower than those recorded during previous years (i.e. 2017 and 2018). Refer to Figure 4.1 below.

The BOD levels recorded were low across all eleven sampling areas and conform to high status in this respect i.e. ≤1.3 or ≤2.2 (95%ile) according For inspection to the purposes Surface only. Water Regulations (S.I. No. 77 of 2019). Consent of copyright owner required for any other use. However, these measurements are based on annual averages and the results should be applied tentatively as with the ortho-p readings. Nonetheless very low and good BOD levels were recorded across the eleven sites on the Rivers Derry and Slaney. The levels recorded were lower than those recorded during previous years (i.e. 2017 and 2018). Refer to Figure 4.2 below.

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Ortho-P levels between 2017 & 2019 0.10

0.08

0.06 p(mg/l) - 0.04

Ortho 0.02

0.00 Site 1 Site 2 Site 3 Site 4 Site 5 Site 6 Site 7 Site 8 Site 9 Site 10 Site 11 2017 2018 2019

Figure 4.1 Ortho-p levels recorded between 2017 and 2019 on the Derry & Slaney Rivers

BOD levels between 2017 & 2019 6.00

5.00

4.00

3.00

BOD BOD (mg/l) 2.00

1.00

Figure 4.2 BOD levels recorded between 2017 and 2019 on the Derry & Slaney Rivers

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Table 4.1 Historical ortho-phosphate levels in the Derry and Slaney Rivers between 2017 and 2019

Year Site 1 Site 2 Site 3 Site 4 (Derry) Site 5 (Derry) Site 6 (Derry) Site 7 (Derry) Site 8 (Derry) Site 9 Site 10 Site 11 (Derry) (Derry) (derry) 25m d/s 200m d/s 600m d/s 1km d/s Kerry 2.5km d/s (Derry) (Slaney) (Slaney) Greenhall Deegins Shillelagh Kerry Foods Kerry Foods Kerry Foods Foods outfall Kerry Foods Balisland Kilcarry New Bridge Bridge Bridge outfall outfall outfall outfall Bridge Bridge Bridge

2019 0.03 0.02 0.02 0.03 0.04 0.03 0.04 0.03 0.03 0.03 0.03

2018 0.07 0.08 0.05 0.08 0.06 0.08 0.07 0.08 0.07 0.05 0.07

2017 0.06 0.09 0.03 0.06 0.06 0.06 0.06 0.06 0.06 0.06 0.06

Table 4.2 Historical BOD levels in the Derry and Slaney Rivers between 2017 and 2019

2018 3.0 4.0 5.0 4.0 4.0 4.0 4.0 4.0 4.0 4.0 4.0

2017 2.0 2.0 2.0 2.0 2.0 2.0 2.0 2.0 2.0 2.o 2.0

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Table 4.3 pH levels recorded in the Derry & Slaney Rivers between 2018 & 2019

2019 7.34 7.34 7.43 7.31 7.42 7.36 7.45 7.30 7.31 8.12 8.44

2018 7.20 7.30 7.40 7.30 7.10 7.00 7.20 7.70 7.30 8.10 8.50

Table 4.4 Dissolved Oxygen levels recorded between the Derry & Slaney Rivers 2019

2018 9.7 9.4 9.6 9.4 9.4 9.6 9.7 9.6 8.9 9.2 9.3

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4.2 Q Sampling Results

Our results are discussed in this context of the EPA tolerances categories for riverine invertebrates in order to interpret potential changes in the river community composition. According to the methodology of Toner et al. (2005), the Environmental Protection Agency (EPA) group invertebrates into classes whereby pollution intolerant species are denoted class A, and species with greater pollution tolerance fall into successive classes (B through E, respectively). As such the presence or absence of these groups and their relative abundance facilitates an assessment of biological river health. A total of n=41 species across n=36 families were recorded from the n=11 Q sampling sites (see Tables 4.5 & 4.6 below). No very rare macroinvertebrate species were recorded from the n=11 samples on the Derry or Slaney Rivers.

