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Ireland

Pr Dan Su ces R ation

Background

Directive 76/464/EEC specifies two categories of substances which,
depending on their characteristics, pose certain threats to the
aquatic environment. These substances are categorised into two
groups known as List I and List ıI substances. Article 2 of the
Directive requires Member States to eliminate pollution by List I
substances and to Zeduce pollution by List II substances.

Response

Ireland has adopted Regulations in respect of all List I substances
which have been the subject of separate "daughter" Directives,

The requirement in the case of List II substances is that Member
States must establish pollution reduction programmes in respect of
such substances (article 7). These Programmes must include, inter
alia, quality objectives for water.

Phosphorous

The water quality issue of greatest concern in Ireland is
eutrophication arising from excess inputs of phosphorous, In
response to the requirements of Directive 76/464/EEC, a strategy
document was published in May, 1997 which set out Ireland’'s
pollution reduction Programme in respect of phosphorus. The

unsatisfactory waters in rivers and lakes to a satisfactory level
eonsistent with the potential beneficial uses of the water. Interim
quality standards were also identified, to be achieved generally
over a 10-year timeframe. Statutory effect was given to these
interim quality standards under the Local Government (Water
Pollution) Act, 1977 (Water Quality Standards for Phosphorus)
Reguläations, 1998,

The Strategy and Regulations together represent a comprehensive
response to the single biggest threat to water quality in Ireland
i.e. increasing levels of eutrophication in rivers and lakes due

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excessive inputs of phosphorus. Tt is the Government's intention
to concentrate resources on implementation of the wide range of
measures set out in the Strategy and, in particular, on meeting the
requirements of the Phosphorus Regulations. In view of (1) the key
role which phosphorus plays in terms of water quality and (ii)
demands on limited resources, it is considered that this approach
will optimise the deployment of resources.

Other Substances

The Department has identified 15 further substances which, though of
much less significance in terms of their inputs/impacts on Irish
waters, are viewed as meriting priority consideration for
requlation, These are listed in Tables I and 2 attached. The
substances have been selected by reference to :

Ic the draft EU Commission Priority list of dangerous substances
under article 21 of draft Water Framework Directive.

2, the "129” List of candidate List I substances and those List II
substances identified by Cion as priorities.

3. the draft priority list being prepared by Clean Technology
Centre, Cork on behalf of the EPA/Department of the Environment
and Local Government which takes account of (1) 1 above, (ii)
OSPAR candidate list and (iii) scale of usage in Ireland.

4. the substances in respect of which analytical methods are
available in Ireland.

5, related proposals/recommendations of other bodies eg.
Commission’s Scientific Committee on Toxicity, Ecotoxicity and
the Environment (CSTE), EPA, TCEWOS, WRC(UK).

Tables 1 and 2 set out a good mix of substances in terms of sectoral
use, arisings and characteristics. Six are metals, two are ions
(cyanide and fluoride), four are industrial pesticides of which two
are also used in agriculture and the remaining three are industrial
solvents. All 15 substances are used in industrial processes, 4 of
the metals are also widely used in the domestic/commercial sector eg
galvinised roofs, traffic and hence are common in urban runoff and
sewage discharges. Approximately 50% o£ the substances arise mainly
from diffuse sources and the remainder are of point source origin.
Approximately 50% of the substances are of natural origin and the
remainder are predominantly synthetic.

Table 1 includes those substances that are regarded as synthetic for
the purposes of this discussion document (toluene and xylene do
occur in nature but most are produced or extracted for use by
industry). Table 2 includes those substances that generally occur
in nature and apart from cyanide cannot be synthesised.

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Longterm Objective

The overall objective will be to achieve concentrations near
background values for naturally-occurring substances and close to
zero for man-made synthetic substances. Outside of major urban
areas, most of our fresh surface waters and groundwaters and marine
coastal waters would currently be expected to meet these criteria
for the 15 substances identified,.

