Esso Australia Pty Ltd – Longford Gas Plant
EPA Reasons for View Formed (18/10/17)
Fire fighting foams containing Per and Polyfluoroalkyl substances (PFAS) have been used at the premises as part of fire training activities. The premises continues to be used for fire fighter training and as an oil and gas processing, with the adjoining premises being used for agricultural activities. Contamination by PFAS has been identified in soil, sediments, groundwater, and surface waters at your premises. Contamination by metals (nickel and zinc) has been identified in soils at your premises. Contamination by dioxin and furan compounds have been identified in sediments at your premises. Exceedance to your groundwater monitoring program criteria have been identified for gross alpha, total dissolved solids, ethylbenzene, naphthalene,
copper, lead, nickel, zinc, ammonia, nitrate, phosphorus, and nitrogen at your premises.
The concentrations of contamination satisfy the EPA that an activity has caused pollution where surface waters, groundwater and land have been so changed as to make or reasonably expect to make detrimental to any beneficial use made of those waters and land.
Further time is required to allow the Auditor to appropriately asses the Interim Draft Clean Up Plan to ensure Auditor Verification can be obtained prior to submission to EPA. This notice replaces the previously issued
CUN 90007860.
In order to address this, you must take the clean up and ongoing management measures listed in this notice.
EPA Observations
“… 1.2.4 On page X that PFAS was identified as a key contaminant of potential concern, due to historical use of aqueous film forming foam.
1.2.5 On page X that site investigations are continuing. This report details results from 77 soil, 44 sediment, 24 surface water, and 41 groundwater locations that were sampled.
1.2.5 On page X that 72 of 77 soil results indicate PFAS above the limit of reporting (LOR) whilst two exceeded industrial screening criteria (these samples were in the FTG) and one exceeded ecological criteria
(sample located within a paddock east of the FTG). Concentrations of metals (three nickel and five zinc) above industrial screening criteria were identified at locations within the Main Plants, FTG, and Heliport.
1.2.6 On page X and XI that 41 of 44 sediment results indicated PFAS above the LOR whilst five exceeded ecological criteria north of the FTG, north of the Heliport, and in Lyndon’s Dam. One sediment sample, located within the drainage line north of the FTG reported concentrations of dioxin & furan compounds above ecological criteria.
1.2.7 On page XI that 23 of 24 surface water samples collected from the Main Plants, FTG, Heliport and Premises reported PFAS concentrations above the LOR whilst seven exceeded ecological criteria adjacent to the Heliport and within the Premises boundary. The Main Plants, FTG and Heliport are zoned industrial and, as such, samples taken at these locations were not compared to ecological criteria. Results from samples taken from the south of the Main Plants and within a small dam located to the north of the Heliport
indicate PFAS levels exceeding ecological criteria. Analyses of other CoPC in surface water are pending.
1.2.8 On page XI that 41 of 48 groundwater samples collected from the regional (Boisdale Formation) aquifer on the Premises reported PFAS concentrations over the LOR, whilst eight exceeded criteria. No PFAS
ecological criteria were adopted for groundwater at the Main Plant, FTG or Heliport as groundwater is not extracted at those sites from the targeted Boisdale Formation aquifer or perched aquifers and as those sites are zoned industrial. Analyses was performed for additional CoPC and a total of 30 results for various chemical compounds (gross alpha, TDS, ethylbenzene, naphthalene, copper, lead, nickel, zinc, ammonia, nitrate, phosphorus, and nitrogen) from a total of 12 locations (including the Main Plant, Heliport and western and south western landfill) were above their respective relevant criteria per the Groundwater Monitoring Program (GMP) for the Premises.
1.2.9 On page XI that several of the soil, sediments, surface water and groundwater samples collected from the Premises outside the Main Plants, FTG and Heliport areas (primarily surface water drainage lines and water bodies) show impacts from PFAS and other CoPC.
1.2.10 On page XI that water collected from separators at the FTG recorded the highest concentrations of PFAS. The principle mechanisms for PFAS migration have been identified as flow of impacted stormwater or
run-off from the site and overflow of impacted ephemeral water courses during flood and other events. Key discharge points for stormwater from the Main Plants, FTG and Heliport have been identified.
1.2.11 On page XI that as the receiving water bodies (potentially including dams and drainage channels) are protected under SEPP Waters of Victoria, a number of beneficial uses may be impacted, principally maintenance of aquatic ecosystems and stock watering, as livestock are known to have access to impacted surface water features located to the north, east, and south-east of the Main Plants, including Lyndon’s Dam.
