Thrumster Wastewater Scheme

I am commenting on how the project would impact Port Macquarie Race Club

Please see attached submission

Please see attached submission

See attached submission

See attached submission

See attached submission

As a resident living 500m away from the proposed water treatment facility I have multiple objections to this proposal

1/ Odour and air pollution when operating
There are many missing parts to the odour modelling study
I have made multiple requests to the council re further information but they have been unable to provide this information until September which is close to when this submission is due
The odour modelling does not show the percentage the wind is travelling in the South or West directions and therefore does not show the odour units at my residence. It also does not take into account the manufactured elevation of the site once constructed which I believe would increase the odour units experienced at my residence as the odour would more easily travel over the ridge located behind my house
Therefore the modelling is incomplete. Also the modelling uses an analytical model. As per article published in Water Research, analytical measurements do not relate to odours as perceived by humans which is of critical importance in considering odour nuisance. Sensory measurements are best suited to this role. The council have ignored residents concerns at the meetings and are refusing to consider an odour control unit. They have also displayed deceptive behavior by recommending we tour Mothept water treatment facility which has an odour unit attached
The odour emmissions at the inlet of the proposed facility have an odour measurement of 40+ odour units!!! (6 OU is very unpleasant)
In the Health Impact Assessment, it states that all odour units are under the EPA guidelines. Again this is misleading as these guidelines are tailored for higher resident density population numbers. Based on their modeling, 100% of the closest neighbors will be affected by the odour. Let me explain:
As per Department of Environment and Heritage Protection Guideline for Odour Impact Assessment from developments, 1 odour Unit is defined as that concentration of odourant(s) at standard conditions that elicits a physiological response from a panel (detection threshold) equivalent to that elicited by one Reference Odour Mass (ROM), evaporated in one cubic meter of neutral gas at standard conditions.
As per page 56 of Health Impact Assessment Report the “predicted odour units at various locations close to the plant site average 1.8 units.
The Department and Heritage Protection Guideline recommend that one should not be able to detect odour from a new development 99.5% of the time (or 44 hours in a year). Hence the residents closest to the facility would be able to detect the odour 100% of the time and sometimes severely. This is not conducive to peaceful living and puts our health at risk
If the council moved the Water treatment facility East away from residences or installed and used the odour control unit from the start of operation, the predicted odour units would range between 0.2-0.5 odour units
Council (as quoted by Cameron Hawkins who is the project manager) estimates the cost of an odour control unit would be less than 8% of the total cost of the project. The council clearly doesn’t care about these few residents and show an absolute disregard for their well being
Port Macquarie Hastings council has a very poor history of controlling odour at their existing water treatment facility as evidenced by the number of complaints and EPA mandates
Therefore I would recommend the water treatment facility be moved East away from residences or make it mandated that the odour control unit be installed and used from the first day of its operation

2/ Microorganisms and viruses and micro toxins released from waste water system will threaten health of closest residents.
There is no prevention strategy, management plan or even a detection system for bioareosol transmission
Microflora and micro toxins are present in the air around Water treatment facilities. Basically if you can detect odour there is microrganisms and toxins present in the air. All the residences closest to the proposed facility have no access to clean town drinking water. We collect our water off our roofs or use bore underground water. The microorganisms will land on our roof and contaminate our water tanks. Hence we will be unable to have access to clean water

3/ Pollution of environment with PFAS chemical
PFAS is a chemical which is concentrated at Water treatment facilities is currently found in the solid waste of the Port Macquarie Koala St facility. This chemical is highly toxic and medical studies show there is no safe level of this chemical. The proposed scheme has no management plan to mitigate this risk to surrounding residents.

4/ Pollution of Pristine Waterways
I have lived at Fernbank Creek Road for many years and our road and surrounding mangroves have a serious flood every 3 years where I am unable to drive down Fernbank Creek Rd
On page 38-41 of the Health Impact Assessment report the council proposes that during an emergency storm or flood, wastewater overflow (similar to raw wastewater/raw sewage) will be released into Partridge Creek and then flow into Fernbank Creek and Hasting River.
Partridge Creek water quality normally has an enterococci count of 50-64
Wastewater released has a water quality of enterococci count of 30,000-50,000
The report is very deceptive as it then claims it would only increase the enterococci count of around 5%. This is clearly incorrect
There would be an increase in enterococci count of >500%
They are justifying this proposed pollution by quoting WHO on page 41 “Ancient civilisations that invested in sanitary improvements become healthy, wealthy, powerful societies.”
Wouldn’t it be better to construct a water treatment facility to the best standards to prevent odour and air pollution and pollution of pristine waterways?
Surely common sense should prevail and the construction of the water treatment facility should prevent both air and water pollutions and the subsequent significant health impacts this would have on the surrounding farms, residences and industry

5/ Safety of school children walking home from school
There is a bus stop located at the corner of Fernbank Creek Rd and Hastings River Drive. Children subsequently walk along this very narrow road with no footpath and long grass on each side of the road. Due to the increase in traffic this is clearly unsafe and there either needs a walkway in place or a change in bus route.

