ENVIRONMENT, NATURAL RESOURCES AND …...Version: 1.3 Date: 23/02/2016 2154309_22\C ENVIRONMENT, NATURAL RESOURCES AND REGIONAL DEVELOPMENT COMMITTEE Inquiry into the CFA’s Training

$Page 1: ENVIRONMENT, NATURAL RESOURCES AND …...Version: 1.3 Date: 23/02/2016 2154309_22\C ENVIRONMENT, NATURAL RESOURCES AND REGIONAL DEVELOPMENT COMMITTEE Inquiry into the CFA’s Training$
Version: 1.3

Date: 23/02/2016

2154309_22\C

ENVIRONMENT, NATURAL RESOURCES AND REGIONAL DEVELOPMENT

COMMITTEE

Inquiry into the CFA’s Training College at Fiskville

FURTHER SUBMISSIONS OF THE COUNTRY FIRE AUTHORITY

Table of Contents

OVERVIEW AND CONTEXT ................................................................................................................................................. 2

Correcting misinformation – why it is necessary .................................................................................................................. 4

THE PERIOD BETWEEN 1970 AND 1999 ............................................................................................................................. 6

Correcting misinformation relating to the period between 1970 and 1999 ................................................................................ 6

May 1988 – the A.S. James Report ....................................................................................................................................... 6

1996 – 1999 (major PAD upgrade Vs the allegation of “shopping around” for scientific reports) ....................................... 8

Residential water at Fiskville .............................................................................................................................................. 10

The opinion of those at Fiskville in the period before the PAD was redeveloped ................................................................... 11

THE PERIOD BETWEEN 1999 AND 2006 ........................................................................................................................... 13

The development of firewater management plans ................................................................................................................... 13

Expert evidence called by the Committee - “foam contaminants, quite frankly are a very minor problem” ........................... 16

THE PERIOD BETWEEN 2007 AND 2012 ........................................................................................................................... 18

Correcting misinformation relating to the period between 2007 and 2012 .............................................................................. 18

2007 – The alleged Pseudomonas aeruginosa experiment .................................................................................................. 18

The alleged use of PFC containing foams after 2007 .......................................................................................................... 21

2010 Expert opinion on PFC risk ............................................................................................................................................. 23

THE PERIOD BETWEEN 2012 AND JANUARY 2016 ....................................................................................................... 24

Correcting misinformation relating to the period between 2012 and September 2015 ............................................................ 24

The allegation of “selective” testing ................................................................................................................................... 24

The PFOS levels of those at Fiskville ................................................................................................................................. 25

The evidence contradicting the Committee’s Interim Finding that PFOS is carcinogenic .................................................. 27

Addressing the Committee’s Interim Findings in relation to neighbouring properties........................................................ 28

The recycling of fire water in the period before October 2012 ........................................................................................... 31

The evidence relating to the presence of contaminants in the sludge of the Dam 1 settling pond ........................................... 33

A balanced consideration of the February 2012 ALS water report ..................................................................................... 35

The implementation of the IFI and environmental auditors recommendations ........................................................................ 36

The independent monitor’s assessment of the implementation of the recommendations .................................................... 36

The environmental auditor’s assessment of the remediation of the site .............................................................................. 37

Schedule 1 – Chronology of External Assurances given to the CFA that the Firefighting Water at Fiskville was Safe .......... 38

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OVERVIEW AND CONTEXT

1. In July 2012, the Country Fire Authority (CFA) published its response to the Independent

Fiskville Investigation (IFI) report “Understanding the Past to Inform the Future.”1 Among

other things, that response noted that:

“What took place at Fiskville, and to a lesser extent at our other [Regional Training

Grounds], was not good enough and we regret what happened. While we cannot

change what happened in the past, we can clearly demonstrate that we can learn

from past mistakes and we are committed to making changes to ensure the ongoing

health and safety of our people, along with our care for the environment.”2

2. The CFA is sorry to those whose trauma, sickness or injury was caused by their time at

Fiskville.

3. The CFA has attempted to demonstrate its remorse by accepting and implementing the IFI

recommendations, implementing a series of Board initiatives and working closely with the

EPA and its appointed auditor, Worksafe, independent experts and now the Environment,

Natural Resources and Regional Development Committee (Committee). The CFA will

continue to work closely with Worksafe in relation to its ongoing investigation.3

4. The CFA will also ensure that, just as it has in relation to the implementation of the

Committee’s Interim Recommendations that its response to any Final Recommendations is

guided by its ongoing commitment to demonstrating that it has learnt from what happened at

Fiskville. The CFA intends to continue to work hard to ensure that it never sees a repeat of

Fiskville.

5. This further submission is made by the CFA in response to a letter from the Committee dated

25 June 2015. In that letter, the Committee extended an invitation to the CFA to address “any

concerns it has as a result of evidence presented to the Committee” in the form of a further

submission. This further submission is made in addition to:

a. the CFA’s written submission to the Committee dated March 2015 (First CFA

Submission). The First CFA Submission focussed on the work that had been

1 Also known as the “Joy Report” by reference to the surname of the Chair of the Investigation, Professor Robert Joy 2 Also reproduced at First CFA Submission at p11 3 The fact that there is a current Worksafe investigation into the CFA in relation to matters arising at Fiskville was confirmed

in evidence by Ms Clare Amies, Chief Executive Officer of Worksafe Victoria who when giving evidence on 20 November

2015 said: “We have an ongoing investigation, so I don’t think it is appropriate for me to comment on a current

investigation.”: Transcript of oral evidence of Clare Amies, p17

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undertaken by the CFA following the completion of the IFI and the implementation

of the recommendations made as a result of the IFI;4

b. the CFA’s responses to the Committee’s various requests for documents and other

information.5 These requests have included details of CFA insurance policies, board

papers , details of Freedom of Information requests relevant to Fiskville, details of the

CFA’s reporting structures over time and expenditure in relation to Fiskville;

c. written answers addressing a series of specific questions posed by the Committee,

relevant to the Lloyd family who, since 1997, have occupied a farm adjacent to the

Fiskville site (Lloyd answers);

d. the evidence given to the Committee by the approximately 20 current and former

CFA officers and board members, relating to the matters being considered by the

Inquiry.

6. In these further submissions, the CFA focuses on correcting misinformation given in evidence

to the Committee and addressing matters arising from the Committee’s Interim Report,

published on 24 June 2015. The correction of misinformation focuses primarily on those

matters that were not otherwise dealt with in the First CFA Submission,6 the Lloyd answers

7

or in evidence. The addressing of issues arising from the Committee’s Interim Report deals

primarily with those matters referred to by the Committee which have been the subject of

further evidence, since the publishing of the Interim Report.

7. By taking this approach to its further submission, the CFA has been guided by the

Committee’s Interim Report. In that report, the Committee noted that it had not heard

evidence from the CFA or other relevant organisations, including the Environment Protection

Authority (EPA) and Worksafe.8 As the Committee noted, the second stage of hearings (of

which this further submission is part), is vital to ensuring that the Committee gains a

comprehensive understanding of the issues surrounding Fiskville.9

4 These submissions are expanded upon in the part of these submissions which deals with the period between 2012 and

January 2016 5 These requests having been made in the form of letters from the Committee to the CFA dated 10 February 2015, 2 March

2015, 18 March 2015, 15 April 2015, 27 May 2015, 3 July 2015, 8 September 2015, 25 September 2015 and 27 October

2015. 6 An example being the misinformation given to the Committee about the development of Water Quality Standards at

Fiskville. Whilst this is a matter which has already been dealt with in detail in Attachment 4 to the First CFA Submission,

including the involvement of the EPA, Department of Human Services and Worksafe in the development of these standards

this issue is further dealt with in this submission in the context of misinformation which has been provided 7 An example being the misinformation given to the Committee about the provision of information sought by the Lloyd

family 8 Interim Report pviii 9 Interim report pix. Whilst the CFA has sought to address all issues in this further submission, it notes that, notwithstanding

its various requests, it has not been provided with copies of all documents referred to by witnesses in the course of their

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8. The CFA submits that the Committee's approach to the matters the subject of these further

submissions must be contextual, with a recognition that the state of scientific knowledge

regarding contaminants such as perfluoroalkyl compounds (PFCs) and the standards of

workplace safety are not static, but were and are evolving. It would be erroneous to measure

and judge past CFA management practices at Fiskville and elsewhere against the knowledge

and standards of today

Correcting misinformation – why it is necessary

9. The Committee has heard a large amount of evidence about the presence of contamination at

Fiskville. In the past, unknown fuels were burnt and drums containing unknown substances

were both handled and buried on the site. Firefighting foams containing PFCs were also used.

These practices have resulted in the remnants of various substances being present at the site.

10. The way in which the CFA has gone about addressing the presence of these various

substances at Fiskville is considered in detail in the First CFA Submission. The Committee

has also heard evidence about those matters from witnesses, including the environmental

auditor, Mr Strudwick.

11. The acknowledged presence of certain substances at Fiskville has meant that the issue for the

Committee in this Inquiry has become less about whether certain substances are present at

Fiskville, and more about whether the presence of those substances resulted in practices that

were unsafe.

12. In that context, the presence of substances at Fiskville has been used by some witnesses as a

basis to provide the Committee with misinformation. In particular, the Committee has heard

evidence from witnesses including members of the United Firefighters Union (UFU) that:

“Since 1988 there has been a series of independent reports, some commissioned by the CFA

which have demonstrated clearly that the soil and water is contaminated.”10

Those witnesses

alleged that the CFA were aware as early as 1988 that the water used for firefighting at

Fiskville was contaminated and the CFA failed to act on that knowledge.

13. Whilst the CFA denies this allegation, the Committee indicated in its Interim Report that it

wished to consider these issues further.11

14. The misinformation provided by UFU members about the firewater at Fiskville forms the

basis of other submissions by the UFU.12

Those submissions seek recommendations that the

evidence. There have also been a number of confidential submissions made to the Inquiry which have not been provided to

the CFA 10 Transcript of oral evidence of Mick Tisbury, p168 11 Interim Report p 57

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CFA board be reconstituted and there be a prosecution of all those involved in Fiskville from

2011 to present, including those involved from CFA, MFB, Worksafe and the EPA.13

15. Whilst many of the allegations which have been made by the UFU pre-date the tenure of the

current CFA board and senior management, the nature of the allegations which have been

made by the UFU, the misinformation upon which they are based and the conclusions sought

to be drawn from them, make it incumbent on the CFA to address those allegations.

16. In this further submission the CFA addresses the misinformation provided to the Committee

by identifying the evidence which contradicts the allegations made.

12 See unnumbered PowerPoint slide of Peter Marshall entitled “UFUA Submission” 13 See unnumbered PowerPoint slide of Peter Marshall entitled “The UFU Recommends”

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THE PERIOD BETWEEN 1970 AND 1999

18. The Committee’s terms of reference require the Committee to consider events from 1970 to

the present.14 CFA purchased Fiskville in 1971.15 The Practical Area for Drills (PAD)

commenced operation in 1974.16

19. The issues arising in the period between the commencement of PAD operations in 1974 and

1999 were those first raised in the media in December 2011. Initially those issues were

punctuated by allegations relating to the collection and burning of unknown fuels for the

purpose of hot fire training on the PAD and the burying and handling of drums containing

those unknown fuels. These were the issues that caused the CFA to commission the IFI.

20. The IFI concluded, among other things, that whilst the precise nature of what was burnt in

this period will never be known,17 the practice of burning unknown fuels ceased when the

PAD was upgraded in 1996.18

It also concluded that despite its best endeavours including

through the use of ground penetrating radar, it found no evidence of buried drums remaining

on the Fiskville site19

as at 2012, when the IFI was conducted.

21. Through the work of the IFI, additional issues were identified as requiring further

investigation. Those additional issues related to the legacy effects of burning unknown

substances and using firefighting foams containing perfluorooctane sulfonate (PFOS). These

legacy effects continued to be relevant to the Fiskville site mostly because of the practice of

recycling the water that was used in firefighter training.

Correcting misinformation relating to the period between 1970 and 1999

May 1988 – the A.S. James Report

22. The first example of misinformation being provided to the Committee about events which

occurred between 1970 and 1999 arises in the context of the evidence the UFU witness Mr

Tisbury gave about a scientific report dated May 1988 from A.S. James Pty Ltd.20

In his

14 Terms of Reference 1 15 IFI Report p37 16 IFI Report p37; CFA 29th Annual Report, 30 June 1974, CFA Melbourne, CFA.3151.5000.001.0287 17 IFI Report p9. What is known about these materials is derived almost exclusively from the interviews conducted with

former Fiskville staff and trainees, in the context of the IFI Report. These matters are considered in detail in chapter 5 of the

IFI Report. This is also a conclusion which was specifically referred to and thereby confirmed by the EPA in its submission

to the Committee, See EPA submission p1 18 IFI Report p121; CFA.3151.0006.015.0003 19 IFI Report p12, 13, Cardno Aus Pty Ltd, CFA Training College Fiskville Ground Penetrating Investigative Report, 2012,

Cardno Australia Pty Ltd: Melbourne. These findings have been further confirmed by investigations carried out in the

context of implementing recommendations 7, 8 and 9 of the IFI which found no evidence of there being buried drums

remaining at Fiskville. See Kieran Walshe, Independent Monitor – Fiskville Report, July 2015 pp23,24 20 CFA.3437.0005.002.0215

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evidence, Mr Tisbury said that this report related to “contaminated dam water”21

and that it

stated that “this risk is not acceptable and the materials must be removed from the site and

disposed of in a suitable manner.”22

23. The allegations made by Mr Tisbury in relation to this report are the product of

misinformation.

24. In that regard, a proper analysis of the A.S. James report reveals that:

a. it does not relate to “contaminated dam water”23

at all. Rather, it relates to the issue

of buried drums and was commissioned specifically in the context of the allegations

made by Mr Alan Bennett from whom the Committee heard evidence on 27 July

2015;24

b. rather than stating, as the Committee was told, that “this risk is not acceptable and

the materials must be removed from the site and disposed of in a suitable manner”

[emphasis added], the report in fact states that:

i. little contamination of the soil adjacent to the buried drums has occurred;

ii. future contamination by these drums is possible and that possibility could be

managed by forming an “umbrella” over and around the storage area;

c. the report in fact recommends in relation to these buried drums that: “If this risk is

not acceptable then the materials should be removed from the site and disposed of in

a suitable matter.”25

[emphasis added]

25. Removal of the drums is precisely what occurred26

as is confirmed by contemporaneous

evidence provided to the Committee in the form of a letter dated 12 November 1991.27 That

contemporaneous evidence notes, among other things, that removal of the drums was

completed in mid-January 1991 by a recognised firm of waste processors.