Good status (Q4) unpolluted water quality is achieved according to the EPA, if at least one Group A taxon is present in, at least, fair numbers (5-10% total sample composition). Therefore, samples containing less than 5% composition within group A are excluded from the Q4 category. Group B taxa may be common or absent and Baetis rhodani are often dominant in Q4 samples. Other Group C taxa are never excessive and group D/ E taxa are present in small numbers or absent within Q4 samples (Toner et. al 2005). Sites 2 and 3 above the Kerry Foods outfall achieved target good status, unpolluted (Q4) water as required under the Surface Water Regulations 2019. These sites had the EPA Class A clean water indicator stonefly families Perlodidae and Chloroperlidae present and also the EPA Class A mayfly family Heptageniidae in fair numbers, and thus were placed in the Q4 category. However, site 4 downstream of the Kerry Foods outfall had no EPA Class A indicator species and thus achieved a Q rating of 3 (i.e. moderately polluted, poor status water quality). There was however an improvement in water quality moving downstream of site 4, with Q4 (unpolluted, good status) water recorded at sites 5, 6, 7 and 8 moving successively For inspection purposesfurther only. downstream of the outfall. There was then Consent of copyright owner required for any other use. a very slight decline in water quality at site 9 (i.e. Q3-4 slightly polluted, moderate status water quality). Upstream of the confluence of the Derry River with the River Slaney the biological water quality was recorded as Q3 (i.e. moderately polluted, poor status water quality). However, the biological water quality improved downstream of the confluence of the Derry River with the River Slaney given Q4 (unpolluted, good status) water quality was recorded downstream of the confluence at New Bridge.

The invertebrate Q-sampling was summarised as follows at the n=11 sampling sites, with seven sites achieving target good status Q4 water quality as required under the Water Framework Directive (2000/60/EC) as prescribed through the Surface Water Regulations 2019. However, site 4 downstream of the Kerry Foods outfall achieved Q3 moderately polluted, WFD poor status water quality and thus was not meeting the Q4 target.

• Site 1 (Derry River, Greenhall Bridge) Q3-4 Slightly polluted (Moderate WFD status)

• Site 2 (Derry River, Deegins Bridge) Q4 Unpolluted (Good WFD status)

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• Site 3 (Derry River, Shillelagh Bridge) Q4 Unpolluted (Good WFD status)

• Site 4 (Derry River, 25m downstream Kerry Foods outfall) Q3 Moderately Polluted (Poor WFD status)

• Site 5 (Derry River, 200m downstream Kerry Foods outfall) Q4 Unpolluted (Good WFD status)

• Site 6 (Derry River, 600m downstream Kerry Foods outfall) Q4 Unpolluted (Good WFD status)

• Site 7 (Derry River, 1km downstream Kerry Foods outfall) Q4 Unpolluted (Good WFD status)

• Site 8 (Derry River, 2.5km downstream Kerry Foods outfall) Q4 Unpolluted (Good WFD status)

• Site 9 (Derry River, Balisland Bridge) Q3-4 Slightly Polluted (Moderate WFD status)

• Site 10 (Slaney River, Kilcarry Bridge) Q3 Moderately Polluted (Poor WFD Status)

• Site 11 (Slaney River, New Bridge) Q4 Unpolluted (Good WFD Status)

4.3 Historical Trends in Water Quality

Figures 4.1 and 4.2 below illustrate the changes in biological water quality between 2010 and 2019 on the Rivers Derry and Slaney. These are also summarised on Table 4.7. Evidently when viewing historical biological water quality trends, the water quality has fluctuated between Q3 and Q4 between 2015 and 2019 downstream of the Kerry Foods outfall at site 4 (see Figure 4.1 below). When viewing the biological water quality between 2019 and 2018, the water quality has declined downstream of the outfall from Q4 (good status, unpolluted water quality) to Q3 (moderately polluted, poor status water quality) between 2018 and 2019 respectively. However, the majority of the remaining survey sites further downstream of the outfall location (e.g. sites 5 & 6) remained stable or improved since 2018. For inspection purposes only. Consent of copyright owner required for any other use.

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Figure 4.1 Summary of Biological Q Ratings between 2015 and 2019 (5 years)

Biological Q Ratings between 2010 and 2014

5 4.5 Target Q4 4

3.5

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

EPA Q Rating 2

1.5 1 0.5

0 Site 1 Site 2 Site 3 Site 4 Site 5 Site 6 Site 7 Site 8 Site 9 Site 10 Site 11 2014 2013 2012 2011 2010

Figure 4.2 Summary of Biological Q Ratings between 2010 and 2014 (5 years)

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Table 4.5 Summary of Invertebrate Q Ratings recorded on the Derry River including invertebrate species records (sites 1 to 5)

