Scott Chidgey: Response to Expert Witness Statements and IAC RFI CEE Pty Ltd Environmental scientists and engineers Gas Import Jetty and Pipeline Project Environment Effects Statement (The EES) Inquiry Advisory Committee Scott S Chidgey Expert Witness Response to Marine Biodiversity to Expert Witness Statement Submissions & IAC Request for Information Prepared for: Ashurst and Hall&Wilcox Lawyers September 2020 CEE Pty Ltd Unit 4 150 Chesterville Road Cheltenham VIC 3192 03 9553 4787 cee.com.au Scott Chidgey Response to Expert Witness Statements and IAC RFI Marine Biodiversity Impact Assessment CONTENTS Response to Expert Witness Statement 1. Prof Perran Cook 3 Response to Expert Witness Statement 2. Cardno Australia Pty Ltd 8 Response to Expert Witness Statement 3. Dr Matt Edmunds 14 Response to Expert Witness Statement 4. Mr Frank Hanson 19 Response to IAC Request for Further Information 21 Declaration 29 Appendix to Item 6 30 Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 2 of 41 Scott Chidgey: Response to Expert Witness Statements and IAC RFI CEE Pty Ltd Environmental scientists and engineers Response to Expert Witness Statement 1. Prof Perran Cook Professor Cook is a Professor of Chemistry at Monash University and provides a balanced discussion of matters presented in EES Technical Appendix A and its Annexure A, related to chlorine toxicity and the formation of halogenated organic compounds. My responses to his discussion are listed with reference to the Item numbers used in Prof Cook’s Statement. 1. In Item2, 3 and 4, Prof Cook discusses the derivation and acceptability of the guideline value for chlorine established by CSIRO. a. He appears to agree with CSIRO’s recommended guideline value for chlorine as an acute value, but in Section 4 expresses reservations on its applicability as a chronic value. b. I would add that the CSIRO the values include important conservative considerations including: i. the laboratory results were chosen from flow-through laboratory tests that did not allow for degradation of the key toxicants (Chlorine produced Oxidants or CPOs) to less toxic forms (halogenated organocarbons or HOCs) over the duration of the test. Hence, they overestimate the toxicity expected for the exposure experienced in the field ii. Our modelling of the chlorine contours is based on the CSIRO conservative value based on dilution only, with no allowance for degradation of the more toxic CPOs to HOCs. Hence a further level of conservatism to the extent of CPO and HOC toxicity to the marine ecosystem was added in the modelled outputs presented in out reports. 2. In item 7, Prof Cook notes that brominated compounds are naturally produced by algae through natural processes. a. I would add that bromoform, dibromoacetic acid (DBAA), tribromophenol (TBP) are produced also by marine algae (Jenner and Wither 2011, Gribble 2015, Mata et al 2013), such as the red alga Asparagopsis, which is present as a natural epiphyte of seagrass in Western Port (Figure 1). Figure 1. Asparagopsis in North Arm Western Port Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 3 of 41 Scott Chidgey Response to Expert Witness Statements and IAC RFI Marine Biodiversity Impact Assessment 3. In Item 8, Prof Cook notes that “A wide range of brominated organic compounds are found in seawater after treatment with chlorine. Bromoform is typically dominant (93- 97% of THMs) with dibromoacetic acid (DBAA), dibromoacetonitrile (DBAN) and tribromophenol (TBP) comprising the majority of other identified brominated compounds.” a. As noted previously, marine biota produce these chemicals naturally. b. Prof Cook concludes that “the risk of these compounds is low compared to primary CPOs such as bromate and hypobromite” (the latter two compounds are oxidants). a. This is consistent with CSIRO’s explanation of the conservative nature of their guideline values for chlorine which is conservative in its estimate of the acute toxicity of CPOs by selecting predominantly flow-through bioassays (Annexure A, EES Technical Appendix A). 