26. In the circumstances, the evidence given to the Committee in relation to this report by Mr

Tisbury does not support the recommendations sought by the UFU.28

21 Transcript of oral evidence of Mick Tisbury, p168 22 See Mr Tisbury’s PowerPoint slide 6 23 Transcript of oral evidence of Mick Tisbury, p168 24 IFI Report p104 25 CFA.3437.0005.002.0215 at [0218] 26 IFI Report p115 27 CFA.3151.9000.041.1830 28 See unnumbered PowerPoint slides of Peter Marshall entitled “The UFU Recommends”

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1996 – 1999 (major PAD upgrade Vs the allegation of “shopping around” for scientific

reports)

27. The second instance of misinformation provided to the Committee by Mr Tisbury in relation

to the period between 1970 and 1999 relates to a number of scientific reports which were

produced in the period between 1996 and 1999.29

28. In relation to these reports, Mr Tisbury made a number of statements which did not accurately

reflect the content of each of the individual reports.30 After doing so he alleged that:

“What you can see is a fair bit of shopping around. You don’t like the answer you get

from one mob so you go to another mob, and they give you the same answer, so you

keep going to another one, and you do nothing about it. It just beggars belief.”31

29. Contrary to this evidence, a proper analysis of the contemporary documents and the previous

consideration this issue was given by the IFI shows that:

a. rather than being evidence of “shopping around”, the period between 1996 and 1999

represents a period of time when the CFA sought to actively engage with regulators

and consultants to seek to understand and address health, safety and environmental

issues at the site.32

Various expert reports were produced accordingly;

b. as the IFI put it, from March 1995, the Structural Fire Safety Department began to

consider Fiskville’s compliance with the Dangerous Goods obligations that existed at

the time.33 As part of that process, a number of deficiencies were identified and as a

result:

“In early 1996 a Fiskville Instructor was tasked to undertake a review of dangerous

goods, occupational health and safety and environmental issues at Fiskville…The

instructor reviewed previous audits, reports and notices, commissioned significant

further investigations and actively engaged regulators, particularly EPA and [the

then Health and Safety Organisation] to ensure the site was in compliance with

29 Transcript of oral evidence of Mick Tisbury, p168-169 30 The CFA notes that in the course of making the “shopping around” allegation, Mr Tisbury quoted selectively and at times

inaccurately from a number of the specific expert reports and other documents produced in the course of the major PAD

upgrade. These reports included what Mr Tisbury described as “key correspondence from the EPA,” the “1996 Mineco

Report,” the “1996 Diomides Report” and the “1996 Coffee Report” 31 Transcript of oral evidence of Mick Tisbury, p169. In the context of this evidence, Mr Tisbury also provided the

Committee with a series of PowerPoint slides which purported to quote from the various reports 32 IFI Report p77, Dangerous Goods Occupational Health & Safety Environmental Audit 1996, CFA: Melbourne,

CFA.31510006.015.0003, IFI Report p119-123 33 IFI Report p119-120

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regulatory requirements. These included assessments of soil, surface water and

ground water contamination.34

30. The review undertaken in 1996 was referred to by some members of the Committee during

the hearings as the “Clancy Review,” being a reference to the CFA Fire Officer who prepared

the various internal CFA documents which were produced by reason of this review.35

31. This review resulted in a series of immediate changes to the way Fiskville operated, including

decisions being taken to:

a. on 27 May 1996, close the flammable liquids PAD, effective immediately;36

b. upgrade the PAD (it was not reopened until September 1999);37

c. no longer accept fuel in unidentified drums;

d. provide Material Safety Data Sheets and label all dangerous goods;

e. issue a series of directives requiring compliance with safety procedures for the

storage and transportation of dangerous goods;

f. issue a directive that hydrocarbon waste from the flammable liquid PAD not to be

dumped into the surrounding environment;38 and

g. establish an OH&S Committee,39

who contacted the EPA and sought advice on

specific issues including groundwater testing and issues of landfill.40

32. It was immediately after these changes occurred that the various scientific reports that were

referred to individually by Mr Tisbury were produced. The production of these reports was

part of a process by which the CFA sought to better understand and then address the issues

that had been identified.

33. This process culminated in the CFA obtaining expert advice about the efficacy of the

measures which had been implemented to address the concerns that had been identified. This

included expert advice about the efficacy of the water recycling system used at Fiskville.

34 IFI Report p121, citations omitted 35 See for example CFA.3437.0001.001.0206 36 See memorandum to all Fiskville Staff, CFA.3342.0013.004.0241 37 IFI Report p123, CFA, Annual Report, 1999/2000: Melbourne CFA.3151.5000.004.0293 38 IFI Report p121 39 IFI Report p121; OH&S Committee, Meeting Minutes, 25 July 1996, CFA.3342.0001.006.0473 40 See for example, relevant correspondence: CFA.3151.0001.311.0239; CFA.3437.0005.001.0612;

CFA.3437.0005.001.0418.

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34. The advice that the CFA obtained about the efficacy of the water recycling system at this time

was contained in the report that was produced to the Committee and was referred to by Mr

Tisbury in his evidence as the “1998 GHD report.” 41

35. In his evidence, Mr Tisbury told the Committee that this report: “Found extensive &

significant contamination of dams 1 & 2.”

36. Contrary to this evidence, rather than being a report relating to an investigation of

contamination levels, this report was prepared because GHD was commissioned by the CFA

to prepare a functional design followed by a detailed design for an upgrade for the PAD at

Fiskville.42 This report noted that the design of the redeveloped PAD had sought to meet the

requirements of both the Office of Gas Safety and the EPA.43

37. Among other things, this report considered the process by which firewater was to be recycled

following the upgrade of the PAD. That consideration occurred in the knowledge of historical

contaminants, the ongoing presence of contaminants in Dam 1 and B-Class foams would

continue to be used as part of PAD operations.44

38. In that context, GHD concluded that the firefighting water recycling system was appropriate

and appeared to be sufficient.45

It further noted, based on a survey of other facilities that were

operating in other Australian states at the time, that:

“1. Training facilities in other states typically use simple systems e.g., drying basis,

to treat the fire fighting waste water…

2. None of the facilities surveyed used aerators. We understand that aerating at

Fiskville has improved effluent quality and we recommend that this continue…”46

39. In the circumstances, when properly considered in its totality, the evidence does not support

the allegation of “shopping around” for scientific reports. The CFA simply sought to

comprehensively address the issues which had been identified and implement a PAD design,

including waste water treatment system that addressed those issues.

Residential water at Fiskville

40. A number of witnesses gave evidence to the Committee about the water supplied to the

residential facilities at Fiskville in the period between 1974 and 1999. Much of this evidence

41 CFA.3437.0003.001.0001 at 0006 42 CFA.3437.0003.001.0001 at 0006 43 In relation to the requirements of the EPA, see, for example, CFA.3437.0003.001.0001 at 0007 and

CFA.3437.0003.001.0001 at 0013. 44 CFA.3437.0003.001.0001 at 0012 45 CFA.3437.0003.001.0001 at 0024 46 CFA.3437.0003.001.0001 at 0023

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confused the issues relating to firewater with those relating to residential water. The

suggestion being that the issues relevant to the recycling of firewater were also relevant to the

issues relating to the provision of residential water.

41. The CFA submits that the Committee should be careful not to perpetuate this confusion.

Rather, it is submitted that the Committee should note the succinct description of the

difference between the firewater and residential water given by the former CFA PAD

instructor and later PAD supervisor, Kenneth Lee. Mr Lee was present at Fiskville between

1979 and 1999. He said in his evidence that:47

“…recycled water was only on the fire training ground. It was not at the houses or

down where they slept or anything like that. It was only recycled within the fire

training ground.

…

As for Ballan water being brown and dirty, that happened in Ballan. It had an old

reservoir, Ballan, and it had very dirty water. Fiskville was no different to any of the

streets around or the town or anything else. They all used to suffer with very dirty

water there…”48

42. The evidence about recycled fire water should not be confused with the evidence relating to

residential water.49

The opinion of those at Fiskville in the period before the PAD was redeveloped

43. The events that occurred in the period between the establishment of the PAD in 1974 and its

closure for redevelopment in 1996 are difficult to reconcile with modern standards of

occupational health and safety, the handling of dangerous goods and environmental

protection.50 As the EPA submission to the Committee puts it: “Clearly, past practices were

not consistent with the current comprehensive legislation and operational policies…”51

44. That is not to say however that the issues arising in this time were considered in the same way

as they are today.

47 Mr Lee worked as a PAD instructor and later PAD supervisor at Fiskville between 1979 and 1999. See Transcript of oral

evidence of Kenneth Lee, p76 48 Transcript of oral evidence of Kenneth Lee, p79; Also see the evidence of the former Fiskville Primary School student

David Card at Transcript of oral evidence of David Card, p46 49 See for example the Transcript of oral evidence of Deborah and Kevin Etherton, p38, Transcript of oral evidence of Diane

Potter, p14 and Interim Report p52 50 This was a specific finding of the IFI, see IFI Report p47 51 EPA Submission p2

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45. In that context, the Committee has heard evidence about the extent to which the matters that

were identified at Fiskville gave rise to concerns, at the time. Overwhelmingly, that evidence

indicates that what occurred at Fiskville in the period between 1974 and 1996 was not

considered with the same degree of seriousness as it is today.52

46. In the circumstances, the CFA submits that the Committee should be careful not to apply

modern standards to historical allegations. Any criticism which seeks to do so has the

potential to unfairly assign a degree of knowledge which, either did not exist or was not

considered with the same importance as it is today.

52 This includes relevant evidence from the IFI such as the evidence from an unnamed former Chairman of the CFA who

noted that because the CFA Board included volunteer representatives; “if one of them saw that there was some health issue

emerging, they would have been on it…” (IFI report p124, Chapter 9, endnote 52); the evidence of the former CFA PAD

Instructor Kevin Etherton who worked at Fiskville in the period before 1988, see Transcript of oral evidence of Deborah and

Kevin Etherton, p35-36: “…when the offer came along to burn slops at basically no cost I guess they jumped at the

chance…hindsight. What a wonderful word…. If we knew then what we know now, obviously it would be a lot different.” ;

the evidence of Alistair Allan, an employee of the petro-chemical industry who attended Fiskville for Training during the

1980s, Transcript of oral evidence of Alistair Allan, p29-30: “…at that stage, back in the 80s, nobody thought that the

contaminated fuel, or the slops that were used, would have the effect that we are now seeing. It was just not recognised… I

do not think anybody thought of it as being an issue at that time, but we now know better”; Similar evidence was also given

by others including David Card, a former pupil at the Fiskville school who said: “It is reflective for me to look at it. At the

time the doctors were not saying that to me. I developed asthma…but the doctors were not saying to me, ‘you have asthma

because you go to school at Fiskville’. It was ‘you have asthma because you are a growing kid and this is what happens’…”,

see Transcript of oral evidence of David Card, p36; John Cutler, a neighbour and contractor to the site who said in answer to

a questions: “During those years did you feel that there was anything that you needed to alert people to? Was it just business

as usual for you?” said “Business as usual.” See Transcript of oral evidence of John Cutler, p57; Additionally, the

Committee heard from Brian Whittaker, former MFB Commander, who spoke of earlier attitudes where it was not seen as a

concern to breathe in smoke when firefighting, and that advancements have been made in the last 10 to 15 years in

understanding the associated dangers See Transcript of oral evidence of Brian Whittaker, p4. Also see EPA submission p3

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47. After the PAD re-opened in 1999 following its major redevelopment, only LPG, unleaded

petrol and diesel was burnt in hot fire training.53 There was also a greater emphasis on risk

reduction through minimising exposure via inhalation or skin contact with smoke, foam and

recycled firewater.54

48. At the same time however, firewater together with B-Class foam at Fiskville continued to be

used in much the same way as it had prior to 1999. Whilst dams were added55 and unknown

fuels were no longer burnt, the practice of recycling firewater continued.

49. Whilst there were no specific instances of misinformation being provided to the Committee

about events which occurred in the period between 1999 and 2006, an important event did

occur during this period which is relevant to the matters which are the subject of

consideration by the Committee. That event was the development and subsequent

implementation of firewater management plans at all of the CFA’s training facilities,

including Fiskville.

The development of firewater management plans

50. During 2005, the CFA took proactive steps to retain Wynsafe Occupational Health Services

to assess the quality of firefighting water at CFA training grounds, including Fiskville. This

assessment was designed to consider potential impacts on the health of personnel and the

environment and to make recommendations for the ongoing management of the issue. The

subsequent report produced by Wynsafe entitled “Assessment of Firefighting Water at CFA

Field Training Grounds” has been provided to the Committee.56

51. Insofar as it relates to both Fiskville and more generally, this report referred to results from

testing of water supplies in 2005 and notes that:

The results to date show that there is no significant threat to the health of personnel

using firefighting water at the training grounds tested…57

Based on the results of sampling carried out by Wynsafe, and on previous testing

available, it is considered that personnel exposed to firefighting water at training

grounds should not suffer any adverse health effects from such exposure.

53 IFI report p 7 54 IFI Report p42. This shift to a more safety focused culture is noted to have increased even further following the 2002

Linton Bushfire tragedy 55 See the discussion at IFI Report p41 56 See for example CFA.3151.0002.300.0345 57 CFA.3151.0002.300.0345 at .0358

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To provide further data to verify this conclusion, the 12 month testing schedule as set

out above should be implemented.”58

52. After the 12 month testing schedule had been implemented, fire water management plans

were developed in relation to all CFA training grounds.

53. The plan that was subsequently developed in relation to Fiskville notes, among other things,

that:59

“In October-November 2005, CFA commissioned a report into the quality of water

used for firefighting training that CFA Field Training Grounds. This report examined

and assessed the potential impact on health of personnel and the environment and

made recommendations for the ongoing management of the identified issues.

This report was followed up with a second report…

…

CFA Fiskville has a series of Dams on its premises as well as a “Pit”.

Water for the main firefighting supply is pumped from the Pit which is filled from the

town water supply to the main hydrants on the PAD. Water from Dam 2 can also be

diverted into the pit. Water for the backup water supply is pumped from Dam 2.

Once used on the fire ground, the water flows back into Dam 1 via a triple

interceptor which is serviced every 12 months. Possible contaminants on the fire

ground are foam and hydrocarbons. Possible contaminants in Dam 1 are faecal

matter from wildlife and contaminants from the fire ground. Possible contaminants in

Dam 2 are faecal matter from wildlife and contaminants from the fire ground as Dam

1 and Dam 2 are connected via a channel containing 300mm of crushed scoria…

…

Water is not to be used if:

• Water is visibly contaminated

• Water gives off an unpleasant odour

• Any person complains of irritation or other health effects after using the

water

• Scheduled testing has not been carried out

58 CFA.3151.0002.300.0345 at .0359 59 CFA.3151.8010.010.3535

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• Unacceptable analytical test results are received

NOTE: If any of the above conditions apply, then:-

• Isolate and tag out the suspected tank

• Use other sources of water if available

• Take a water sample for analysis

• Take steps, if necessary, to correct any contamination i.e., by flushing out the

tank or treating with disinfectant products

• Advice or assistance from water treatment company as necessary

…

Protections of health of personnel using firefighting water:

1. All personnel (staff, firefighters, commercial clients, etc) must wear turnout

clothing and equipment as outlined in the SOP relevant to the PAD area being

used.

2. Water must not be used if any of the conditions, as listed [above]…exist.

3. If water analysis results indicate that the water is not to the agreed standard then

the storage and location is to be immediately isolated and tagged out.

4. Notify the following

i. Manager, CFA Fiskville

ii. PAD supervisors

iii. Site Health and Safety representative

iv. All staff

5. Provide a copy of the test results to:

i. Manager, CFA Fiskville

ii. PAD supervisors

iii. Site Health and Safety representative

iv. Staff notice board

6. Use other source of water

7. Investigate cause

8. Determine course of action to rectify problem – i.e:

i. Take steps to correct any contamination, like flushing out storage

tanks, or treating with disinfectant products.

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ii. Seek advice or assistance from water treatment company.

9. Acceptable test results must be obtained before any tagged out water source can

have the tag out removed.”

54. The Committee heard evidence about the operation of this plan at Fiskville. The evidence in

that regard included evidence from Mr James Stitz who was responsible for the development

and implementation of the plan.60 It also included the evidence of Mr John Myers, the

supervisor of the PAD who said he followed the plan.61

For his part Mr Jeff Green, gave

evidence that as a CFA Occupational Health and Safety Manager he expected the plan to be

followed.62

55. The CFA respectfully submits that any consideration by the Committee of the safety of the

firewater used at Fiskville must necessarily consider the details of the Water Management

Plan and the evidence of the manner in which it was utilized at the Fiskville site.

Expert evidence called by the Committee - “foam contaminants, quite frankly are a very minor

problem”

56. Whilst the water management plan sets out the strategy the CFA adopted for dealing with

most of the contaminants which might have been present in the firefighting water at Fiskville,

the Committee has also been concerned about the presence of contaminants not considered by

that Management Plan.