EPA Site 1 (Derry) Site 2 (Derry) Site 3 (Derry) Site 4 (Derry) Site 5 (Derry) Class Greenhall Deegins Shillelagh 25m d/s Kerry 200m d/s Kerry Group Family Species Bridge Bridge Bridge Foods outfall Foods outfall Stoneflies Chloroperlidae Chloroperla torrentium A 6 2 Stoneflies Perlodidae Isoperla grammatica A 3 7 12 4 Stoneflies Leuctridae Leuctra hippopus B 1 2 2 Mayflies Heptageniidae Rhithrogena semicolorata A 5 4 Mayflies Heptageniidae Heptagenia sulphurea A 2 5 Mayflies Caenidae Caenis rivulorum C 11 8 Mayflies Baetidae Baetis scambus B 1 Mayflies Baetidae Baatis rhodani C 4 2 5 2 Mayflies Ephemerellidae Seratella ignita C 46 48 38 92 78 Caddis (Cased) Limnephilidae early instar B 2 Caddis (Cased) Sericostomatidae Seracostoma personatum B 1 1 1 Caddis (Cased) Lepidostomatidae Lepidostoma hirtum B 1 1 1 Caddis (Cased) Goeridae Silo Pallipes B 1 Caddis (Caseless) Rhyacophilidae Ryacophila dorsalis C 3 1 1 2 Caddis (Caseless) Hydropsychidae Hydropsyche siltalai C 9 5 7 3 5 Crustaceans Gammaridae Gammarus duebenii C 26 11 10 6 4 Crustaceans Asellidae Asellus aquaticus D 1 For inspection purposes only. Beetles Elmidae Limnius volckmari ConsentC of copyright3 owner required for any 4other use. 2 8 7

Beetles Elmidae Elmis aenea C 2 4 4 5 Beetles Elmidae Esolus paralellipidus C 1 Beetles Elmidae Ouliminis tuberculatus C 1 2 3 2 Beetles Gyrinidae Gyrinus sp. C 1 Flatworms Planaridae Polycelis sp. C 1 Dipterans Simuliidae Simulium sp. C 6 4 2 4 Dipterans Chironomidae Chironomous sp. C 6 21 Dipterans Chironomidae Unidentified C 3 3 2 Dipterans Tipulidae Tipula sp. C 1 2 1

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EPA Site 1 (Derry) Site 2 (Derry) Site 3 (Derry) Site 4 (Derry) Site 5 (Derry) Class Greenhall Deegins Shillelagh 25m d/s Kerry 200m d/s Kerry Group Family Species Bridge Bridge Bridge Foods outfall Foods outfall Limpet Ancylidae Ancylus fluviatilis C 2 3 4 Snails Lymnaeidae Radix balthica D 1 Potamopyrgus C Snails Hydrobiidae antipodarum 7 76 26 Freshwater Worm Lumbricidae Eiseniella tetraedra n/a 2 1 1 1 Freshwater Worm Tubificidae Tubifex sp. E 1 Hydrachnidia Water Mite (order) n/a 1 1 % EPA Class A invertebrates 4% 15% 16% 0% 5% Taxon Richness 16 20 18 16 20 EPA Q RATING Q3-4 Q4 Q4 Q3 Q4

Table 4.6 Summary of Invertebrate Q Ratings recorded on the Derry & Slaney Rivers including invertebrate species records (sites 6 to 11)

EPA Site 6 (Derry) Site 7 Site 8 (Derry) Site 9 Site 10 Site 11 Class 600m d/s (Derry) 1km 2.5km d/s (Derry) (Slaney) (Slaney) Kerry Foods d/s Kerry Kerry Foods Balisland Kilcarry New Group Family Species outfall Foods outfall outfall Bridge Bridge Bridge Stoneflies Chloroperlidae Chloroperla torrentium A 2 For inspection purposes only. Consent of copyrightB owner required for any other use. Stoneflies Leuctridae Leuctra hippopus 3 Stoneflies Perlodidae Isoperla grammatica A 3 5 8 2 3 Mayflies Heptageniidae Rhithrogena semicolorata A 4 1 8 Mayflies Heptageniidae Heptagenia sulphurea A 4 1 Mayflies Caenidae Caenis rivulorum C 2 Mayflies Baetidae Baetis rhodani C 2 4 9 1 8 11 Mayflies Ephemerellidae Seratella ignita C 102 45 61 41 55 47 Caddis (Cased) Sericostomatidae Seracostoma personatum B 1 2 4 1 2 Caddis (Cased) Lepidostomatidae Lepidostoma hirtum B 1