2. Prof Cook identifies the key HOCs produced compounds found in seawater after treatment with chlorine as bromoform, dibromoacetic acid (DBAA), dibromoacetonitrile (DBAN) and tribromophenol (TBP). a. These are consistent with Allonier et al 1999 (see my response to EPA submission). b. Allonier et al provide the concentrations of chlorine, bromoform, DBAN, TBP and DBAA in chlorinated effluents from three nuclear power stations on the English Channel. Allonier et al present concentrations for chlorine in mg/L and concentrations for the HOCs in μg/L. I provide Allonier et al’s data all expressed in μg/L. Table 1. Halogenated compounds in chlorinated seawater effluent, μg/L (From Allonier et al 1999) 1 Cl Bromoform DBAN TBP DBAA 2 μg/L μg/L μg/L μg/L μg/L 3 Gravelines 770 26.75 3.61 0.37 9.5 4 Penly 570 7.37 0.94 0.1 7.25 5 Paluel 200 26.8 2.83 0.14 10.19 6 Average 513 20.31 2.46 0.20 8.98 13 % of chlorine 0.55% 0.084% 0.003% 0.281% Line 13, my calculation c. Allonier et al state that the concentration of the HOCs is approximately proportional to the amount of chlorine. Hence, I consider that i. The concentrations of these HOCs in effluent from the FSRU (100 μg/L chlorine) would be less than half the average shown in Table 1 (513 μg/L chlorine); ii. the concentrations of these HOCs would be less one than 30th of their values shown in the Table 1 at the CSIRO chlorine concentration guideline vale of 6 μg/L. iii. Allowance for further reduction due to natural decay during mixing (see Table 2 would further reduce their concentration in ambient seawater. Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 4 of 41 Scott Chidgey Response to Expert Witness Statements and IAC RFI Marine Biodiversity Impact Assessment Table 2. Natural decay constants for bromoform, and other HOCs (From Jenner and Wither 2011) 3. In Section 9, Prof Cook refers to toxicity tests of bromoform, TBP and TBAA (haloacetic acid) on sea urchin embryos (Lebaron et al 2019). a. I have read Lebaron et al and provide the following comments and analyses. b. The endpoints for the 48 hour embryo exposure tests were provided as micromolar, µM (Lebaron et al 2019). c. The LOEC results reported by Lebaron et al, together with corresponding power station discharge concentrations (Allonier et al) and expected concentrations at the CSIRO Chlorine Guideline Value of 6 ug/L (= 0.17 µM) are shown in Table 3. Table 3. Comparison of HOC LOEC toxicity test results with chlorine values Toxicity tests Lebaron, et al 1 TBP Bromoform TBAA 2 LOEC, µM 3.02E+00 1.98E+02 3.37E+2 3 LOEC, µM 3.02 198 337 4 Average in PS, µM 0.005 0.08 0.041 5 Expected at GV 0.17 µM Cl 5.30E-06 9.39E-04 4.81E-04 Line 2. As reported by Lebaron Line 3. Lebaron converted to decimal form Line 4. Average concentrations in power station (PS) discharges, from Allonier et al 1999 Line 5. Expected concentration at CSIRO Chlorine Guideline value of 6 ug/L = 0.17 µM d. Table 3 shows that the Lowest Observed Effects Concentrations (LOEC) of HOCs used in the tests were more than 500 times higher than the concentrations measured in power station discharges, and 1000s of times higher than could be expected at the at the CSIRO Chlorine Guideline Value of 6 ug/L (= 0.17 µM). e. Lebaron et al further tested composite mixtures of the HOCs at their respective NOEC, LOEC and twice the LOEC, to determine potential genotoxicity. i. They found that only the composite mixture at twice the LOEC showed evidence of potential genotoxicity. These concentrations are more than 1,000 times higher than the concentrations measured in power station discharges would be required to induce potential genotoxicity and many more thousand times higher than could be expected at the at the CSIRO Chlorine Guideline Value of 6 ug/L (= 0.17 µM). f. Lebaron et al noted that test biota from a “bromo-DBP-polluted area produced more resistant progenies, as if they were locally adapted”. In other words, marine biota adapt to exposure. Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 5 of 41 Scott Chidgey Response to Expert Witness Statements and IAC RFI Marine Biodiversity Impact Assessment g. Prof Cook cites tests toxicity tests of TBP on Daphnia magna (Howe et al 2005). This is a freshwater species and could be expected to have a low tolerance to TBP compared to any marine species. h. From this, I conclude that CSIRO’s Chlorine Guideline Value of 6 ug/L is an appropriately conservative for ecosystem protection from CPOs and associated HOCs. 4. Prof Cook cites two case studies from the Gulf of Fos in France: Boudjellaba et al 2016 (cited in EES Technical Appendix A) and; Manasafi et al 2019. a. I note that HOC concentrations in the Gulf of Fos should be considered in the following context from Boudjellaba et al 2016: • The industrial zone of the Gulf of Fos is the largest in Southern Europe • The Gulf is a “semi-enclosed bay favouring water confinement in some of its more restricted inlets and docks” • “Average tidal range is 0.4 m” • Facilities discharging chlorinated seawater to the Bay of Fos listed by Boudjellaba et 2016 include: • Two LNG terminals • Three power stations • Steel industry • An oil refinery • The discharges to “several millions m3 day” of chlorinated seawater • The area of the Bay of Fos is km2 compared to the area of North Arm in Western Port.