57. In that regard, it is noted that, the Water Management Plan did not have regard to the possible

presence of PFOS in the water. In relation to the relative risk associated with that issue, the

CFA notes that there is a body of evidence before the Committee. That evidence includes the

evidence of Dr Drew, Professor Ackland, Dr Lester and Professor Priestly. It also includes the

evidence of the expert advice CFA obtained in 2010 about the PFOS risk at Fiskville

(described below under the heading “2010 Expert opinion on PFC risk”).

58. In addition to that evidence however, there is also the evidence of the witnesses Dr Roger

Klein and Mr Nigel Holmes. These experts were called by the Committee, independent of the

CFA, because of their expertise in the areas of environmental contamination, caused by

firefighting foam.

60 Transcript of oral evidence of Lex De Man, James Stitz and John Myers, p28 61 Transcript of oral evidence of Lex De Man, James Stitz and John Myers, p4 62 Transcript of oral evidence of Jeff Green (28 January 2016), p8-9

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59. When giving their evidence, Dr Klein and Mr Holmes compared the relative risks associated

with the past practices of burning unknown fuels (for which the Water Management Plan was

in part designed to address) to that which exists by reason of the legacy effect of the historical

use of firefighting foams containing PFOS.

60. In that context, Dr Klein gave evidence that:

“When we come to the Fiskville situation, as I understand it, there are a whole range

of contaminants there, of which the foam contaminants, quite frankly, are a very

minor problem, because I gather the fire training ground was used as an incineration

site for industrial waste solvents of unknown composition [i.e., the hydrocarbons

referred to in the Water Management Plan]…in terms of what we know about

toxicity, I would be far more worried about dioxins, polychlorinated biphenyls and

polycyclic aromatic hydrocarbons…In terms of doing a risk assessment, as I said, the

PFOS and the PFOA, yes, they are a risk but they are nothing compared with the

others…”63

61. As was made clear to the Committee, the incineration of “industrial waste, [and] solvents of

unknown composition” ceased at Fiskville in 1996. Any effect they might have had after 2005

was considered and managed pursuant to the provisions of the Water Management Plan that

was in place at Fiskville.

63 Transcript of oral evidence of Roger Klein and Nigel Holmes, p237-238

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62. A number of important developments occurred in the period between 2007 and 2012, namely:

a. as the knowledge of the risks created by PFCs continued to grow and evolve, in 2007,

the CFA ceased using PFOS containing B-Class AFFF firefighting foam;

b. in December 2011 the CFA became aware, through newspaper reports, of the

allegations of past practices at Fiskville; and

c. as a result of the allegations made in newspaper reports, in December 2011, the CFA

commissioned the IFI.

Correcting misinformation relating to the period between 2007 and 2012

63. Similar to the period between 1974 and 1999 referred to above, there are a number of specific

allegations arising during the period between 2007 and 2012 that are the product of

misinformation. Those matters arose from the evidence of Mr Tisbury of the UFU who gave

evidence to the Committee on 15 June 2015. 64

2007 – The alleged Pseudomonas aeruginosa experiment

64. In particular, the Committee heard evidence from Mr Tisbury that:

“In February 2007, there is an Ecowise report. This report was the first report that I

saw where all of a sudden the CFA started testing for this stuff called pseudomonas

aeruginosa. It was found in dam 1 only. The safe levels of this organism – sorry, for

this toxic bacteria – in water, according to the Australian water guidelines, is less

that 10 organisms per 100 millilitres. The results show that the tests on the water that

they took out of dam 1 was 33 000 organisms per 100 millilitres. Training was not

stopped. Our people were still being exposed to this water.”65

65. Mr Tisbury continued:

“…I started having these suspicions that maybe it has been introduced into the water.

Nobody had heard about it. The eighth company I called was a mob called ALS. I

have since found out that ALS bought Ecowise. I spoke to a bloke there named Brad

Snibson. He was a scientist. He told me that he was part of an experiment with CFA

where they deliberately introduced pseudomonas aeruginosa into the water supply as

a biological way of cleaning up the hydrocarbons in the water.”

64 Transcript of oral evidence of Mick Tisbury, p168 65 Transcript of oral evidence of Mick Tisbury, p 169

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66. Mr Tisbury’s evidence in relation to this matter was contradicted by other witnesses who gave

evidence to the Committee. Those witnesses included:

a. Mr Peter Rau, the MFB Chief Officer. Mr Rau’s evidence in relation to this matter

was that he was at Fiskville at the time of this allegation. He said that the location at

which this test was conducted (the Dam 1 settling pond) was not a water source used

in firefighter training. He also said that the testing referred to by Mr Tisbury had

occurred at a time when no training was being conducted and there was a major

drought. He gave evidence that at about the same time as this reading occurred, the

MFB “blue helmet” course materials advised MFB personnel not to use water from

Dam 1 whilst at Fiskville;66

b. Mr John Myers, the CFA PAD supervisor gave evidence which corroborated the

evidence of Mr Rau, particularly to the extent that the water in the Dam 1 settling

pond was not used for Firefighter training.67

67. Mr Tisbury’s evidence about the alleged 2007 “experiment” is also contradicted by the

contemporary scientific evidence which was produced at the time the allegation was said to

have occurred.

68. In that regard, as was noted above, in 2005, the CFA commenced the process of developing

Water Management Plans. Part of these plans was to test for the presence of pseudomonas

aeruginosa.

69. As part of the implementation of the management plans, a report was produced by Wynsafe in

October 200768 (8 months after the alleged “experiment”). The purpose of that report was to

review the test results carried out at training grounds since the 2005 report and make further

recommendations for the ongoing management of firefighting water at CFA training

grounds.69

70. In revisiting the water testing results, Wynsafe considered the February 2007 analytical data

that was referred to by Mr Tisbury during his evidence.70

71. In doing so, Wynsafe did not alter the earlier opinion that it had given that in 2005 that:

66 Transcript of oral evidence of Peter Rau, p5-6 67 Transcript of oral evidence of Lex De Man, James Stitz and John Myers, p8 68 CFA.3151.7008.017.0454 69 CFA.3151.7008.017.0454 at .0456 70 CFA.3151.7008.017.0454 at .0457

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“Based on the results of sampling carried out by Wynsafe…it is considered that

personnel exposed to firefighting water at training grounds should not suffer any

adverse health effects from such exposure.”71

72. This conclusion is hardly surprising when one considers, as is noted in the 2005 Wynsafe

report and was noted by witnesses such as Mr Rau, Mr Myers and others, that firefighting

water was not drawn from Dam 1 (being the dam with the elevated pseudomonas aeruginosa

reading), but rather from the Pit which was filled from the town water supply and, if

necessary, could also be filled from Dam 2. 72

73. In those circumstances, the results most relevant to the issues being considered by the

Committee (and Wynsafe at the time) were those from the Pit and Dam 2. Those results have

been extracted from the relevant report and appear in the image immediately below:73

74. As is evident from this extract, the pseudomonas aeruginosa reading for Dam 2 at the time of

the alleged “experiment” was zero.

75. In addition to the contradictory evidence heard by the Committee and the contemporary

scientific evidence, the CFA also notes that Mr Snibson (a person who, according to Mr

Tisbury was part of the alleged experiment) has made a submission to the Committee.74

That

submission emphatically refutes Mr Tisbury’s allegations on this topic and confirms that Mr

Snibson’s only involvement in Fiskville was to receive and test samples and supply objective

analytical results to the CFA. 75

76. In the circumstances, the CFA submits that it would be inappropriate for the Committee to

make any findings in relation to the allegations made by Mr Tisbury, insofar as they relate to

the alleged “experiment” to introduce pseudomonas aeruginosa into the water at Fiskville.

71 CFA.3151.0002.300.0345 at .0359 72 CFA.3151.0002.300.0345 at .0352 73 CFA.3151.0002.300.0345 at .0357 74 entitled “Counter Submission to #446 (Michael Tisbury) and relevant transcripts.” 75 Submission No 464

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The alleged use of PFC containing foams after 2007

77. The Committee’s Interim Report states that in 2007, “Fiskville discontinue[ed] the use of

foams containing PFOS. Subsequently used foams containing other PFCs.”76

This finding

appears to have been made on the evidence of Dr Roger Klein and Mr Nigel Holmes when

they gave evidence to the Committee on 18 June 2015. In the course of that evidence Dr

Klein said:

“I actually spoke at Greenvale fire station within 20 minutes of landing at

Tullamarine and one of the things that turned up was that it did appear that the

Country Fire Authority was still using PFOS foam.”

78. According to Dr Klein he was told this information in the week prior to giving his evidence.

When asked who had told him this information he said that he and his colleague Nigel

Holmes “were in a meeting with a range of fire service officers. I could not be specific who

said it.”77

79. With respect, this statement is not supported by the evidence.

80. In 2007, the CFA moved to a variety of firefighting foam known as “Tridol”. That firefighting

foam is marketed as being PFOS and PFOA free. This proposition is supported by:

a. the evidence of the environmental auditor Daryl Strudwick, who gave evidence to the

Committee on 25 May 2015. In his report, he noted that foams containing PFCs have

not been used at the Fiskville Site since 2007;78 and

b. an independent analysis by ALS that was commissioned by CFA by reason of the

Committee’s Interim Finding.79 The results page from that independent analysis is

immediately below:

76 Interim Report px 77 Transcript of oral evidence of Roger Klein and Nigel Holmes, p237 78 AECOM, Environmental Audit Report – Risk to Land, Surface Water and Groundwater – CFA Fiskville Training College,

EPA Victoria, Melbourne, 2014, p6. Also cited at Interim Report p14, Mr Strudwick gave evidence to the Committee on 25

May 2015. 79 Interim Report px

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The results of that analysis are that:

i. there is either no PFOS in Tridol or, if there is, it is present at a level that

cannot be detected;

ii. in Tridol concentrate there is negligible quantities of PFOA (measured in the

concentrate at 182 parts per billion) which would be further reduced when the

concentrate is mixed with water so that it can be used in firefighting

operations.

81. In addition to the analysis that occurred after this allegation was made in the Interim Report,80

the CFA has made inquiries of relevant staff members. Those staff members have confirmed

that they have no knowledge of the use of PFOS containing foams by any CFA brigade after

2007 and that any unidentified foam which may have been present at CFA brigades by reason

of those brigades accepting donated foam products was destroyed using high temperature

incineration.

80 Interim Report px

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2010 Expert opinion on PFC risk

82. Whilst the Committee heard evidence from Dr Drew, Professor Priestly, Professor Ackland,

Dr Lester and Dr Klein about the relative risks associated with the presence of PFOS, the

CFA notes that it was also pro-active in assessing any legacy effects that might have existed

at Fiskville after 2007, when the use of PFOS containing firefighting foam ceased.

83. In that regard, more than two years before the issue of PFC risk was identified by the IFI, the

growing concern about the presence of PFCs in the environment generally caused the CFA to

obtain the advice of independent experts on whether PFCs were present in the recycled

firewater at Fiskville and, if so, whether such presence presented an adverse health risk.

84. That independent advice is set out in a report by Wynsafe entitled “Perfluorochemicals in the

firefighting water used at Fiskville”.81 In that report, the analytical results showed the

presence of both PFOS and perflurooctane acid (PFOA) in each of the Pit, Dam 2 and

Pumper 3. In relation to these results however, the report notes, among other things, that:

Although levels measured for PFOS and PFOA were above the USEPA advisory

levels for drinking water (no standards or guidelines are currently available for

occupational exposures), it can be shown that the estimated exposures will produce

daily intakes several hundred times lower than the recommended Tolerable Daily

Intake (TDI) for both PFOS and PFOA. This was based on the highest result which

was for the Pit…The result for the Pit can also be considered as a worst case

scenario as the PAD had been used for a recruit training course the day before

sampling and runoff containing foam from the PAD had flowed back into the Pit.

It is considered that if current Standard Operating Procedures (SOP’s) are

followed, and related Personal Protective Equipment (PPE) is used, personnel will

suffer no adverse health effects from exposure to PFOS and/or PFOA in the

firefighting water…”82 [emphasis added]

85. The Committee has heard no evidence that contradicts this contemporary expert opinion.

Furthermore, that opinion has subsequently been corroborated in evidence before the

Committee from witnesses including the Toxicologist Dr Roger Drew83

and the Principal Risk

Assessor Kristi Hanson.84

81 CFA.3437.0005.002.0030 82 CFA.3437.0005.002.0030 at 0034 83 Transcript of oral evidence of Roger Drew, p 14-15. 84 Transcript of oral evidence of Douglas Ahearne, MrMichael Rehfisch and Kristi Hanson, p13-14. See in particular the

evidence of Kristi Hanson.

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THE PERIOD BETWEEN 2012 AND FEBRUARY 2016

86. The period between 2012 and February 2016 begins with the handing down of the IFI report

and ends at the date that these submissions were provided to the Committee. The reason for

choosing February 2016, rather than 26 March 2015 (the date that the Fiskville site was

permanently closed) is because the CFA’s work to correct past conduct that occurred at

Fiskville has not ended with the closure of the site.

Correcting misinformation relating to the period between 2012 and September 2015

The allegation of “selective” testing

87. When Mr Tisbury gave his evidence to the Committee on 15 June 2015, he alleged that:

“…the testing they have done at Fiskville, the ground soil testing, the boring and all

that, it is not the whole site. They have not tested the whole site. It has been selective.

CFA told the people from Cardno Lane Piper where they could and could not drill –

where they could and could not test. I know that mound with all the drums up in the

top corner near the walking track; that has not been tested. Somebody from Cardno

Lane Piper told me that they wanted to test it and they were told they were not to test

there.”85

88. When he was later asked by the Committee: “Are you able to assist this inquiry specifically

with identifying anyone to the committee that has given those directions?”86

Mr Tisbury

replied:

“I used to get a lot of anonymous phone calls because I ended up becoming the

spokesperson on this, so I got a lot of anonymous phone calls from people saying

stuff. One was a Cardno Lane Piper employee, and he said he could not give me his

name because he would do his job (sic). I asked him to put a submission in to this

committee confidentially or do it in camera, and I am hoping he has but I do not

know whether he has or not.”87

89. In the context of that evidence, the CFA notes that it has commissioned a number of reports in

response to the IFI. While the scope of investigations was responsive to the IFI and other

concerns, none of these reports indicate that the testing of the site was conducted in a

selective manner. Rather, these reports were:

85 Transcript of oral evidence of Mick Tisbury, p175 86 Transcript of oral evidence of Mick Tisbury, p176 87 Transcript of oral evidence of Mick Tisbury, p176

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a. conducted by independent scientists in accordance with the relevant accepted

standards or guidelines. The methodology and sampling locations are generally

described in their respective reports;88

b. the work of these scientists has been the subject of independent review in the course

of:

i. the work of the EPA-appointed environmental auditor Mr Strudwick, from

whom the Committee heard evidence on 25 May 2015; and

ii. the Independent Monitor’s assessment of the implementation of the

recommendations of the IFI. The Independent Monitor’s report being

Attachment A to this further submission;

neither of these independent reviews identified any evidence of “selective testing.”

90. In the circumstances, the CFA submits that there is no evidence which can properly support

this allegation.