1.2.12 On page XI that the assessment of risks to aquatic ecosystems has derived a moderate to high risk level due to the expected distance of transport of PFAS in the water course. Further assessment of ecological risk will be undertaken.
1.2.13 On page XI that human health effects from drinking water and recreational use have been assessed as being low with further assessment being undertaken on a precautionary basis.
1.2.14 On page XI that human health effects from consumption of impacted livestock produce have been assessed as being low. Further assessment by testing animal blood is being undertaken as a precautionary measure.
1.2.15 On page XI that human health effects from consumption of irrigated crops have been assessed as being low. No action is being taken as human exposure from consumption of crops is considered unlikely given low uptake of PFAS by most plants.
1.2.16 On page 5 that the use of aqueous film forming foam (AFFF) containing PFAS ceased in 2007, but was stored on-site until 2016 and that it is possible that residual contamination remains (and/or remained for some time) in current foam and water management systems.
1.2.17 On page 26 table 6-2 summary of PFAS soil sample results showing exceedances of the adopted criteria at the FTG and adjacent to the FTG.
1.2.18 On page 27 table 6-3 summary of soil results including exceedance of nickel adopted criteria at the Heliport and zinc adopted criteria at the Heliport, FTG and Main Plants.
1.2.19 On page 29 and 30 table 7-2 summary of PFAS sediment results showing exceedances adjacent to the FTG, Adjacent to the Heliport and within the premises boundary.
1.2.19 On page 31 table 7-3 summary of sediment results exceeding adopted criteria – excluding PFAS with a dioxin and furan concentration at the FTG above the adopted criteria.
1.2.20 On page 32 table 8-1 summary of PFAS surface water results with exceedances of the adopted criteria adjacent to the heliport and within the premises boundary.
1.2.21 On page 36 table 9-2 summary of PFAS groundwater results with exceedances of the adopted criteria within the premises boundary.
1.2.22 On page 38 table 9-3 summary of June 2016 GME groundwater results exceeding adopted criteria – excluding PFAS including gross alpha, ethylbenzene, naphthalene, copper, lead, nickel, zinc, ammonia, nitrate, phosphorus, nitrogen and TDS.
1.2.23 On page 39 and 40 table 10-1 risks to protected beneficial uses of land with the following beneficial uses showing further investigation is required to assess potential impact by contamination: maintenance of modified ecosystems, human health and production of food flora and fibre.
1.2.24 On page 40 and 41 table 10-2 risks to protected beneficial uses of surface water with the following beneficial uses having potential impact by contamination: aquatic ecosystems that are slightly to moderately
modified, secondary contact recreation
1.2.25 On page 41 and 42 table 10-3 risks to protect beneficial uses of groundwater with the following beneficial uses having potential impact by contamination: maintenance of aquatic ecosystems, agriculture,
parks and gardens, stock watering
1.2.26.1 On page 47 that potential receptors outside of the premises boundary include:
1.2.26.2 Flow into Carrs Creek via a watercourse flowing through four unnamed dams, Lyndon’s Dam and onward to Carrs Creek. Carrs Creek flows to Lake Reeve.
1.2.26.3 The Esso saline water pipeline alignment (due to potential current or historical leakage) with emphasis on sloping stretches.
1.2.26.4 The Western Storage pond (which was a historical alternative discharge point to the Esso wastewater pond).
1.2.26.5 The Esso Saline waste water pond and Dutson Downs No. 2 Pond (which outfalls to Bass Strait once treated).
1.2.26.6 Multiple unnamed channels and farm dams, which exist within close proximity to the premises.
1.2.26.7 Known channels including: three channels draining into paddocks from the FTG, two channels draining from the Heliport, with one discharging directly into a dam to the north and the other onto vacant land adjacent to the Heliport and the paddocks east of the premises, associated channels and dams.
1.2.26.8 Down-gradient groundwater users for domestic/stock watering/irrigation purposes.
1.2.26.9 Livestock and terrestrial ecosystems within proximity of the premises due to potentially contaminated windblown dust and foam.
1.2.26.10 Livestock and terrestrial ecosystems in areas potentially impacted by contaminated surface waters.
1.2.27 On page 53 to 58 table 12-2 qualitative risk assessment to receptor showing high risk rating for exposure of plants and animals in aquatic ecosystems to impacted water and a medium risk rating for exposure of plants and animals in aquatic ecosystems to impacted groundwater with all other risks rated as low…”