6/ Conduct of Port Macquarie Council employees and contractors
This whole process has been very difficult
I was first made aware of this proposal through neighborhood gossip. Phone calls and messages left with council in regards to the proposed waste water facility were left unanswered. Finally upon emailing council, I received a response on the 9/5/2023. I then shared this response with the other neighbors who had no knowledge of the proposed facility
The meetings which were then conducted by council provided us with misleading information and the environment report was misleading and biased to meet council needs
Eg other potential sites for the waste water facility had major issues with them
Eg tour a like for like water treatment facility – the facility toured had odour mitigation unit attached
Eg The Thrumster Waste Water Scheme Odour fact sheet stated “that very stable conditions occur most frequently (34% of observations) yet don’t label the other conditions on the graph which occur 66% of the time. I think 66% is much more common than 34%
I found the behavior of the council employee’s patronizing eg “if you’re anxious about odour, of course you will smell it” and misleading.




Conclusion
I would appreciate your measured assessment of this facility and the conduct of the Port Macquarie Council
I believe a new facility should minimize environmental pollution both air and water and should include the newest and best technology to achieve minimal environmental impact, not just to the environment but to the pre-existing residences
If this proposal is passed as is, I believe there will be huge environmental impacts and subsequent litigation to the PMQ council



References
Odour measurements for sewage treatment works
P. Gostelow, S.A. Parsons, R.M. Stuetz
Published in Water Research Volume 35, issue 3, pgs 579-697
https://www.sciencedirect.com/science/article/abs/pii/S0043135400003134

The bioaerosols emitted from toilet and wastewater treatment plant: a literature review
Mengmeng Lou,1 Shuai Liu,1 Chunjie Gu,1 Huimin Hu,1 Zhengkun Tang,1 Yaopeng Zhang,1 Chenye Xu,corresponding author1,2 and Fang Licorresponding author1,2
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7585356/

Department of Environment and Heritage Protection
Guideline : Odour Impact Assessment from Developments
The purpose of this document is to provide information on odour impact assessment from developments under the Environmental Protection Act 1994.
https://environment.des.qld.gov.au/__data/assets/pdf_file/0021/90246/guide-odour-impact-assess-developments.pdf

I am an adjoining neighbour to the proposed Thrumster Plant. As a direct neighbour, my number one concern is odour. Our property is in direct line with the predominant summer long north easterly winds. This puts us in the direct path of any odours coming from the proposed Thrumster plant all summer long – hence our anxiety.
I attended the organised tour of the Farley Wastewater Treatment Plant. We were told this plant was the same technology that would be deployed in the Thrumster plant. At the time of the visit, I noticed the proximity of the surrounding neighbours. By looking at Google maps, it would appear that the surrounding neighbours of the Farley Plant are approximately 800-900m away. It should be noted that the neighbours to the proposed Thrumster plant appear to be as little as 500m away.
The Farley plant tour was very informative, and I was relieved by the almost total lack of odour experienced while on site. We walked over the top of the Inlet Works, and over the open raceway/tanks where the liquified sewage ran and there was almost no detectable odour. This provided great relief from the anxiety we had about the proposed Thrumster plant.
Unfortunately, this relief was short-lived with the release of the EIS. From my research, the worst odour comes from the Inlet Works. At Farley the Inlet Works are fully enclosed. We walked over the top of them and there was no detectable odour. I am now of the understanding that the Thrumster plant will not have an enclosed Inlet Works, and the odour table in the EIS gives that part of the plant an odour rating of 40+.
When I asked council officers at the EIS drop-in session if I would have experienced any 40+ odours during our Farley Plant tour, it quickly became apparent that we had not experienced anything like that. In fact, it was likely we had experienced low single figure odour ratings at worse.
Given both the Farley and Morpeth Plants (with neighbours at a greater distance) require fully enclosed Inlet Works to reduce odour, why is it that Thrumster does not get a fully enclosed Inlet Works ? When this question was posed to council officers, the response was “to save on capital costs”. They tried to reassure us that the Inlet Works would be “pre-dosed” with chemicals, however this is of little comfort when that part of the plant is rated 40+ on the odour scale, when the rest of the plant has largely negligible odour ratings (see: Thrumster WWS_Air Quality Assessment Table 4.9, page 29).
Given the risk to both us and surrounding neighbours, the close proximity to the plant, and the potential impact on the amenity and value of neighbouring properties, we would ask that the Thrumster Plant Inlet Works be fully enclosed like the Farley and Morpeth plants. This protects our properties, the amenity we can continue to enjoy, and the value of our properties to our families into the future. Please insist on the full enclosure of the 40+ odour producing Inlet Works for the Thrumster Wastewater Plant.