The PFOS levels of those at Fiskville

91. Media reports in relation to Fiskville have contained misinformation about the levels of PFOS

in the serum of those who had interacted with Fiskville. In particular on 28 June 2015, the

Herald Sun published an article entitled “Our Neighbours from Hell.”89 Among other things,

that article alleged that those living close to Fiskville had PFOS levels in their serum that

were “10 times higher than they should have been”. The article also alleged that the one

person’s results were “through the roof.”90

92. The Committee has been careful to explore the allegations contained in this newspaper article.

It has done that in two ways. First through obtaining evidence in relation to the PFOS levels

of those who had interactions with Fiskville and secondly through the implementation of

Recommendation 2 of the Committee’s Interim Report. That recommendation was that the

government assess the feasibility of providing voluntary and free testing for PFOS. 91

88 See, for example, Diomides & Associates Pty Ltd Environmental Consultants, Report to Country Fire Authority,

Environmental Site Assessment, 27 June 1996, Appendix 1, p 5; Cardno Lane Piper, Buried Drums Assessment, June 2013,

p vi; Cardno Lane Piper, Geotechnical Investigation for Proposed Creek Diversion, April 2013, pp 43-51; Cardno Lane

Piper, Investigation of Risks at Former Landfills, September 2013, p vi; Cardno Lane Piper, Buried Drums Assessment,

October 2013, p vi; Cardno Lane Piper, Groundwater Contamination Assessment, October 2013, p vi; Cardno Lane Piper,

Soil Management Plan, Creek Diversion Works, October 2013, Appendix F, p 143; Cardno Lane Piper, Supplementary

Surface Water and Sediment Sampling Downstream, 18 October 2013, Appendix F, pp 20, 21; Cardno Lane Piper, Surface

Soil Assessment - 4WD High Mound, 18 October 2013, p 2; Cardno Lane Piper, Targeted Soil Assessment, December 2013,

p vi; Cardno Lane Piper, Surface Water and Contamination Assessment, February 2014, p viii; Cardno Lane Piper, Summary

Report - Human Health Risk Assessment - CFA Training Personnel, March 2014, pp iii, 6, 13, 19. 89 P29 90 P31 91 Interim Report pxiii

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93. Whilst the CFA has and continues to support the implementation of Recommendation 2 of the

Committee’s Interim Report, it also notes that the content of the newspaper article relating to

the PFOS levels in those exposed at Fiskville has been contradicted by evidence before the

Committee. That evidence was given by Dr Roger Drew to the Committee on 23 November

2015. Dr Drew gave his evidence in relation to the PFOS levels of those who had interactions

with Fiskville by reference to the following graph:

94. In describing the information contained in this graph to the Committee, Dr Drew said:92

“…On the right-hand side of that figure there is a whole heap of dots. They represent

the serum concentrations for all the people who were tested at Fiskville and also

include the farm results. You will see there are only four above the background

concentration, and right at the top of that figure you will see a broad dotted line,

which represents the level at which we anticipate there to be no harm to a person.

There is a big difference between the serum no-effect level in humans and the

concentrations that were measured.”

95. Put simply, most people were below the normal background level that exists in all humans.

There were only four people who were not below the normal background level and all of

those four people were significantly below the “safe” level.

92 Transcript of oral evidence of Roger Drew, p7

Figure 6: Compilation of all Fiskville PFOS serum concentration results

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96. The evidence given by Dr Drew in relation to this issue was broadly consistent with the

evidence given by other witnesses including Professor Priestly, Professor Ackland and Dr

Lester.

97. In the circumstances, the CFA submits that the media reports about the PFOS levels of those

who interacted with the Fiskville site are not supported by the evidence that was given to the

Committee.

The evidence contradicting the Committee’s Interim Finding that PFOS is carcinogenic

98. In its interim report, the Committee unequivocally described PFOS and PFOA as

carcinogenic.93 Examples of lay evidence the Committee heard asserting that PFCs are

carcinogenic included the evidence of the former Department of Primary Industry prosecutor

Gavan Knight who gave evidence that “leukaemia is linked to PFOS.”94

99. With respect, the CFA submits that this is a conclusion which is inconsistent with the expert

evidence that was heard by the Committee. In particular, the CFA notes that this was a

conclusion which was reached before the Committee had received the benefit of evidence

from Professor Priestley, Dr Drew, Professor Ackland and Dr Lester.

100. In that regard, there is little doubt PFCs are of concern and that PFOS has been banned in

countries other than Australia. As Nigel Holmes noted in his evidence to the Committee, the

principal reason for this is that their persistence means that appropriate management of these

substances must occur.95

101. On the specific question of whether PFOS (being the particular PFC found at Fiskville) is

carcinogenic however, the Committee heard evidence from Professor Brian Priestly on 19

October 2015.96 In his evidence, Professor Priestley referred to his literature review which

noted that:

“An independent review of 18 epidemiological studies of cancer incidence reached

the conclusion that the evidence does not support an association between cancer and

either PFOS or PFOA.”97

93 Interim Report pxi 94 Transcript of oral evidence of Gavan Knight, p51 95 Transcript of oral evidence of Nigel Holmes (19 October 2015), p 6-7 96 Professor Priestly is the Director, Australian Centre for Human Health Risk Assessment; School of Public Health and

Preventative Medicine, Monash University. 97 P 5 “Literature Review and Report on the potential health effects of Perfluoroalkyl Compounds, Mainly Perflurooctane

Sulfonate (PFOS).” 7 October 2015; It is further noted that Professor Michael Ackland, in his evidence to the inquiry on 20

November 2015, noted that the Priestley review was not commissioned by the CFA.

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102. This evidence of Professor Priestley was broadly consistent with the evidence given by Dr

Drew, Professor Ackland (Acting Chief Health Officer) and Dr Lester (former Chief Health

Officer).

103. Furthermore, this evidence was not contradicted by the evidence the Committee heard before

it published its Interim Report in relation to the proposition that PFOS and PFOA is

carcinogenic in humans. That evidence included that of Dr Klein that whilst he “would not be

surprised if there was a high cancer incidence in the area…[he] would not put it down to

foam (being the source of the PFOS at Fiskville).”98

104. In the circumstances, the CFA respectfully submits that it was premature for the Committee to

unequivocally conclude that PFCs are carcinogenic. Any ongoing consideration of that issue

should be undertaken by experts in the field, having regard to all of the scientific evidence

that might be available.

105. Respectfully the CFA submits that it would be inappropriate for the Committee to make any

form of recommendation in its final report which proceeds on the assumption that PFCs,

including PFOS, are carcinogenic.

Addressing the Committee’s Interim Findings in relation to neighbouring properties

106. The Committee’s Interim Report notes that:

“The Committee is concerned that while the CFA is taking action regarding the

Fiskville site there seems to have been no similar considerations of contamination of

neighbouring properties in light of the reasons that Fiskville was closed. The

Committee is concerned about the environmental and health impacts of the spread of

PFOS to neighbouring properties.”99

107. With respect to the Committee, this Interim finding is not supported by the evidence.

108. Part F of the CFA’s First Submission is entitled “Safeguarding the Local Environment.”100

That part of the CFA’s First Submission sets out the details of the 11 separate studies relevant

to this issue, together with details of the EPA auditor approved clean-up plan arising from the

matters identified. In particular, it refers to the following studies which are directly relevant to

the effect of Fiskville on its neighbours:

a. study 2: Feasibility Study of Water System Upgrade, Diversion Work and

Remediation, CFA Fiskville Training College, Cardno, December 2013;

98 Transcript of oral evidence of Roger Klein and Nigel Holmes, pp237, 242 99 Interim Report p59 100 At p18-21

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b. study 9: Environment – Environmental Sampling and PFC Analysis Program,

Adjacent Land, Fiskville, Cardno, March 2014 (which is generally referred to as the

Adjacent Land Report).

109. In addition to the matters contained in the First CFA Submission, and since the Committee

has published its Interim Report, the CFA has provided the Committee with the Lloyd

Answers. The Lloyd Answers are a comprehensive set of answers in relation to a series of

questions the Committee posed in relation to the Lloyd family. The Lloyd Answers detail the

water, soil, animal and human tests that were carried out specifically in relation to the Lloyd

family. Those answers were provided to the Committee on 8 July 2015. In particular, these

answers referred to the following studies which have been carried out in relation to the Lloyd

property:

a. the pilot ewe study and lamb HHRA which considered the presence of PFCs in the

blood serum of sheep located on the Lloyd’s property;101

b. water and sediment testing conducted on the Lloyd’s property as part of the CFA’s

broader consideration of the issues relevant to the Fiskville site;102 and

c. the soil, sediment, grass and surface water testing carried out specifically in relation

to the Lloyd’s property.103

110. In addition to the information provided to the Committee in relation to the Lloyd family, the

CFA notes that the Committee also has evidence before it in relation to the extent to which

the impact on the Callow property has been investigated. That evidence includes a Worksafe

entry report dated 12 August 2013.

111. That entry report was described in detail in the First CFA Submission, where it was noted

that:104

“A Worksafe entry in 2013 followed a request for an inspector to deal with an alleged

health and safety issue associated with the impact of foams on cattle drinking troughs

and on the collection of drinking water on an adjoining property. The inspector was

advised of CFA’s precautions for handling foams ([in the nature of personal

protective equipment] and relevant policies); email notifications to various people,

including neighbours, of CFA’s training schedule (with opportunities to be raised

with the Training Centre which CFA noted at the time had not been utilised); and

101 At p7-10, 21-23 102 At 11-13, 23 103 At 15-16, 24-25 104 At p16

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monitoring of environmental conditions and changes to the program if necessary as a

result of those prevailing conditions. CFA agreed that foam on Dam 1 was to be

tested for contaminant and Worksafe was to be made aware of the results. Cardno

undertook this testing and provided a report to CFA in January 2014 which

concluded that it is “highly unlikely that wind-blown foams would cause any harm to

the residents on adjoining properties as a result of potentially contaminating rain fed

drinking water supplies in water tanks.

112. The “Cardno” report referred to is the Wind Blown Foam Assessment – CFA Fiskville.

Worksafe Entry Report – Reference No V01011101740L.105

113. Furthermore, in late October 2015, a further Human Health Risk Assessment (HHRA) was

undertaken in relation to the Callow property, made up of a report by Senversa entitled

“Preliminary Environmental Site Assessment 4475 Geelong-Ballan Road, Fiskville” and an

associated report by Dr Roger Drew entitled “PFOS in stock-water at 4475 Geelong-Ballan

Road, Fiskville.” This HHRA concluded that whilst further testing was recommended, “it is

unlikely that stock raised at 4475 Geelong-Ballan Road pose a risk of harm to human health

should they be consumed.”106

114. The Committee also heard evidence from environmental scientists, Douglas Ahearne,

Michael Rehfisch and Kristi Hanson from Senversa. These witnesses gave evidence to the

Committee on 19 November 2015. As part of their evidence, they described to the Committee

the ongoing work that is occurring in relation to the implementation of the 26

recommendations that were made by the environmental auditor, Mr Strudwick. The

implementation of these recommendations has and will continue to include work relating to

environmental matters arising in the context of neighbouring properties.107

115. With respect, the CFA submits that any recommendations relating to the further investigations

into the effect of Fiskville on neighbouring properties have regard to the consideration that

this issue has already been given.

105 Cardno 24 January 2014. A copy of this report was provided to the Committee under cover of a letter dated 23 February

2016 106 At p2. A copy of this report was provided to the Committee under cover of a letter dated 23 February 2016 107 Transcript of oral evidence of Douglas Ahearne, Mr Michael Rehfisch and Kristi Hanson, p3. See in particular the

evidence of Michael Rehfisch.

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The recycling of fire water in the period before October 2012

116. In the Interim Report, the Committee noted that “the Committee will consider both past and

present actions and events since the inception of Fiskville to the present day, noting that

water quality has continued to be an issue up until its closure this year.”108

117. Whilst this comment in the Interim Report was made notwithstanding the evidence of the

various scientists who gave evidence to the Committee and the evidence of the environmental

auditor that the risk both on-site and off-site are low and acceptable, the Committee has

sought to focus its attention during the second stage of the hearings on the issue of the

contamination in both the Dam 1 settling pond and Dam 2.

118. Given this focus, it is appropriate that the CFA’s further submission address this issue,

particularly to the extent that it has been the subject of misinformation in evidence before the

Committee.

119. One of the more acute examples of the misinformation provided to the Committee by Mr

Tisbury relates to his description of the way in which water was used and recycled at the

Fiskville site. In that regard, whilst it was noted in the IFI that this process evolved over

time,109

it is noted that the evidence Mr Tisbury gave is contradicted by the documentary and

scientific evidence that has been provided to the Committee.

120. For his part, in response to a direct question from the Committee, Mr Tisbury described the

way in which water was recycled in the following terms:

“Dam 1 to dam 2 and then straight in the pit, mate. There is no water treatment

plant. You have been up there. You have got one bubbler, and that is it in dam 1. The

water test results they got from dam 1 to dam 2 were failing. There is no fancy

computerised system there. It is a pipe underground. There is dam 1, dam 2 and the

pit, and they are sucking the water out of dam 2 and out of the pit.”110

121. This evidence is contradicted by other evidence heard by the Committee. In that regard, both

the PAD supervisor, Mr John Myers111

and the former Officer in Charge of the Fiskville Site,

Justin Justin112 told the Committee that the primary water source on the PAD was the “Pit”

which was filled with potable water before training exercises commenced. As Mr Justin put it

108 Interim Report p39 109 See in particular IFI Report p41 110 Transcript of oral evidence of Mick Tisbury, p172 111 Transcript of oral evidence of Lex De Man, James Stitz and John Myers, p8 112 Transcript of oral evidence of Justin Justin, p6

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in his evidence: “We would not fill the pit directly from the Dam. It was a constant flow of

mains water into the pit.”113

122. If necessary the potable water in the Pit would be supplemented by water drawn from Dam 2.

According to Mr Justin, whilst there was a pipe filled with crushed scoria which connected

the Dam1 settling pond with Dam 2:

“The water in Dam 2 was mostly collected from natural run-off as well as the

substantial roof space on the Fiskville buildings…This approach was consistent with

the advice from all experts, being ALS, Wynsafe and HAZCON. As far as I was

aware, the water being used in training was always within CFA guidelines.”114

123. Later in his evidence, Mr Justin went further and said:

“…from 11 December [2011] when that article was raised I had had Worksafe on

site, I had had three independent hygienists on site who were all exposed and talked

through the water process and what transpired and what occurred in the water

process. At no time did anyone mention the water…at no time did any of those people

raise any concerns in relation to that…

…

…With the assurances from three independent hygienists and Worksafe, I am not sure

what more expert advice I could gain.”115

124. In addition to the evidence of Mr Myers and Mr Justin about the way potable water was used

to fill the Pit, and the confirmation they received from experts about the appropriateness of

the water recycling system, there is also a detailed description of the way in which water

recycling system at Fiskville was maintained in the February 2012 ALS Water Reuse

Investigation Report entitled “Country Fire Authority Fiskville Training College Water Reuse

Investigation Report” (ALS Report).116

125. The ALS Report contains a comprehensive description of the process by which water

recycling system was maintained at Fiskville in the period about which Mr Tisbury was able

to give direct evidence, based on his own experience. That report contains a series of google

earth images and photographs which describes the process by which the water recycling

system was maintained. That description includes that:

113 Transcript of oral evidence of Justin Justin, p6 114 Transcript of oral evidence of Justin Justin, p6 115 Transcript of oral evidence of Justin Justin, p19 116 CFA.3151.7008.005.0529

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“Fiskville CFA utilises five ponds for the supply and backup for provision of water

for training purposes (Figure 4-4)…The immediate runoff from the training site

passes through a coarse filter basket (Figure 4-5)…Once filtered, the water flows into

a large holding basin (Figure 4-6) which settles the solids and allows the supernatant

to flow into another separation cell (Figure 4-7). The settling, separation and mixing

design is based on the triple interceptor concept.

During times where the training area is not used, the solids produced in the settling

tank is dried and shovelled into piles, removed and stockpiled for future attention.