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EPA Site 6 (Derry) Site 7 Site 8 (Derry) Site 9 Site 10 Site 11 Class 600m d/s (Derry) 1km 2.5km d/s (Derry) (Slaney) (Slaney) Kerry Foods d/s Kerry Kerry Foods Balisland Kilcarry New Group Family Species outfall Foods outfall outfall Bridge Bridge Bridge Caddis (Cased) Glossosomatidae Glossosoma boltoni B 1 1 Caddis (Cased) Odontoceridae Odontocerum albicorne B 1 1 1 Caddis (Caseless) Rhyacophilidae Ryacophila dorsalis C 3 2 3 3 Caddis (Caseless) Hydropsychidae Hydropsyche siltalai C 8 9 11 6 Crustaceans Gammaridae Gammarus duebenii C 2 4 5 4 Beetles Elmidae Limnius volckmari C 6 3 1 1 Beetles Elmidae Elmis aenea C 3 2 4 2 Beetles Elmidae Esolus paralellipidus C 1 Beetles Elmidae Ouliminis tuberculatus C 2 1 2 1 Beetles Dytiscidae Nebrioporus elegans C 1 Bugs Aphelocheiridae Apheloceirus aestivalis B 12 Flatworms Planaridae Polycelis sp. C 1 1 Leeches Piscicolidae Pisciola geometra C 1 Leeches Erpobdellidae Erpobdella octoculata D 1 Dipterans Simuliidae Simulium sp. C 1 3 2 14 Dipterans Chironomidae Chironomous sp. E 6 4 3 For inspectionC purposes only. Dipterans Chironomidae Unidentified Consent of copyright owner required for any other use. 2 3

Dipterans Tipulidae Tipula sp. C 1 Limpet Ancylidae Ancylus fluviatilis C 2 2 Snails Planorbidae Planorbis carinatus C 2 Snails Hydrobiidae Potamopyrgus antipodarum C 9 14 6 212 3 Freshwater Worm Lumbricidae Eiseniella tetraedra n/a 1 Freshwater Worm Tubificidae Tubifex sp. E 3 % EPA Class A invertebrates 5% 6% 16% 1% 0% 5% Taxon Richness 15 20 18 12 11 11 EPA Q RATING Q4 Q4 Q4 Q3-4 Q3 Q4

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Table 4.7 Summary of historical Q ratings covering a ten year period between 2010 and 20195

Year Site 1 Site 2 Site 3 Site 4 Site 5 Site 6 (Derry) Site 7 (Derry) Site 8 (Derry) Site 9 Site 10 Site 11 (Derry) (Derry) (derry) (Derry) 25m (Derry) 600m d/s 1km d/s 2.5km d/s (Derry) (Slaney) (Slaney) Greenhall Deegins Shillelagh d/s Kerry 200m d/s Kerry Foods Kerry Foods Kerry Foods Balisland Kilcarry New Bridge Bridge Bridge Foods outfall Kerry Foods outfall outfall outfall Bridge Bridge Bridge outfall

2019 3-4 4 4 3 4 4 4 4 3-4 3 4

2018 4 3-4 4 4 3-4 3-4 4 4 3 3 3-4

2017 3-4 3-4 3-4 3 3 3-4 3 3 3 3 3-4

2016 3 3 3-4 4 3 3-4 3 3-4 3 3-4 4

2015 3-4 3-4 3-4 3-4 3 3-4 3-4 3-4 3-4 3-4 3-4

2014 3-4 3-4 3 3-4 3-4 3 3-4 3 3 3-4 4

2013 3-4 3-4 3-4 3-4 3-4 3-4 3-4 3-4 3 3-4 3-4

2012 4 4 4 4 4 4 4 3-4 3-4 4 4

2011 3-4 3-4 3-4 4 4 4 4 4 3-4 3-4 4

2010 4-5 4-5 3-4 3-4 4 4 4 4 4 3-4 4 For inspection purposes only. Consent of copyright owner required for any other use.

5 Trends shown with arrows; green arrows illustrating improvement, red arrows decline and orange arrows indicting stable trend from previous year.

