The safety of children attending Barretstown Gang Camp in Co Kildare will be "seriously endangered" if levels of pollution at a proposed concrete manufacturing plant exceed agreed standards, the centre has claimed.
In a statement to a Bord Pleanála hearing into the planned development, Barretstown said it had no objection to the plant being built on a neighbouring site as long as conditions of planning permission were complied with.
Neither the Environmental Impact Statement (EIS) attached to the development, nor its own review of the information, "identifies a known significant risk" to the children, Barretstown said.
However, it added, the reports did not demonstrate "no risk".
Given the potential threat, the centre urged An Bord Pleanála to provide for independent weekly monitoring of dust and noise pollution from the plant - funded through a "significant bond" by the developer - if the plan were to go ahead.
The statement, read into the record by planning consultant Mr Simon Clear, came on the first day of an oral hearing in Kill into Kildare County Council's decision on October 18th last to grant planning permission for the plant.
A total of 12 third-party appeals have been made against the scheme, which covers more than 120 acres at Dowdenstown and Donode, near Punchestown.
The plan by Readymix (Dublin) Ltd entails the extraction of sand and gravel over an area of 35.5 hectares, new vehicular accesses and access road, a concrete batching plant and ancillary development works on an overall site of 49.5 hectares.
Opposition centres on the impact of the development on local amenities, traffic, property prices, and public health, including the health of the 1,500 children from throughout Europe who attend the camp each year.
Local Independent county councillor Ms Mary Glennon said the children, some of whom have cancer or leukaemia, come for a few weeks of "rebirth" each summer. "We owe it to them to ensure that they have the clear air environment for which this area of Kildare is famous."
The inquiry heard there was a conflict in medical opinion over the potential threat, with Mr Clear stating that Barretstown's medical director, Dr Finn Bhreathnach, did not share the same concerns as an expert witness for the appellants, Ms Lynda Fenelon of St Vincent's Hospital, Dublin, over the creation of air-borne spores from the works.
Mr Clear said Dr Bhreathnach, a senior consultant at Our Lady's Hospital for Sick Children, Crumlin, did not believe the potentially harmful spores would travel the distance required from the manufacturing plant to Barretstown.
Mr Stephen Browne, a local residents' representative, claimed the EIS covering the plan omitted crucial information, including predictions of noise and dust pollution. A "very severe weakness" in the plan was that there was nothing to prevent lorries from using narrow side roads.
While recommended transit routes were outlined, he said: "Who is going to enforce this? The answer is nobody." Noise levels, averaging an estimated 55-74 dB, would result in "unbelievable" disruption in certain homes, given the "very quiet" nature of the locality.
Outlining the development, Dr Alan Cobb, an installation and hydrology expert for Readymix, noted the plant would be sunk into a depressed area, and landscaped by means of "progressive restoration". The main effect of this would be to keep the sand and gravel working area to an absolute minimum so there was very little such material exposed at any one time, he said.
The hearing continues today, and is expected to run at least until tomorrow, with a decision in several weeks' time.