The oil fraction from the grease separator is also removed with the solid waste…The

final effluent from the triple interceptor system enters dam 1 (Figure 4-8) via a pump

system. At the time of the visit an aerator was operating in Dam 1…The overflow

from Dam 1 gravity feeds into Dam 2 which consists of a series of bends and an

island. The water is extracted from Dam 2 (Figure 4-9) and pumped into the holding

cell for fire fighting activities…The overflow from Dam 2 enters a small drain which

runs into Dam 3 (Figure 4-10)…The overflow from Dam 3 also passes to Dam 4 and

then to Fiskville Lake. At times of low rainfall or low water availability from Dam 2,

water is pumped from either Dam 3, 4 or Fiskville Lake using a portable pump and a

series of fire hoses. The water is used to top up Dam 2 thus utilising the exiting pump

shed and delivery system to the holding tank. It was noted at times of extreme low

water supply potable water was used to top up the supply.117

126. Although by October 2012 the Pit was fully replaced by two above ground water storage

tanks containing potable water, the CFA submits that any recommendations based on the

process by which fire water was recycled prior to the replacement of the Pit must accurately

reflect the water reuse process which existed. It would be inappropriate for the Committee to

rely upon the misinformation provided by Mr Tisbury in that regard.

The evidence relating to the presence of contaminants in the sludge of the Dam 1 settling pond

127. The Committee has spent considerable time exploring whether the presence of contaminants

in the sludge in the Dam 1 settling pond at the Fiskville site could have caused the recycled

water used in fire training to be unsafe. As the Committee has noted, it seems that the

presence of contamination in the sludge in the Dam 1 settling pond at Fiskville may have

been known for a number of years.

117 ALS “Country Fire Authority Fiskville Training College Water Reuse Investigation Report” February 2012

CFA.3151.7008.005.0529 at 0543-0547

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128. Being one of the legacy effects of burning unknown fuels in the period before 1996,118 the

presence of contaminants in the settling pond was described by one Committee member

during the hearings as “the elephant in the room.”

129. In the context of the careful consideration that the Committee has given this issue, the CFA

notes that the Committee heard no evidence that:

a. any firefighter or other person was ever exposed to the contaminants present in the

Dam 1 settling pond;

b. firefighter training was ever conducted at a time when the water quality standards

were beyond the parameters described in the CFA’s Water Management Plan for the

Fiskville site.119

The absence of such evidence is important in circumstances where

the Committee has available to it both the results of water testing conducted and also

heard evidence from witnesses representing the relevant testing authority, Central

Highlands Water;

c. the procedures set out in the CFA’s Water Management Plan for the Fiskville site

were at any time not followed. On the contrary, it was the evidence of the PAD

supervisor, Mr John Myers that he at all times followed the Water Management

Plan.120 This evidence was corroborated by the evidence of the former Officer in

Charge of Fiskville, Mr Justin Justin.121

130. Despite the absence of evidence in relation to these matters, the Committee was told by a

number of witnesses that there were attempts made over time to obtain funding to remediate

the sludge in the Dam 1 settling pond. Some members of the Committee have sought to assert

that the desire to remediate the sludge in Dam 1 suggests that there were concerns about the

safety of the settling pond.

131. That proposition is not supported by the evidence. Rather, as Mr Justin, the former Officer in

Charge of the Fiskville Site, described on numerous occasions during his closed appearance

before the Committee, the push by he and the facilities manager at the time, Martyn Bona, to

remediate Dam 1 was in the context of an expected increase in demand for firefighter training

at the site. Mr Justin said that, in the context of that expected increased demand, “remediation

118 ALS “Country Fire Authority Fiskville Training College Water Reuse Investigation Report” February 2012

CFA.3151.7008.005.0529 at 0547 119 These standards and their development over time is described in detail in Attachment 4 to the First CFA Submission 120 Transcript of oral evidence of Lex De Man, James Stitz and John Myers, p4 121 Transcript of oral evidence of Justin Justin, p6

35

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of Dam 1 could only ensure that there was a greater longevity for the facility and help

provide a greater water source for the future.”122

132. The CFA submits that any recommendations made by reason of the presence of contaminants

in the Dam 1 settling pond should be made having regard to the totality of the evidence in

relation to this issue. That includes the absence of evidence of exposure and the motivating

factors for the desire to remediate the Dam 1 settling pond. Respectfully, the CFA submits

that any recommendation should also have regard to the external assurances given to the CFA

that the firefighting water at Fiskville was safe, as summarised in schedule 1 of this further

submission.

A balanced consideration of the February 2012 ALS water report

133. In the course of its careful consideration of the sludge in the Dam 1 settling pond, the

Committee has spent some time considering the content of the February ALS Report. This

report was commissioned by the former Officer in Charge at Fiskville Mr Justin Justin and the

former Facilities Manager Mr Martyn Bona. According to Mr Justin the purpose of the report

was to assist the management at Fiskville appeal to CFA headquarters for funding to

remediate the sludge in the Dam 1 settling pond, as part of their plan to ensure the long term

sustainability of the site.123 It was the subject of detailed consideration by a number of

witnesses, including the UFU representative Mr Tisbury. 124

134. Whilst it is correct that in many ways the ALS Report is consistent with the content of earlier

reports by noting the presence of contaminants in the Dam 1 settling pond, there are a number

of aspects of this report which have not been referred to in evidence before the Committee.

These aspects of the ALS Report are nevertheless important to consider in any balanced

consideration of the ALS Report by the Committee. Those matters are:

a. the ALS Report does not conclude that the presence of contamination in the Dam 1

settling pond rendered the practice of recycling firefighting water at Fiskville unsafe.

In that respect, the ALS Report does not contradict the evidence Mr Justin gave that

he had obtained advice from “three independent hygienists and Worksafe”125

that the

recycled fire water was safe;

b. the ALS Report is equivocal about the impact the Dam 1 settling pond was having on

Dam 2 (which for a time was used as an additional water source). In that regard, the

122 Transcript of oral evidence of Justin Justin, p8 123 Transcript of oral evidence of Justin Justin, p7 124 Transcript of oral evidence of Mick Tisbury, p171 125 Transcript of oral evidence of Justin Justin, p19

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report states: “This report is based on one sampling event and may not be

representative of the actual water quality of the reuse water…;”126

c. in the absence of a conclusion that the recycled firewater at Fiskville was unsafe, the

ALS Report recommended:

i. a monitoring program, including water management standards. Such a

program had already been implemented at Fiskville, pursuant to the

provisions of the CFA’s Fiskville Water Management Plan, for a number of

years before the ALS Report;

ii. an environmental improvement plan;

iii. an audit of the overall water treatment facility; and

iv. removal of the sludge in Dam 1 to a secure site on the Fiskville property.

135. In short, even taken at its highest, the ALS Report is not evidence that the firefighting water at

Fiskville was unsafe. Any recommendations made by the Committee which have regard to

this report should be made having regard to that fact.

The implementation of the IFI and environmental auditors recommendations

136. The IFI and the work which followed from it identified a series of issues that needed to be

addressed by the CFA. In addition to implementing all 10 of the recommendations contained

in the IFI report,127

the CFA board also set about implementing a series of 11 other initiatives.

These initiatives are set out in full in the CFA’s earlier submission to the Committee dated

March 2015.128

The EPA environmental auditor made a total of 26 recommendations.

137. The implementation of these 36 recommendations (those of the IFI and the EPA

environmental auditor) and 11 initiatives has been the subject of independent review.

The independent monitor’s assessment of the implementation of the recommendations

138. In July 2015, after the CFA’s First Submission was lodged with the Committee, Kieran

Walshe who had been appointed129 to monitor the CFA’s progress in implementing the 10

recommendations of the IFI and the 11 other initiatives adopted by the CFA published his

final report. In that report the Independent Monitor noted that:

126 CFA.3151.7008.005.0529 at 0550 127 Together with the 18 recommendations arising from the subordinate report to the IFI report by Brian Lawrence entitled

“Review of CFA Regional Training Grounds.” 128 These initiatives are set out in full in the First CFA Submission at p7,8 129 Mr Walshe was appointed in February 2013 and previously published an interim report in July 2013.

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“CFA has demonstrated a commitment, and has been active in the implementation of

the recommendations and [CFA Board] initiatives contained within the reports

addressed and reviewed by the Independent Monitor – Fiskville.”130

139. In his report, the Independent Monitor recommended that any ongoing monitoring that was

necessary be undertaken by the CFA.131 A copy of the Independent Monitor’s report is

Attachment A to this further submission.

The environmental auditor’s assessment of the remediation of the site

140. In relation to the 26 recommendations made by the EPA appointed environmental auditor, the

Committee heard evidence from environmental auditor Daryl Strudwick, on 25 May 2015.

The Committee also referred to the audit report of Mr Strudwick extensively in the Interim

Report.132

141. Both in oral evidence133

and his written report, Mr Strudwick gave evidence that the risk to

human health both onsite and offsite posed by potential exposure to PFCs was “low and

acceptable”. The Committee has heard no evidence to contradict the opinion of the

environmental auditor.

142. The CFA submits that the evidence of Mr Walshe and Mr Strudwick demonstrates the CFA’s

commitment to addressing the issues arising from the presence of certain substances at the

Fiskville site. The CFA respectfully urges the Committee to have regard to the assessments

made by the Independent Monitor and the evidence of the Environmental Auditor in relation

to any recommendations that are made by the Committee by reason of its Inquiry.

130 Independent Monitor – Fiskville Report – July 2015 p6 131 Independent Monitor – Fiskville Report – July 2015 p3 132 Interim Report pp13-15 133 Transcript of oral evidence of Daryl Strudwick, p96-97

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Schedule 1 – Chronology of External Assurances given to the CFA that the Firefighting Water at Fiskville was Safe

DATE AUTHOR REPORT TITLE SUMMARY OF REPORT FINDINGS PAGE REFERENCE

October –

November

2005

Wynsafe Assessment of

Firefighting Water at

CFA Field Training

Grounds

“Based on the results of sampling carried out by Wynsafe, and on

previous testing available, it is considered that personnel exposed to

firefighting water at training grounds should not suffer any adverse health

effects from such exposure.”

P15

June 2010 Wynsafe Perfluorochemicals in

Firefighting Water at

Fiskville

“…it can be shown that the estimated exposures will produce daily

intakes several hundred times lower that the recommended Tolerable

Daily Intake (TDI) for both PFOS and PFOA”

P5

7

December

2011

Wynsafe NA – letter to CFA “It is considered that personnel carrying out training and other activities at

CFA Fiskville should not suffer any adverse health effects from chemical

exposure from either the burning of LPG, Petrol and Diesel in the

Training PAD area, or from the drum burial pits located south of the

western end of the airstrip near the hangar.”

P2

January

2011

Hazcon Health and Safety Review

– CFA Fiskville Training

College

“The general health and safety at Fiskville does not present an

unacceptable risk to the people attending the site once the purpose and the

activities of the training college is taken into account…”

P12

15 June

2012

Golder &

Associates

CFA Fiskville –

Preliminary Site

Assessment

“[The] exceedances of surface water and sediment criteria in Dams 1-4 do

not indicate the potential for an immediate human health risk. Procedures

should be established to manage the risks to those who have the potential

Pp33-34

39

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to come into contact with surface water and sediments in Dams 1-4 during

training and routine maintenance activities.”

3 August

2012

Cardno

Lane Piper

Letter – Water

Monitoring Results –

Fiskville Week of 30 July

2012

“These test reports have derived from the water monitoring program set

out in CFA’s water management plan…we can report that the results do

not indicate any water quality issues that would make the water unsuitable

for use in fire fighting training.”

P1

CFA.3151.7008.008.0028

3 October

2012

Worksafe

– Jarrod

Edwards,

Director

Workplace

Hazards &

Hazardous

Industries

Group

Letter – Fiskville Training

Facility

“Worksafe inspectors visited the Fiskville Training Facility on 6

December 2011 following articles published in the Herald

Sun…Worksafe inspectors again visited CFA’s Burwood facility on 10

July 2012 and attended [Fiskville] on 10 August 2012 pertaining to the

quality of water used for fire fighting training and the associated risk to

health and safety…

Worksafe acknowledges the continued operation of the Fiskville Training

Facility in accordance with the risk controls associated with dangerous

goods and fire fighting water presented during inspector visits conducted

since 6 December 2011.”

P1

CFA.3151.8000.017.0401

25 May

2015

EPA

appointed

Auditor

Daryl

Strudwick

In evidence to the

Committee

The human health risk both onsite and off-site is low and acceptable. T97

Independent Monitor – Fiskville Report – July

2015

Independent Monitor – Fiskville Report – July 2015

1

Table of Contents

Topic Page

Introduction 2

Methodology 2

Independent Monitor Recommendations 3

Chronology of Events – Fiskville Investigation 4-6

CFA Response 6-8

Governance 7

Closure of Fiskville 7-8

Status of Recommendations and Initiatives 8-11

IFI Recommendations 8-9

Board Initiatives 9

Lawrence Report Recommendations 10-11

Recommendations from Cardno Lane Piper & 53V Audit Reports 11

EPA Clean Up Notice & Environmental Auditor (53V) Report 12-14

Fiskville Works 14-17

Health Initiatives 17-19

Health Surveillance Program 17-18

Monash Study 18-19

Appendices

IFI Report Recommendations - Appendix “A” 20-24

CFA Board Initiatives - Appendix “B” 25-26

Lawrence Report Recommendations – Appendix “C” 27-40

Cardno Lane Piper & 53V Audit Recommendations – Appendix “D” 41-49


2

Introduction

In December 2011 and January 2012, the Herald Sun newspaper published a series of investigative reports raising serious concerns about the possible health impacts of training practices at the Country Fire Authority (CFA) Fiskville Training Centre dating from the 1970s. As a result of the first report, CFA commissioned an independent investigation into the use of materials and training practices at Fiskville. The investigation was chaired by Professor Robert Joy (former Deputy Chairman of the Victorian Environment Protection Authority and Adjunct Professor at Royal Melbourne Institute of Technology). Publication of the terms of reference for the investigation occurred on 14th December 2011.

The Independent Fiskville Investigation (IFI) Report was provided to the CFA by Professor Joy on 28th June 2012. The report detailed 10 recommendations to address the findings and conclusions of the report. The IFI Report included subordinate reports prepared by Golder & Associates and a report titled ‘Review of CFA Regional Training Grounds’ by Brian Lawrence (Lawrence Report). Each of these reports made additional recommendations which the Joy report recommended be addressed.

The IFI Report was considered by the CFA Board in June, 2012 and a “Response to the Professor Joy Report of Independent Investigation into the CFA Facility at Fiskville” document was released on 12th July 2012. In that document the CFA accepted the facts, conclusions and recommendations of the IFI Report and undertook to ensure that the recommendations would be addressed as a matter of priority. In addition, the Board identified a number of additional initiatives for action.

The Independent Monitor – Fiskville was appointed in February 2013 to monitor CFA’s progress to implement the recommendations and the Board initiatives and report on progress to the Board. An Interim Report was published on the CFA website in July 2013.

Methodology

In undertaking the monitoring role, the Independent Monitor – Fiskville has reviewed evidence documents, including assessment reports, met with program and project managers, attended program and project workshops and conducted visits to Fiskville to view progress on the implementation and completion of recommendations and initiatives.


3

Independent Monitor Recommendations

The Independent Monitor – Fiskville makes the following recommendations relative to outstanding issues.

Recommendation 1:

That the Executive Director, Informing The Future Program, be responsible for the on-going monitoring and reporting of the outstanding IFI recommendation.

Recommendation 2:

That the Executive Director, Informing The Future Program, be responsible for the on-going monitoring and reporting of the implementation of ISO 14001 Environmental Management and AS4801 Occupational Health and Safety (Board Initiative 2).

Recommendation 3:

That the Executive Director, Informing The Future Program, be responsible for the on-going monitoring and reporting of the outstanding Lawrence Report recommendations.

Recommendation 4:

That the Executive Director, Informing The Future Program, be responsible for the on-going monitoring and reporting of the outstanding recommendations arising from the Cardno Lane Piper work and the 53V Audit Report.

Recommendation 5:

That the Executive Director, People and Volunteerism be responsible for the on-going Health Surveillance Program monitoring and reporting.


