PFAS investigations at Longford Plants

What is PFAS?

Per and polyfluoroalkyl substances (PFAS) are a group of chemicals which have been widely used in consumer and industrial products for over 40 years. They were, and in some cases still are, used in common household products such as stain prevention of carpets, furniture and other textiles, cosmetics, manufacturing, cooking implements, packaging for microwave popcorn and other food products.
PFAS have also been used in firefighting foams and hence its relevance at the Longford Plants where such foams have been used for firefighting purposes including training.

Environmental Audit and Findings

An environmental audit was completed at Esso Longford in December 2020. An environmental audit is an assessment of the condition of the environment, or the nature and extent of harm (or risk of harm) posed by an industrial process or activity, waste, substance or noise (EPA, 2007).

Esso engaged internationally-recognised environmental consultancies to undertake the investigative program and provide independent advice on the assessment and mitigation of potential risks to human health and the environment. An EPA appointed Auditor then audited our work program and conducted an Environmental Audit pursuant to Section 53V of the Environment Protection Act 1970.

The audit focused on if there was, and if so the nature of, any significant risk of potential harm to beneficial uses of the environment on and from the premises, caused by firefighting training as well as oil and gas refining and, in particular, risks posed by the historical use of Aqueous Film Forming Foam (AFFF) that contained PFAS.

The audit was triggered by a Clean Up Notice issued to Esso by EPA Victoria on 13 July 2017. Further notices were issued by EPA Victoria during the audit process refining the scope, process and deliverables, with all notices having been revoked by December 2020. 

The audit has found that:

1. A comprehensive and well formulated program of investigative works has been carried out to understand the risks posed by contamination that has arisen from historical use of PFAS and other contaminants of potential concern at the site.
2. Use of PFAS containing products has ceased. Remedial works have been carried out (and are ongoing) and management measures have been implemented, with effort directed to areas of highest risk. This work has reduced the impacts to onsite surface waters by an order of magnitude over the last few years, and over time it can be expected that this reduction will extend off site.
3. The risk posed by residual PFAS both on site and off site is now low.
4. A Site Management Plan has been prepared; this outlines a proposed program of remedial works and monitoring so that the risk remains low. This program includes:

• Complete remediation of the Fire Training Ground
• Further investigate and reduce migration of PFAS from the southern and eastern areas of the site
• Reduce and contain as necessary on site source areas
• Undertake a monitoring program
• Maintain fencing of dams as may be necessary. 

Next steps

Esso will continue to implement the Site Management Plan, which has been verified by the Auditor and was submitted to the EPA in December 2020. We are continuing to engage with relevant stakeholders, including neighbours and government agencies such as the EPA. This includes annually surveying surrounding properties for change in use, ongoing sampling at selected locations and ongoing management measures (where required).

PFAS and Health

Most people will have PFAS chemicals in their body as these compounds have been used in common household and industrial applications for many decades. At present, there is limited and contradictory evidence that these chemicals cause adverse human health effects. Whilst there have been numerous studies on effects on animals, as indicated by Australian health agencies, the link between these chemicals and effects on human health is not clear.

An independent expert health panel established by the Australian Government (which studied both Australian and international health evidence) recently concluded "there is mostly limited, or in some cases no evidence, that human exposure to PFAS is linked with human disease" (Department of Health). Notwithstanding this, it is recommended that human exposure is minimised as a precaution on the basis that these compounds do not readily break down and are retained in the body for long periods.