To: The NSW Planning Department / EIS
We appreciate the opportunity to collaborate on this project and are in agreement with its overall objectives. However, we must emphasize the critical importance of addressing the foundational issues before proceeding further. We don’t have the tools to assess the potential influence of bad smell and noise and hope that council has implemented the world’s best available technologies, machineries, filters etc., regardless of costs.
The following is what we are concerned of and what we know and live through every day, by some of us being living here for over 50 years.
The entire area is heavily saturated at all times, with land fences consistently submerged in water. (Pictures available) We have already lost approximately 20% of our land to rising water levels. Fernbank Creek, which serves as the primary channel for water drainage from the entire area, including the project site, has significantly diminished in capacity, with an average depth of only 10 cm.
It would be disastrous to introduce additional water into the creek without first dredging it and ensuring a clear path to the Hastings River. As it stands, the water levels will continue to rise, and a future flood could have catastrophic consequences. We are all aware that the plant’s site has been submerged in previous floods. Now that the area is concreted, the question arises: where will all the excess water go? Moreover, if, heaven forbid, raw sewage were to flow towards the creek, it could inundate our lands and homes, causing severe health and environmental hazards.
Council itself on Page s38-41 of the Health Impact Assessment proposes that during emergency (Flood, earthquake, storm etc.) the “wastewater overflow (Other word for Raw sew will be released into Partridge Creek and then into Fernbank Creek to Hasting river). How misleading is that? Fernbank Creek is full to the gills and overflows already without the “favour” of any emergency. Even more water, especially contaminated water will turn into a long term disaster in every aspect.
To illustrate the importance of solid foundations, consider the scenarios that did happen is the area of Casino, Gosford, and Lismore.
Secondly, the Fernbank Creek road, as it currently stands, is almost at the existing water level. This two-way road is dangerously narrow, winding, and in poor condition, with rough and broken surfaces. The road has no edges, and large trees, stumps, deep cavities, and slippery sides are in no way ready to support three years of construction and heavy vehicles. The junction of Fernbank Creek Road and Hastings River Drive is already hazardous, and additional heavy traffic will lead to tragic accidents.
This without mentioning the fact that school children are dropped of their bus on corner of Fernbank Creek Road and must walk home on this narrow, two way road, as no edges or foot paths available. The road needs to be well adjusted to 3 years of construction traffic plus the local resident’s traffic and all drivers from / to Thrumster, Sovereign Hills and Wauchope using it instead of the congested Oxley Highway. Without such adjustment and upgrading of the road, we honestly cannot see how road safety and engineering can approve a project such as this.
We recommend that Fernbank Creek Road be upgraded to improve road quality and create safe, comfortable edges by removing trees, stumps, and other obstacles. We invite the EIS experts, hydro and road safety engineers to visit the location and hopefully call for steps to safely regulate the waterways and their escape, as well as address the hazardous road conditions.
We strongly urge that these foundational concerns be prioritized to prevent potential disasters and ensure the long-term success and safety of the project.
Thank you for your attention to these critical matters.
Sincerely,
Simon Seidenman
Michael Munday
Robert Hough
Fernbank Creek Residents
Attached 2 pictures reflecting the current water level way into private land, with no recent flooding.

I would like to advise that I support the project. Major projects such as these will always result in negatively affecting a small number of people and this unfortunately has to be managed appropriately, but this town has a record of pandering to small groups with loud voices, hence why I am taking the time to register support for a very important development. Without this, growth of the town will be severely hampered, which would have a significant, negative impact on just about everyone. The provision of new waste water treatment facilities is an urgent infrastructure priority and this location is any to service a significant growth area of this town.

This is long overdue and needs to be urgently fast tracked. It is holding up important rezoning in the town like the Health and Education precinct area as well as other infill development needed to address the community’s health, education, childcare, university accommodation and essential worker accomodation.
It is extremely urgent to fast track this development.

Hopkins Consultants are in support of this project. The Thrumster WWS is essential infrastructure to support the targets in Council's Housing Strategy. We encourage approval and commencement of this project at the earliest opportunity.

See attached.