4

Chronology of Events – Fiskville Investigation

6 December 2011: Claims firefighters have been exposed to harmful chemicals used in practical firefighting drills between 1970’s and 1990’s revealed in the media

14 December 2011: CFA announces Professor Rob Joy to conduct an enquiry into past hot fire training practices and potential for contamination at Fiskville

December 2011: CFA establishes support services for anyone who believes they may have been affected by historical practices.

December 2011: Two hygienists report no significant risks to the health and safety of people working at the site and those attending the site either as trainees or visitors.

26 June 2012: CFA switches to town mains water for practical firefighting training.

28 June 2012: Professor Joy delivers ‘Understanding the Past to Inform the Future’ report to CFA.

12 July 2012: CFA accepts all 10 Professor Joy recommendations and commits to 11 additional management initiatives.

July 2012: Leading Australian environmental engineering firm Cardno Lane Piper commences implementation of the recommendations.

August 2012: Program manager appointed with responsibility for managing the implementation of the 10 Professor Joy Recommendations and 11 management initiatives.

August 2012: Voluntary Health Surveillance program established.

October 2012: Worksafe issued a formal letter stating that it “acknowledged the continued operation of the Fiskville Training Facility in accordance with the risk controls associated with dangerous goods and fire fighting water presented during inspector visits conducted since 6 December 2011”.

October 2012: CFA completed installation of two fully enclosed, above ground storage tanks to replace the previous open underground storage tank known as 'the Pit' to address concerns regarding run-off from the surrounding area, including dirt and clay particles entering 'the Pit' during rain events. The storage tanks are filled exclusively with town mains water.

3 December 2012: Line control of CFA training campus staff transferred to Executive Director Operational Training and Volunteerism.


5

30 November 2012: Monash Centre for Occupational and Environmental Health engaged to investigate the cancer incidence and all causes of mortality among Fiskville Practical Area Drill (PAD) workers and instructors who operated the Fiskville Training Campus 1971-1999. The study was completed late 2014 and released early 2015.

December 2012: Environmental adviser appointed.

January 2013: EPA issues two clean up notices in respect of CFA’s Fiskville State Training College each requiring an audit by an EPA-appointed Environmental Auditor.

January 2013: EPA-appointed Environmental Auditor engaged to conduct the two environmental audits as per the requirements of the two clean up notices.

February 2013: Former Victoria Police Deputy Chief Commissioner Kieran Walshe appointed Independent Monitor - Fiskville by CFA Board.

April 2013: EPA accepts CFA's current program of work to undertake environmental and human health risk assessments and upgrades to the site.

May 2013: Victorian Government announces $16.8 million dollars in State budget for upgrades at CFAA training campuses, primarily Fiskville.

May 2013: Eminent toxicologist advises CFA some members may have eaten fish containing residues from firefighting foams from dams at Fiskville and recommends blood tests and health checks. Following review of blood tests and health checks, toxicologist advised risk is negligible.

July 2013: Independent Monitor – Fiskville releases interim report indicating good progress implementing recommendations and management initiatives.

January 2014: Fiskville Stage 1 engineering works commenced to divert creek around Lake Fiskville, enhance drainage systems from the Practical Area for Drills (PAD), establish wetland to filter storm water and install bunds to increase the capacity of the dams.

March 2014: Cardno Lane Piper completes their final Fiskville environmental and human health assessment reports.

11 April 2014: EPA-accredited Environmental Auditor completes the first of two audits of Fiskville and submits his report to EPA.

3 July 2014: Fiskville Stage 1 civil works completed.

7 July 2014: EPA releases the Environmental Auditor’s report, along with all of Cardno Lane Piper’s Fiskville assessment reports.

2 March 2015: Training operations at Fiskville were suspended temporarily following the detection of PFOS in a limited number of industrial training infrastructure outlets


6

(pumps and hydrants) that supply water to the fire fighting training area. In order to confirm where PFOS was throughout the water supply further testing of all water outlets across the site commenced on 5 March 2015. This testing included water outlets for domestic use (taps, showers and toilets), mains water entering the site, hydrants used for training, and training water infrastructure such as pumps and tanks.

26 March 2015: Fiskville facility closed permanently following the confirmation of PFOS detections in almost all of the industrial training infrastructure outlets (pumps and hydrants) that supply water to the fire fighting training area and the unexpected detection of PFOS in a fire hose connection outlet located in the hangar, away from the main training area. Testing showed there was no PFOS in the mains water supply nor in the domestic water outlets.

CFA Response

CFA has demonstrated a commitment, and has been active in the implementation of the recommendations and initiatives contained within the reports addressed and reviewed by the Independent Monitor – Fiskville. CFA responded swiftly to the IFI Report by appointing a Program Management Team, comprising a Program Manager and support staff to manage a program of activities and projects established to implement the IFI recommendations and Board initiatives under the banner of the “Informing the Future” Program. Implementation of the recommendations arising from the Lawrence report was assigned to CFA’s Operational Training and Volunteerism Directorate. In July 2012 CFA engaged Cardno Lane Piper to undertake assessments and to prepare reports relevant to works and remediation required at Fiskville and CFA’s six Regional Training Grounds. Cardno Lane Piper possessed the required knowledge and expertise to enable progression of the IFI recommendations. By February 2013 the results of Cardno Lane Piper’s environmental assessments at Fiskville were available and CFA was briefed on the findings, however the work was subject to an environmental audit that was a requirement of clean up notices issued by EPA on 22 January 2013. Due to the volume, breadth and complexity of work undertaken it necessarily took considerable time for the Auditor to consider and understand these reports in order to come to his own findings. This caused delays in finalising the environmental assessment reports, delays which were further exacerbated as these reports provided the factual basis upon which subsequent risk assessments were made. Those risk assessments were in themselves lengthy and highly complex and required groundbreaking toxicology research which was undertaken by eminent toxicologist Dr Roger Drew. The environmental and risk assessment reports on Fiskville were finalised by Cardno Lane Piper in March 2014. The delays to finalising reports in respect of Fiskville similarly delayed the preparation of reports in respect of CFA’s six Regional Training Campuses (formerly


7

Regional Training Grounds). Whilst the site assessments were conducted in 2012, the written reports were completed between September 2014 and April 2015. Despite this delay in completing the reports, Cardno Lane Piper briefed CFA on the findings as they became available with CFA taking corrective action immediately where warranted.

Governance

On 19 December 2011, the CFA Board established a Board Committee to oversight the Fiskville Project with the intention that it ensured the ongoing welfare and wellbeing of CFA members, their families and other parties as well as communications and other matters. Union representation was invited to this Committee which was accepted by Volunteer Fire Brigades Victoria, but not the United Firefighters Union. The Chief Executive Officer was a member of that committee and reported on the progress of the Informing the Future Program. This was later changed with the CEO reporting to a sub-committee of the Board which was established to focus on Health, Safety and Environment matters across all CFA activities. This sub-committee of the Board was comprised largely of Board members with additional membership bringing relevant Health, Safety and Environment expertise.

Additional oversight has been provided by Department of Justice and Regulation (formerly Department of Justice) since mid 2013.

In order to engage and inform the business on the Program of works being undertaken CFA established in late 2013 the Informing the Future Program , Project Board chaired by the Chief Executive Officer with following executive membership:-

Executive Director, Business Services

Executive Director, Operational Training and Volunteerism

Executive Director, People & Culture

Executive Manager, Assets Strategy

Manager, Informing the Future Program

The Project Board meet regularly and the Independent Monitor – Fiskville, has attended some of those meetings as an observer. The Project Board will continue to be kept informed of the progress of the Informing the Future Program until completion of all activities.

Closure of Fiskville

On 2 March 2015 training operations at Fiskville were suspended temporarily following the detection of PFOS in a limited number of industrial training infrastructure outlets (pumps and hydrants) that supply water to the fire fighting

training area.

On 26 March, 2015, the Fiskville facility was closed permanently following testing of more than 500 samples which confirmed the detection of PFOS in almost all of the


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industrial training infrastructure outlets (pumps and hydrants) that supply water to the fire fighting training area and the unexpected detection of PFOS in training infrastructure located away from the Practical Area for Drills (PAD). Testing confirmed there was no PFOS in the mains water supply nor in the domestic water outlets.

The action of the CFA Board to permanently close the facility was for the safety and wellbeing of staff and volunteers as the Board could no longer guarantee the safety of the site.

Status of Recommendations and Initiatives

The Independent Monitor – Fiskville has been responsible for monitoring the implementation of the 10 IFI recommendations, 11 CFA Board Initiative and 18 recommendations arising from the Lawrence Review of Regional Training Grounds (Campuses). Considerable progress has been made with regard to the progression and implementation of the recommendation and initiatives with only a small number still to be finalised. The relevant evidence as to initiation of the recommendations and initiatives has been viewed by the Independent Monitor – Fiskville. For those recommendations and initiatives that have been implemented, the relevant evidence as to implementation has been sighted by the Independent Monitor – Fiskville.

IFI Report Recommendations

Progress on the IFI recommendations has been significant. Of the 10 recommendations made by Professor Joy, 9 have been actioned and completed, refer to Appendix “A”. At the time of writing the following recommendation, whilst it has been actioned, is yet to be completed: Recommendation 8 That historical landfill 1 which has been disturbed by the construction of a walking track have its extent clearly identified, have an appropriate impermeable and properly drained cap constructed and be revegetated with shallow rooting species that will not compromise the integrity of the cap. This should ensure the safety of any people using the walking track. Actioned - Cardno Lane Piper prepared and submitted a report “Investigation of Risks at Former Landfills” that found no risks associated with the landfills. The results of the landfill assessments conclude that there is negligible risk to groundwater and negligible risk to site users and residents as a result of landfill gas.


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The report was reviewed by the EPA-appointed Environmental Auditor as a part of his 53V Audit of Fiskville. The report was published on the EPA website on 7 July 2014 as an appendix to the EPA-appointed Environmental Auditor’s Report.

The remediation of this area is to be subject to future works at Fiskville which are yet to be progressed.

Recommendation 1:

That the Executive Director, Informing The Future Program, be responsible for the on-going monitoring and reporting of the outstanding IFI recommendation.

Board Initiatives

Of the 11 CFA Board initiatives that were instituted by the Board in June 2012, 10 have been actioned and implemented, refer Appendix “B”. At the time of writing, 1 initiative remains outstanding: Initiative 2: Implementing ISO 14001 Environmental Management and along with AS4801 Occupational Health and Safety strive to gain accreditation in these business processes. Actioned - This initiative commenced in 2013 and will be on-going until December 2016. On 5 February, 2015, a “Governance and Planning Workshop” for the leadership group was held at the Boronia Fire Station. That workshop was subsequently followed by a further workshop for the Training Campuses on 14 May 2015.

Recommendation 2:

That the Executive Director, Informing The Future Program, be responsible for the on-going monitoring and reporting of the implementation of ISO 14001 Environmental Management and AS4801 Occupational Health and Safety (Board Initiative 2).


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Lawrence Report Recommendations

Of the 18 recommendations from the Lawrence Review of Regional Training Campuses, 14 have been actioned and implemented, refer Appendix “C”.

At the time of writing, the following recommendations remain outstanding:

Recommendation 9 That CFA develop a strategy to plan, fund, build and maintain and effective water supply system appropriate for each regional training ground.

Actioned - Significant preliminary work and planning has been undertaken to date. Immediate measures were implemented at all campuses in July 2012 to ensure the quality of water supply in the interim whilst a long term strategy is developed and implemented. Interim investments have been made to ensure sufficient water supply capacity exists to support training. Scheduled completion date is 30th June 2017.

Recommendation 11 That CFA develop medical/physical standards or guideline for trainees participating in arduous training regimes such as search and rescue. Actioned - This is a matter that spans Directorates and is a significant project. Accountability for this Lawrence recommendation does not fit within OT&V. OT&V cannot mandate a medical/physical fitness standard for trainees in isolation from Fire & Emergency Management and the ED People & Culture.

Recommendation 12

That CFA develop an appropriate State wide strategy for planning, construction and maintenance of practical hot fire training facilities, including mobile facilities. Actioned – The formal Mobile Trial is now completed, and a feedback report has been finalised and distributed. Based on this feedback, a decision was made to procure mobile training props. The props are currently being manufactured at Geelong. In addition, the ED OT&V will create and fill a permanent, senior Facilities Manager position within the OT&V structure with responsibility for managing all training campuses across the state. This will include responsibility for developing and implementing a state-wide strategy for planning, construction and maintenance of practical hot fire training facilities including mobile facilities. In June 2014 a Facilities Management System (FMS) was purchased for the Training Campuses. This system will provide central access to campus infrastructure thereby supporting the pursuit of a standardised approach across the State for planning, construction & maintenance. A significant 10 year funding bid has also been submitted to the Department of Treasury and Finance to support the strategy. This recommendation is in progress and is subject to funding.


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Recommendation 16

That CFA lay concrete in PAD areas exposed to flammable liquid fuels. Actioned -. This work is dependent upon prior completion of environmental remediation works that may be required. Environmental assessments have been undertaken and recommended remediation actions are being considered and prioritised. In the interim, concrete has been poured to address an urgent requirement at Longerenong campus. This recommendation is in progress and is subject to funding.

Recommendation 3:

That the Executive Director, Informing The Future Program, be responsible for the on-going monitoring and reporting of the outstanding Lawrence Report recommendations.

Recommendations from Cardno Lane Piper and 53V Audit Reports.

A large number of recommendations have resulted arising from the various Cardno Lane Piper reports relating to Fiskville. There are further recommendations arising from the Environmental Auditor (53V Audit Report) that require action by the CFA. These recommendations are detailed at Appendix “D” and the program of work for addressing these recommendations is described further below in the section titled ‘Fiskville Works’. The Auditor’s recommendations are subject to review and verification by the Environmental Auditor.

Cardno Lane Piper have recommended further actions to be undertaken as a result of their targeted site assessments of each of the six Regional Training Campuses. A high level plan has been drafted and a project has been initiated and resourced to implement these recommendations.

Going forward, these recommendations will need to be managed so as to ensure they are addressed.

Recommendation 4:

That the Executive Director, Informing The Future Program, be responsible for the on-going monitoring and reporting of the outstanding recommendations arising from the Cardno Lane Piper work and the 53V Audit Report.


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EPA Clean Up Notice and Environmental Auditor (53V) Report

The EPA issued two Requirement of Clean Up Notices to CFA, dated 22 January 2013 (Notice IDs: 90003319 and 90003174). These Clean Up Notices were later revoked and superseded by Notices 90004570 and 90004571, dated 31 December 2013. The notices require two environmental audits to be undertaken. The first audit is an assessment of risk and was completed in 2014 as per the requirements of the Clean Up Notice. The second audit is an assessment of the site’s suitability for use and is due in June 2017. The first of the two environmental audits has been undertaken and the resulting Environmental Audit Report prepared by an Environment Protection Authority Victoria (EPA) appointed Environmental Auditor – Contaminated Land, of AECOM Australia Pty Ltd (AECOM), at the request of the Country Fire Authority (CFA). This report has been prepared pursuant to Section 53V of the Environment Protection Act 1970 (EP Act) , and relates to the CFA Fiskville Training College, located at 4549 Geelong – Ballan Road, Fiskville, Victoria (the Site). The Audit is a requirement of a Clean Up Notice issued to CFA, dated 31 December 2013. In undertaking the audit the auditor considered the work that had been undertaken by Cardno Lane Piper. In addition, the auditor conducted his own testing and analysis in order to draw his own conclusions. The EPA-appointed Environmental Auditor supported the findings of Cardno Lane Piper namely:

Minor soil contamination was identified on-site at Fiskville and very minor levels immediately off-site, none of which presents a human health risk or an impediment to continued use of the site for fire-fighting training.

It is highly unlikely that the fire-fighting training activities at the site have resulted in any significant contamination of groundwater in the area.