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5. Discussion & Conclusions

A decline in biological water quality was recorded downstream of the Kerry Foods outfall at site 4 when reviewing the current 2019 results to that from the previous monitoring in 2018. The current reporting recorded a Q rating of 3 (i.e. moderately polluted, poor status water quality) declined from previously unpolluted (Q4, good status) water quality in 2018. This would be an equivalent EQR of 0.6 and thus not meeting the target EQR of 0.75 (i.e. equivalent to Q4) as required under the Surface Water Regulations (S.I. No. 77 of 2019). However, the decline in biological water quality at site 4 on the Derry River was very localised and not recorded further downstream at sites 5 and 6 for example (i.e. 200m and 600m further downstream respectively). Both sites downstream of site 4 that were closest to the Kerry Foods outfall, had unpolluted Q4 (good status) water quality, indicating recovery in the biological water quality status of the Derry River moving further downstream of the Kerry Foods outfall. Furthermore, biological water quality downstream of the Derry River confluence with the River Slaney also had Q4 unpolluted (good status water quality) indicating no decline in the connecting River Slaney water quality. Physiochemical water quality measurements (i.e. ortho-p, BOD, pH & DO) were good and in the range of good or higher status water. The BOD and ortho-p levels had improved from previous years readings (i.e. 2017 & 2018).

It can be concluded that there was a localised decline in biological water quality downstream of the Kerry Foods outfall during 2019 which would not be unusual for an industrial emissions outfall. As the water quality improves further downstream, negative effects to the Derry River are localised. Furthermore, given the absence of a sampling site between the Kerry Foods outfall and the Shillelagh WWTP outfall 100m upstream, it is difficult to state whether the localised decline in biological water quality can be attributed to the Kerry Foods outfall alone or as a result of the cumulative affects of the two outfalls combined. For these reasons it is recommended that in future monitoring periods, an additional sampling site 25m upstream of the Kerry Foods outfall should be added to help separate out any upstream contributing affects from the Shillelagh outfall.

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

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6. References

Cronin, M., Gosch, M., Jessop, M., Luck, C., Rogan, E. & Reid, D. (2013) A Pilot Study of Seal Predation on Salmon Stocks in Selected Irish Rivers and Estuaries. Report by Inland Fisheries Ireland, 3044 Lake Drive, Citywest Business Campus, Dublin 24, Ireland.

EPA (2006) Water Framework Directive Monitoring Programme. Version 1 2006. Prepared to meet the requirements of the EU Water Framework Directive (2000/60/EC) and National Regulations implementing the Water Framework Directive (S.I. No 722 of 2003) and National Regulations implementing the Nitrates Directive (S.I No. 788 of 2005). Environmental Protection Agency, Ireland.

Johnston, P. (2002) A recovery plan for the River Slaney salmon fishery. Report prepared Slaney Anglers Development Association Ltd & Eastern Regional Fisheries Board by Paul Johnston Associates Fisheries Consultants

Macklin, R. & Brazier, B. (2018) Fisheries assessment of the Carrigower River at Whitestown landfill, Co. Wicklow. Unpublished report prepared by Triturus Environmental Services for Fehily Timoney & Company.

McGinnity, P. (2003). Quantification of the Freshwater Salmon Habitat Asset in Ireland, Using Data Interpreted in a GIS Platform. Central Fisheries Board.

NPWS (2011) Conservation objectives for Slaney River Valley SAC 000781. V1.0 October 2011. National Parks & Wildlife Service, Dublin. Available at: https://www.npws.ie/protected-sites/sac/000781

Panther Environmental Solutions Ltd. (2018) Aquatic Assessment of the Derry & Slaney Rivers. Prepared for Duffy Meats T/A Kerry Foods.

TEGOS (2018) The Status of Irish Salmon Stocks in 2017 with Catch Advice for 2018. Report by the Technical Expert Group on Salmon to Inland Fisheries Ireland. For inspection purposes only. Consent of copyright owner required for any other use. Toner, P., Bowman J., Clabby, K., Lucey J., McGarrigle, M., Concannon, C., Clenaghan, C., Cunningham, P., Delaney, J., O’Boyle, S., MacCárthaigh, M., Craig, M. & Quinn R. (2005) Water Quality in Ireland 2001 – 2003. Environmental Protection Agency, Ireland.

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Triturus For inspection Environmental purposes only. Ltd., Consent of copyright owner required for any other use.

42 Norwood Court,

Rochestown,

Co. Cork.

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