A proposal to manage PFAS contamination at the Colongra/Munmorah power stations site is a positive step but may fall short of protecting the health of our lakes and community from the long-term effects of this toxic chemical, according to the Central Coast Community Better Planning Group (CCCBPG).
Mr Gary Chestnut, Chair of the CCCBPG, said it is four years since the NSW Environmental Protection Authority (EPA) told residents living around the Colongra/Munmorah site that they didn’t need to worry about the health impacts of PFAS and almost eight years since investigations started.
The site was found to be contaminated with PFAS because of the historic use of firefighting foams that contained the chemical.
According to the Commonwealth Department of Health, “Per- and polyfluoroalkyl substances (PFAS) are human-made chemicals that are used to make products resistant to heat, stains, grease, and water. Most people are likely to have had some exposure to PFAS. PFAS exposure has not been shown to cause disease in humans. However, it has been associated with mildly elevated levels of cholesterol, effects on kidney function and effects on the levels of some hormones. The differences reported for these associations have generally been small and unlikely to be important to health outcomes. PFAS substances take a long time to break down in the environment and human body, so as a precaution it’s recommended to limit exposure where possible.”
Site owners, GPM, have submitted a development application to Central Coast Council (DA 1587/2023) for ‘Alterations, Additions & Change of Use to Water Treatment Plant (WTP)’ at 301A Scenic Drive, Colongra. The plant will be used to treat PFAS-contaminated water and the treated water will then be discharged via the ash dam and inlet canal.
CCCBPG’s submission in response to the DA raised concerns about relying on the current Environmental Protection Licence (EPL) for the site to monitor for PFAS. The requirements in the current EPL for water and/or land concentration limits only cover the pH of the discharged water and total suspended solids.
“The current EPL 759 sets no limit for any residual PFAS,” the CCCBPG submission said.
“Council must not grant consent for DA1587/2023 unless a unit of measurement is set for PFAS at the discharge point.
“As a starting point, we recommend both Council and Generator Property Management Pty Ltd (GPM), refer to the Australian Government Department of Health ‘Health Based Guidance Values for PFAS’.
“We encourage Central Coast Council to make representations to the EPA and NSW Government about the absence of measures for PFAS within the current EPL 759.”
CCCBPG will be making its own representations in relation to this omission from the EPL.
According to documents submitted in support of the DA by GPM, “The final design of the Water Treatment Plant will depend on the final water quality parameters for PFAS removal as agreed with the EPA. The WTP can be designed to meet 90%, 95% or 99% species protection level with higher quality achieved by replicating the final filtration stages. The required species protection level will be agreed with EPA as part of the Voluntary Management Proposal for remediation of the site.”
“We strongly recommend that Council impose the 99% species protection level,” the CCCBPG submission said.
“The maximum design standard is required because, as Council is aware through its own modelling, the Tuggerah Lakes system shows that wind is the primary source of circulation with retention times for each lake to fully circulate its waters being: Tuggerah Lake 220 days; Budgewoi Lake 460 days; and Lake Munmorah needing 520 days.
“As a result of the poor circulation, any PFAS remaining in the discharged water may accumulate and stay in Lake Munmorah.”
Mr Chestnut said the CCCBPG was concerned about the applicant relying on the EPA to inform the community about PFAS and hydrocarbon contamination.
The EPA states that seafood from the Tuggerah Lakes system remains safe.
However, PFAS has been located within and at the end of the canals at the Colongra and Munmorah Power Stations.
Vales Point Power Station has a fishery exclusion zone at the canal’s exit.
Accordingly, GPM and Central Coast Council should both consult with the Department of Primary Industry to confirm whether the level of PFAS detected within and at the outlet of the canals would require a fishery exclusion zone.
This consultation must take place prior to the granting of consent for the PFAS treatment plant development, according to the Central Coast Community Better Planning Group.