A small area of saturated soil (about 1-3 metres deep around one of the dams) contains residues from foams used in past fire training. However, this is not significant and does not present a human health risk.

No buried drums were found in any of the areas identified in Professor Joy’s Report. If drums are still buried anywhere on site, there is only a minor potential for them to be a source of impact to groundwater as it occurs at a considerable depth (over 60 meters below surface level).


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Fiskville’s landfills do not present a risk to groundwater, site-users or local residents.

Surface water and sediment testing has confirmed Professor Joy’s findings that Dams 1 – 4 and Lake Fiskville contain Perflourooctane Sulfonate (PFOS) and Perflurooctanoic Acid (PFOA), and that residues have moved off-site via Lake Fiskville and are subject to significant dilution as they move downstream.

Outcomes of extensive scientific testing of the risks associated with direct exposures to this water and sediments (such as from swimming, drinking and hot fire training) or secondary exposures (such as from eating fish, produce or meat from livestock exposed to this water and sediment) have confirmed:

o Human health risks from potential exposures to these Perfluorinated Compounds (PFC) residues on-site at Fiskville and downstream are low and acceptable.

o Produce grown on properties downstream from Fiskville, including meat, is safe for human consumption. This has been confirmed by Victoria’s health and food safety authorities.

o The historical use of Fiskville dam water for fire training does not present a risk to CFA staff, volunteers, site visitors or occupants (noting this source of water is no longer used and that town mains water has been used solely since late June 2012 until site closure in March 2015).

There is evidence of bioaccumulation of Perfluorinated Compounds (PFCs) in aquatic biota in Lake Fiskville, and while biota was not found in the Beremboke Creek and Eclipse Creek it is assumed that if any were present they would be likely to have accumulated PFCs. There is very limited evidence of bioaccumulation of PFCs in very small concentrations in fish from a site on the Moorabool River. The outcomes of Cardno’s assessments of the aquatic ecology in these water bodies conclude that the ecological risk is considered low to moderate. The low to moderate risks to the aquatic ecology include possible impacts on fish and other aquatic species in Lake Fiskville and the consumption of these species by higher order organisms (such as birds of prey).

The EPA-appointed Environmental Auditor has concluded in his audit report that steps already planned by CFA and underway to remediate the site will reduce the risks.


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Results of all the assessments, by both the EPA Auditor and Cardno Lane Piper, confirm that while residues from historical use of firefighting foams no longer in use by CFA at Fiskville have been detected, they exist in concentrations very unlikely to pose any risk to human health – both at Fiskville and downstream.

The EPA-appointed Environmental Auditor’s recommendations include measures to stop further discharges of water from the water management system and Lake Fiskville and implement measures to remediate and manage the surface water and sediments in Lake Fiskville and the dams linked to the lake. The first stage of this work has been undertaken with storm-water and creek diversion works and the creation of a wetland at Fiskville. It has since been identified that the integrity of the storm-water and wetland works have been compromised and there is potential for PFCs to discharge into the Beremboke Creek (refer below).

The recommendations of the EPA-appointed Environmental Auditor are detailed at Appendix “D”.

Fiskville Works

As mentioned above a large number of recommendations have resulted arising from the various Cardno Lane Piper reports and the Environmental Auditor (53V Audit Report) that require action by the CFA. These recommendations are detailed at Appendix “D” and documented within a program of work referred to as the ‘Clean Up Plan’ as per requirements of the Clean Up Notices issued by EPA in 2013. The Clean Up Plan was prepared by CFA, endorsed by the Environmental Auditor and approved by the EPA on 18 July 2014. The Clean Up Plan is organised into six stages of work and incorporates recommendations made by Cardno Lane Piper, recommendations of the Environmental Auditor (53V Audit Report) and the requirement to conduct a second environmental audit of the Fiskville site.

As this work is in response to the EPA Clean Up Notices and recommendations from the Environmental Auditor’s 53V Audit Report, oversight of the completion of the works will be undertaken by the EPA, and will not be the responsibility of the Independent Monitor Fiskville

Stage 1

Stage 1 works were undertaken to prevent training water flowing downstream from Lake Fiskville to Beremboke Creek whilst CFA plan and execute remediation works for the site (as outlined in Stage 4). These works were well advanced when the Environmental Auditor issued his environmental audit report in April 2014 in which he made a recommendation to cease discharging water to downstream. The works


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involved the diversion of the Beremboke Creek around Lake Fiskville in order to contain onsite all water that has been used in fire fighting training activities (training water) and prevent it flowing downstream. The storage capacity of the lake was increased by raising (bunding) the sides of the lake. With the water storage system closed, further measures were undertaken to minimise the risk of the lake’s capacity being exceeded and overflowing. These measures involved capturing rainwater and diverting it through stormwater diversion channels, into a purpose built wetland to filter stormwater before it flowed into Beremboke Creek and offsite. The Tender for stage 1 works was awarded to Bitu Mill (Vic) Pty Ltd on 9 December 2013. Works commenced on 8 January 2014 and were completed on 3 July 2014.

Recent testing of the stormwater channels, wetland and Beremeboke Creek have detected PFCs and determined these are seeping into the stormwater channels that border the industrial training area. Those concentrations of PFCs have been similar to those detected in the past and therefore do not represent any change in the risk previously assessed as low and acceptable nonetheless, actions are being taken to address this including shutting off the wetlands so it no longer discharges into Beremboke Creek. Once this work has been undertaken, further water testing of Beremboke Creek will need to be undertaken.

Stage 2

Stage 2 requires further environmental assessments to be undertaken. These will address recommendations from the Environmental Auditor (53V Audit Report) and will also satisfy the second of two environmental audits as required by the Clean Up Notices issued by EPA in 2013. The second audit will consider the entirety of the site in accordance with section 53X of the Environment Protection Act. This work commenced in January 2015.

Stage 3

Stage 3 addresses one recommendation from the Environmental Auditor (53V Audit Report) requiring communications to the people living and working downstream of Fiskville. This stage was completed in October 2014.

Stage 4 works

Stage 4 addresses remediating the site to address environmental impacts caused by hot fire fighting training activities, particularly those activities that involved foams which were in use until 2007.

An Expression Of Interest (EOI) was issued on 8 October 2014 to the open market on the Tenders Vic Website. The EOI was the first stage of a multi-stage tender process


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to identify prospective tenderers that had suitable capacity, capability and experience to design, construct and implement solutions to:

Upgrade water treatment infrastructure on the hot fire training PAD to appropriately treat training waste water generated during ongoing hot fire training to a standard suitable for either release to the environment or recirculation and reuse for training;

Remediate the surface waters in Dams 1-4 and Lake Fiskville;

Remediate perched groundwater in the scoria between the dams and also at the southern end of Lake Fiskville; and to

Remediate the sediments in Dams 1-4 and Lake Fiskville.

This is the first step in working towards satisfying several recommendations made by the EPA-appointed Environmental Auditor (53V Audit Report) for Fiskville in relation to remedial activities. The EOI resulted in 10 responses from organisations that demonstrate expertise to complete the works.

As a multi stage procurement process for remediation works was currently underway at the time of the Site closure being announced in March 2015, independent legal and specialist probity advice was obtained regarding the effect of the site closure on the current procurement process. Due to the large changes in scope and project value, the current procurement process has been terminated and a new Open Market process will be established.

With the closure of the Fiskville facility on 26 March 2015, the scope of the future remediation works to be undertaken under the Stage 4 works is being redefined and will be subject to regulatory compliance with EPA. These works will be substantial as CFA are required to remediate the site regardless of operational activity.

Stage 5 works

Stage 5 involves the development and implementation of management plans and operational controls to minimise risk and provide advice for handling issues as they arise. This work is underway and is closely aligned to, and overlaps with, the Health, Safety and Environment Management System being developed to address Board initiative 2.


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Stage 6 works

Stage 6 addresses the requirement to ensure the quality of surface water bodies at the site and those discharging downstream are monitored. This work has commenced and will continue ongoing at least until, and possibly beyond, remediation of the site being completed (as per Stage 4).

Health Initiatives

Arising from the CFA Board’s considerations of the IFI Report, the Board established initiatives, two of which are relevant to the health of past and present employees and volunteers.

Health Surveillance Program

The CFA established a health program involving an annual medical (including pathology) in late 2012 and offered to individuals identified as being in the high or medium risk of exposure groups in the IFI Report. It is a five years program and the participants were subject to medical examination by their own GP or the CFA Doctor.

not all those who were offered the Program have taken up the offer;

some did not take up the offer initially, but did at a later time; and

some who accepted the offer, later withdrew from the program.

The following table shows the status of the Program as at 25 Feb 2015, based on information provided by the CFA Health Surveillance Co-ordinator.


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Risk of exposure group

Number of individuals offered the Program

Number of individuals that have accepted the offer

Number of annual medicals undertaken by individuals to date

High Risk 87

68

Zero medicals: 2

One medical: 12

Two medicals: 29

Three medicals: 25

Family members (of the High risk Group)

8 7 Two medicals: 7

Medium 257 158 Zero medicals: 20

One medical: 45

Two medicals: 82

Three medicals: 11

Total 352 233

This Health Surveillance Program is the only outstanding CFA Board initiative and will be on-going until 2017.

Recommendation: 5

That the CFA Board assigns responsibility to the Executive Director, People and Volunteerism for the on-going Health Surveillance Program monitoring and reporting.

Monash Study The Monash Centre for Occupational and Environmental Health (MonCOEH) School of Public Health & Preventive Medicine undertook a health study relative to those CFA staff and volunteers who were identified in the high, medium and low risk groups in the IFI Report.

The findings of the study were presented to the CFA in December 2014 and subsequently released publicly. The study found higher than expected rates of


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skin, testicular and brain cancer. However, when compared with the Victorian community, the overall incidence of cancer was not higher for the study group as a whole.

The summary at pages 4 & 5 of that report in part stated:- “The CFA assembled a data set of five women, and 611 men who had either been trainers or had been trained at Fiskville between 1971 and 1999. These individuals were categorized into High, Medium and Low groups by the CFA. Two women did not appear to have been involved in training at Fiskville and were excluded from the cohort. In addition, there were eight men who had no date of birth, who were excluded due to difficulty linking with the cancer and death registries. The final cohort of 606 people included three women, and had 95 men in the High group, 256 men in the Medium group (105 career firefighters and 151 volunteer firefighters) and 252 men in the Low group. The cohort was linked to the National Death Index and Australian Cancer Database (both held by the Australian Institute for Health and Welfare) and to the Victorian Cancer Registry. No deaths or cancers were identified for the three women in the cohort. There were 28 deaths and 69 cancers identified among the men in the cohort. When compared to the Victorian population, higher than expected cancer rates were observed for melanoma and cancer of the testis in the High group and for brain cancer in the Medium group. When compared to the Victorian population and to the Australian-born Victorian population, the overall cancer risk was significantly raised for the High group, it was similar to that of both these reference groups for the Medium group and was significantly reduced for the Low group. When compared to the Low group, there was a statistically significantly increased cancer risk for the Medium and High groups, but the number of cancers in the Low group was very small, resulting in a lot of imprecision in the results and this is likely to impact on the robustness of these findings. When compared to the general Australian population, the overall mortality was statistically significantly decreased for the whole cohort and for the Low and Medium groups within the cohort. This reduction in mortality may be due, at least in part, to the healthy worker effect. For the Low group and the volunteer firefighters in the Medium group in particular, the low mortality may also be a result of an ascertainment bias, that is some individuals who had died may have been less likely to have been identified and included in the cohort. The mortality for the career Medium group and the High group was also reduced but not statistically significantly so.”

A similar study undertaken by Cancer Council Victoria of people who worked and trained at Fiskville during the period 1971-1999 was released in June 2014. That study found that this same study group as a whole did not develop cancer at a higher rate than the general population of Victoria, and identified melanoma and cancer of the testis as the most common cancers in the ‘high’ and ‘medium’ groups.


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Appendix “A “

IFI Report Recommendations

Recommendation 1

That soil and groundwater quality be assessed in areas where fuel storage tanks are currently located or have been located in the past both above and below ground.

COMPLETED - Cardno Lane Piper has completed and presented two reports relative soil and ground water assessments, namely “Site History Review” and “Targeted Soil Assessment”. Those reports identified minor soil contamination on site at Fiskville and very minor levels immediately offsite, none of which presents a human health risk or an impediment to continued use of the site for fire-fighting training.

The reports were reviewed by the EPA-appointed Environmental Auditor as a part of his 53V Audit of Fiskville. The reports were published on the EPA website on 7 July 2014 as an appendix to the EPA-appointed Environmental Auditor’s Report. Recommendation 2 That groundwater investigations be undertaken in the vicinity of: the historical flammable liquids PAD (Practical Area for Drills); the fuel mixing area; the historical foam training pits; the prop storage area; and the area used to rehabilitate contaminated soils in 1998.

COMPLETED - Cardno Lane Piper completed and submitted a report that found no contamination of groundwater. The report was reviewed by the EPA-appointed Environmental Auditor as a part of his 53V Audit of Fiskville. The reports were published on the EPA website on 7 July 2014 as an appendix to the EPA-appointed Environmental Auditor’s Report.

Recommendation 3

That further investigation be undertaken into surface waters in and discharging from Lake Fiskville to:

better quantify the risk to downstream human health receptors, taking into account downstream dilution and environmental fate and transport mechanisms;

investigate potential sources of PFOA and PFOS discharges to Lake Fiskville and discharging off site, if the potential risk of adverse impact on downstream human health receptors is found to be unacceptable;


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collect surface water samples at a representative location to assess whether the reported copper and zinc concentrations are consistent with background levels; and

Assess the ecological condition of Lake Fiskville.

COMPLETED - Cardno Lane Piper has prepared and submitted two reports, namely “Surface Water and Sediment Contamination Assessment – Onsite” and “Surface Water and Sediment Contamination Assessment – Downstream”. The reports confirmed that human health risks from potential exposures to Perfluorinated Compounds (PFC) residues on-site at Fiskville and downstream are low and acceptable.

A report relative to the ecological condition of Lake Fiskville found that the ecological risk is considered low to moderate.

Reports, namely “Human Health Risk Assessment – CFA Training Personnel” and “Human Health Risk Assessment – Fiskville Community” found that the risks of health effects arising from exposure to PFC’s in water used for firefighting training at Fiskville are negligible.

A report “Human Health Risk Assessment – Offsite Downstream” found that risks of health effects arising from downstream water contamination are very unlikely.

The reports were reviewed by the EPA-appointed Environmental Auditor as a part of his 53V Audit of Fiskville. The reports were published on the EPA website on 7 July 2014 as an appendix to the EPA-appointed Environmental Auditor’s Report.

Recommendation 4 That any electrical transformers located at any CFA training sites be inspected by an independent hygienist and, if not able to be certified as PCB-free under the National Polychlorinated Biphenyls Management Plan 2003, that it be treated as a scheduled waste and disposed of in accordance with the provisions of the Plan.

COMPLETED - All transformers have been removed and replaced with replicas. None were found to contain PCB’s1, and all have been appropriately disposed of in accordance with EPA requirements.

Exposure of People On and Off Site Recommendation 5 That any subsequent study of possible linkages between exposure of persons during training at Fiskville to materials such as flammable liquids and health effects evaluate the usefulness of the qualitative assessment of relative risk of exposure of different groups developed in Chapter 7.

1 Polychlorinated Biphenyl


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COMPLETED - Reports, namely “Human Health Risk Assessment – CFA Training Personnel” and “Human Health Risk Assessment – Fiskville Community” found that the risks of health effects arising from exposure to PFC’s in water used for firefighting training at Fiskville are negligible.

The reports were reviewed by the EPA-appointed Environmental Auditor as a part of his 53V Audit of Fiskville. The reports were published on the EPA website on 7 July 2014 as an appendix to the EPA-appointed Environmental Auditor’s Report.