"Near background" for natural substances might be defined as 1.5
times background levels (assessed on the basis of annual arithmetic
mean). For synthetic substances "close to zero" may need to be
defined differently depending on the degree of hazard of the
substance and the analytical sensitivity of detection. In general,
for substances of low hazard potential and low limit of detection,
the longterm quality standard of 1.5 to 2 times the detection limit
is suggested. For substance with a high hazard potential and poor
(high) detection limit, a standard less than the detection limit
would be appropriate, For substances in between, the detection
limit may be appropriate as the longterm target.

Proposed Interim Quality Standards

Proposed interim water quality standards are set out in Tables >?
and ??.

Timeframe ta achieve Interim Quality Standards

It is proposed that, in general, the maximum timeframe for achleving
the interim quality standards in the case of rivers and lakes be
fifteen years and for all other waters i.e. groundwaters, estuarine
and coastal waters, twenty years.

The proposed timeframes are principally determined by the need to
allow appropriate time to deal with pollution loads from diffuse
sources. These are more difficult to quantify and to address than
point sources. Where point source inputs only are involved, it would
generally be the case that the proposed interim standards could be
achieved well within the timeframes suggested above. This is due to
the fact that point discharges are readily identifiable and more
readily amenable to controls. For example, on foot of making
Regulations to give effect to proposed interim quality standards, it
would be necessary for local authorities and the EPA to review all
existing discharge licences and to revise the conditions attached to
such licences to take account of the requirements of the
Regulations. In this way, it would be possible, within a fairly
short timeframe, to reduce pollution loads in respect of the 15
substances from point source discharges.

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It would be expected to take considerably longer to achieve a
substantial upgrade in the quality of groundwäaters, estuaries and
coastal waters affected than in rivers and lakes where the response
time is likely to be quicker. The proposed timeframes provide
accordingly,.

Monitoring

Regulations in relation to the proposed standards will impose major
obligations in terms of monitoring requirements. This arises
primarily in the context of determining compliance with the
standards. It will be necessary to expfess standards in statistical
terms e.g. annual arithmetic mean or 95%ile, rather than as a max.
This would require a minimum of 10 - 12 samples per year at each
site to be checked for each substance. Monitoring must be carried
out over an appropriate period initially to establish baseline data.

In drawing up a monitoring programme, it will be necessary to focus
on those waters that are most likely to be affected. This would
require local authorities to conduct an audit of all likely point
and diffuse sources of these substances. When an inventory of
likely input sites has been identified for each substance, an
appropriate monitoring regime would then be developed for sampling
and analysis to check compliance with the standards. There are
likely to be several hundred sites nationally which will need
evaluation for the impact of point or diffuse sources of one or more
of the 15 substances. Groundwaters and estuarine/coastal waters
will be the most difficult to sample. If, for example, there are
500 sites which are deemed necessary to check for all parameters,
this would require an initial 7,500 analyses. Such a check would
need to be done at least twice before deciding on which sites or
Pparameters (i) could be eliminated from further monitoring on the
basis of no detectable levels or levels close to background or (ii)
may deserve only occasional monitoring in the future.

For all other waters which appear unäffected by inputs, it is
proposed that appropriate monitoring regimes be developed to carry
out representative sampling and analysis in order to determine
natural background levels of appropriate substances and to pick up
any unexpected breaches of the quality standards. In the case of
metals, this would also require monitoring the hardness of relevant
waters.

On the basis of the above, it is estimated that something of the
order of several hundred sites (affected and unaffected) would need
to be monitored at varying levels of frequency. This could result
in a demand for up to 50,000 analyses per year. This level of
monitoring would impose substantial burdens on local authority and
national monitoring capability at a conservatively eastimated cost

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of £2.5m per annum. Analytical costs would be higher than for
normal emission level monitoring because of the much lower level of
detection required.

Exemptions

It will be necessary to provide for exemptions from the Proposed
quality standards where (i) there are naturally-occuring elevated
levels that may exceed proposed standards and (ii) where historical
activity e.g. mining of ores, may have resulted in a more or less
permanent change which would require an exceptional effort to
reverse (in terms of human and financial resources).

Water Quality Section

Department of the Environment and Local Government
Dublin

Ireland

May, 1999

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