Monash University Centre for Occupational and Environmental Health has been engaged by CFA to undertake the CFA Cancer Incidence and Mortality Study - Fiskville, which will examine the incidence of cancer and causes of death of those identified by the Professor Rob Joy Report in the moderate and high risk category of exposure to chemicals. Report on the findings is expected in late 2014.

CFA has initiated a Health Surveillance Program for all those identified as being in the high and medium risk exposure groups. This program is on-going.

Recommendation 6

That procedures be put in place to protect the health of personnel potentially exposed to waters and sediments in Dams 1 and 2 of the firewater treatment system and, in particular, to manage the risks to individuals who have the potential to come into contact with sediments in the dams during routine maintenance.

COMPLETED - Risks have been identified and controls have been implemented in consultation with WorkSafe. On 3rd October 2012, WorkSafe advised that compliance had been achieved.

CFA ceased the use of dam water for hot fire training on 26th July 2012 and switched to the sole use of town mains water, which is stored in two fully enclosed above ground tanks.

Fire Training Water Systems standing operating procedures have been reviewed and new procedures implemented.

Cardno Lane Piper submitted a letter outlining their findings which has been reviewed by the EPA-appointed Environmental Auditor as a part of his 53V Audit of Fiskville. The report was published on the EPA website on 7 July 2014 as an appendix to the EPA-appointed Environmental Auditor’s Report.


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Buried Drums Recommendation 7 That soil and groundwater quality be assessed in the following areas that were not examined during the site investigation stage of the Preliminary Site Assessment of Fiskville (see Figure 8.1)2:

Part of Drum Burial Area 1 (south of the Airstrip and south of Deep Creek Road);

Drum Burial Area 2 (north of the Administration Building);

Drum Burial Area 3 (east of the Administration Building)

Historical landfills 1 and 2.

COMPLETED - Cardno Lane Piper prepared and submitted a report “Buried Drums Assessment” that identified that no buried drums were found in the areas identified by Professor Joy.

That report was reviewed by the EPA-appointed Environmental Auditor as a part of his 53V Audit of Fiskville. The report was published on the EPA website on 7 July 2014 as an appendix to the EPA-appointed Environmental Auditor’s Report. Recommendation 8 That historical landfill 1 which has been disturbed by the construction of a walking track have its extent clearly identified, have an appropriate impermeable and properly drained cap constructed and be revegetated with shallow rooting species that will not compromise the integrity of the cap. This should ensure the safety of any people using the walking track. ACTIONED - Cardno Lane Piper prepared and submitted a report “Investigation of Risks at Former Landfills” that found no risks associated with the landfills. The results of the landfill assessments conclude that there is negligible risk to groundwater and negligible risk to site users and residents as a result of landfill gas.

The report was reviewed by the EPA-appointed Environmental Auditor as a part of his 53V Audit of Fiskville. The report was published on the EPA website on 7 July 2014 as an appendix to the EPA-appointed Environmental Auditor’s Report.

The remediation of this area is to be subject to future works at Fiskville which are yet to be progressed.

2 IFI Report pg 101.


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Recommendation 9 That any decision on the future management of historical landfill 2, including possible exhumation of buried drums and further site rehabilitation, await the results of soil and groundwater quality assessment at the site (Recommendation 8). COMPLETED - Assessment completed – as noted above for Recommendation 8.

Regional Training Grounds

Recommendation 10

That the site specific recommendations of the Golder Associates’ Preliminary Site Assessment – CFA Regional Training Grounds be adopted including recommendations to:

Undertake targeted soil and groundwater investigations at sites where possible sources of contamination have been identified;

Assess fire fighting water quality for contaminants associated with flammable liquids and extinguisher foams;

Assess water quality where discharges occur to the environment. COMPLETED -

Cardno Lane Piper has undertaken targeted environmental assessments of each of the Training Campuses detailing remediation works required to be undertaken.

A draft “Action Plan” has been prepared to address:

a) recommendations by Cardno as part of their targeted site assessments in 2012 (targeted to specific areas identified by Prof Joy as greatest risk) and

b) additional recommendations made in 2015 taking into account each site in its entirety (not just targeted to specific areas).

A Project Manager has been appointed to manage these recommendations going forward.


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Appendix “B “

CFA Board Initiatives

INITIATIVE STATUS

1 Establish a Board Committee for OHS&E that will also have independent membership with relevant expertise.

COMPLETED First Committee meeting held 1 October 2012

2 Implementing ISO 14001 Environmental Management and along with AS4801 Occupational Health and Safety strive to gain accreditation in these business processes.

COMMENCED – The ISO 14001 project has commenced and is being led by the newly appointed Environmental Adviser. The AS4801 project commenced in July 2013 and is striving to achieve accreditation in these business processes for all training campuses by December 2016. This initiative is ongoing and as such cannot be finalised within this report.

3 Include a Standing Item on Board agenda’s relating to progress reports on implementation of the Report.

COMPLETED Agenda item established.

4 Arrange for external independent audit of our actions to implement the Professor Joy Report and making the audit results publically available.

COMPLETED Independent Monitor appointed February 2013.

5 Acquire specialist personnel around environmental management to support personnel who are already working on health and safety, and increase the presence across the State around OHS&E.

COMPLETED Environmental Advisor appointed December 2012.


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6 Allocate the executive responsibility and management and control for all Training Grounds with the Executive Director Operational Training and Volunteerism. The Regional Site Review issues and recommendations will be considered, assessed and implemented by OT&V in a manner that is complimentary to the Professor Joy Report and recommendations.

COMPLETED Transition finalised on 1 July 2013.

7 Provide project management capability for the implementation of recommendations.

COMPLETED Program Manager appointed August 2012.

8 Provide health monitoring for those identified as being in a high or medium risk of exposure group.

COMPLETED Health Surveillance Program established September 2012.

9 Commissioning a health impact study to examine the linkages between the risk of exposure to hazardous materials at Fiskville and health effects.

COMPLETED Monash Health Study completed December 2014.

10 Provide Information Packs to CFA members and families outlining the support services available.

COMPLETED Information packs placed on CFA Website in July 2012.

11 Make Information Packs available for the public which will incorporate details on accessing community based services. These packs are intended to target those in the community who feel they could be affected by their involvement with Fiskville or because they live or work close to Fiskville training facility.

COMPLETED Information packs placed on CFA Website in July 2012.


27

Appendix “C“

Lawrence Report Recommendations

Recommendation Action Timeframe

1. It is recommended that CFA review the operation of the Training Grounds Standards Committee including its Terms of Reference and ensure that this committee meets regularly, actively sets standards, monitors compliance and meets the needs of the Chief Officer, OT and V, Managers and users of training grounds across the State of Victoria.

Action: As part of the Regional Training Campus transition the Training Grounds Standards Committee shall be replaced by a Training Campus Health, Safety & Environment Committee (TCHSE) that will focus on standards and compliance across training campuses. This committee will meet on a regular basis at least three monthly. Status: The TCHSE Committee has been established to replace the Standards Committee. Terms of Reference for the Committee have been established. The first meeting of the TCHSE Committee was held on the 25

th September 2013. The TCHSE Committee has a

membership of Health & Safety Representatives from Fiskville, Bangholme and Regional Training Campuses and there are also three Management Representatives. The TCHSE Committee has linkages upward into the CFA Board HSE Sub- Committee through the Director People & Culture and downward into existing Campus HSE Committees.

Completed


28


2. It is recommended that where audits, investigations, reports etcetera are completed and actions, findings or recommendations are made, establish governance arrangements that ensures senior management are informed on the status.

Action: Establish governance arrangements that ensure senior management are informed on the status of audits, investigations, reports etcetera. Status: Under normal operations, the relevant Executive Manager (i.e. the one that commissioned the report or investigation) is responsible for establishing governance arrangements, or delegating this to an appropriate person or body. The TCHSE Committee is responsible for managing the outcomes (actions, findings or recommendations) of Health, Safety and Environment audits and reporting to management on the status of outcomes. This is documented within the HSEMS document titled ‘HSE Roles, Responsibility & Committees’. The Training Campus Health Safety & Environment Committee has been established and held its first meeting on 25

th

September 2013. The CFA Corporate CIRT

3 Program has also been

established by Performance & Strategy Directorate to assist with such monitoring and reporting for future audits, investigations, etc.

Completed

3 The Commission and Inquiry Recommendation Traceability Program (CIRT) is managed by the CFA

Enterprise Program Management Office (Performance & Strategy directorate). CIRT provides the tools and processes to capture the recommendations and the subsequent actions that are taken.


29


3. It is recommended that where audits, investigations, reports etcetera are completed and actions, findings or recommendations are made, ensure a system is established that ensures action plans are completed and regularly reported on to management.

Action: Establish a system that ensures action plans are completed and regularly reported on to management. Status: Under normal operations, bodies to which responsibility is delegated (as per Recommendation 2 above) are required to establish the monitoring and reporting processes. The TCHSE Committee referred to in Recommendation 1 and 2 above will be required to monitor and report on outcomes of Health, Safety and Environment audits and subsequent activities to address those outcomes, and that the body to who they report is responsible for sign off on completion of the subsequent activities. The Training Campus Health Safety & Environment Committee has been established and held its first meeting on 25

th September 2013.

The CFA Corporate CIRT

4 Program has also been

established by Performance & Strategy Directorate to assist with such monitoring and reporting for future audits, investigations, etc.

Completed

4. It is recommended that CFA provide appropriate training for PAD supervisors, PAD staff and Instructors to ensure currency of knowledge on legislative requirements for Dangerous Goods & Hazardous Substances Storage and Handling.

Action: A suitable course be sourced and delivered on an ongoing basis for PAD Supervisors/PAD Staff and Campus based Instructors to maintain currency in this field. Status: Appropriate courses were identified with provider Wynsafe and were delivered at each Campus to relevant staff commencing in March 2014. Wynsafe will inform CFA when new/updated training is necessary (eg. as legislation changes).

Completed

4 The Commission and Inquiry Recommendation Traceability Program (CIRT) is managed by the CFA

Enterprise Program Management Office (Performance & Strategy directorate). CIRT provides the tools and processes to capture the recommendations and the subsequent actions that are taken.


30


5. It is recommended that CFA provide appropriate training for PAD supervisors, PAD staff and Instructors to ensure currency of knowledge on legislative requirements for occupational Health & Safety. .

Action: A suitable course be sourced and delivered on an ongoing basis for PAD Supervisors/PAD Staff and Campus based Instructors to maintain currency in this field Review current qualifications of campus permanent staff and ensure they have completed the OH&S course. Where they have not completed the course arrange enrolment. Status: Courses were identified with provider Interactive Training Services Pty Ltd and were delivered at each Campus to relevant staff commencing in March 2014.

Completed

6. It is recommended that CFA review the Field Training Ground Management Manual for currency.

Action: Conduct review of the Field Training Ground Manual. Status: Funding was secured and Cube Consulting was engaged to conduct the review and their report on the review of the Field Training Ground Manual has been tabled. “A day in the life of a PAD Supervisor” Workshop has been completed with Chapter headings and ownership for development of content identified. The outcome of the CUBE Review is being addressed by Informing the Future Team’s Project 12, which is focussing on developing and implementing a Health Safety & Environment Management System that is compliant with AS4801 and ISO 14001.

Completed

7. It is recommended that CFA establish an ongoing process for review of the Field Training Ground Management Manual that requires reporting to senior management.

Action: Establish an ongoing process for review of the Field Training Ground Management Manual that requires reporting to senior management. Status: As per Recommendation 6 above, the outcome of the CUBE Review is being addressed by Informing the Future Team’s Project 12, which is focussing on developing and implementing a Health Safety & Environment System. This will deliver work instructions and procedures and a process for ongoing review and development. See ITFP project 12 for status.

Transferred to ITFP project 12


31


8. It is recommended that CFA conduct ongoing research on best practice for delivery of realistic hot fire training including latest development of props, fuels etcetera.

Action: 1. Arrange for CFA Training Campus personnel to

tour other facilities and exchange learnings regarding best practice hot fire training delivery.

2. Undertake research into alternative Hot Fire Training fuel.

3. Create a fill a new position for a professional Facilities Manager of all training campuses and embed responsibility for ongoing research into their position accountabilities.

Status: The Fiskville PAD Supervisor and OM Training Delivery recently visited hot fire training facilities in America and NZ to conduct research and share learnings. Biodiesel testing was completed at Bangholme Campus on 20/11/13. The trial concluded the unsatisfactory performance of bio-diesel as a hot fire training fuel due to the difficulty getting it to burn independent of an accelerant. It was determined that Liquid Petroleum Gas (or Natural Gas where it is available) will be the preferred flammable training fuel into the foreseeable future. As the first step, Sunraysia Campus will be designed and built so that LPG is the primary fuel source. Research is undertaken as part on normal campus operations and is done so on an as-needed and opportunistic basis. A systematic process for ongoing research is yet to be established - this will be aided by the implementation of the Training Campus Health, Safety and Environment System and possibly by the mid-2014 centralisation of all Victorian emergency management training facilities under the umbrella of the newly established Emergency Management Victoria (EMV). On 11 February 2015, ED OT&V and Program Manager Informing the Future met with the CEO of the Facilities Management Association of Australia. The purpose of the meeting was to seek his advice regarding a process for creating and filling a permanent, senior Facilities Manager position within OT&V responsible for managing all training campuses across the state.

5

Completed except for establishing a senior Training

Campus Facilities Manager position

5 A re-structure was announced on 19 March 2015 in which OT&V will merge with the People & Culture

directorate and as a result the earlier decision to create this position will need to be reviewed, in the context of this re-structure.


32


9. It is recommended that CFA develop a strategy to plan, fund, build and maintain an effective water supply system appropriate for each regional training ground.

Action: Engage Cardno Lane Piper to prepare ‘fit for purpose’ Water Quality Criteria and a draft Training Campus Water Quality Management Plan (for CFA to customise) for the Training Campuses. Cardno Lane Piper to also complete a Feasibility Study for training water system upgrades at Fiskville and Targeted Environmental Assessments for each campus (including reviews of training water management systems). The outcomes of this work are to be considered by CFA and used as inputs to a strategy and plan for effective water management at each training campus. Status: In July 2012 CFA suspended the recirculation of training water at all campuses and switched to town mains water, except for Bangholme which has a purpose built water treatment system. At this time, the training campus water testing regime was reviewed and updated in accordance with the use of town mains water. The plan, fund and build elements (initial investment) of this recommendation are being addressed by the Informing the Future Program (ITFP) which also addresses recommendations of the IFI:

Cardno completed their Fiskville Feasibility Study in December 2013, and their Water Quality Criteria Report and draft Water Quality Management Plan in March 2014.

CFA have obtained funding (via BERC) and completed stage 1 site works at Fiskville to upgrade the water training management system. An EOI was released to the open market for stage 2 works which will complete the implementation of a fully upgraded training water management system at the Site. This procurement activity was terminated following the closure of the site in March 2015.

Cardno have undertaken Targeted Environmental Assessments for each Regional Training Campus. Environmental advisers have been engaged to assist CFA with the preparation of strategies and plans for implementation.

In progress – to be completed by 30

June 2017


33


9 (continued) Note that completion of the work outlined above is pending Ministerial approval, which may be dependent upon the outcomes of the anticipated Victorian Joint Parliamentary Inquiry into Fiskville. Refer to ITFP project 74 for ongoing status updates. The ongoing funding for these matters is being addressed by OT&V. Centralisation of all training campus assets under OT&V was completed in June 2013 (refer to ITFP project 16) – this was the first step in ensuring training campuses are sufficiently funded in future, and that such investments are made strategically, with a statewide perspective. Funding for assets (including water supply systems) was included in a budget submission (training asset 10-year capital replacement plan totalling $36.6 m) submitted to DTF in November 2014. The maintenance of existing infrastructure is also being addressed by OT&V, and is performed as part of campus operations. Responsibility for the maintenance of new infrastructure being procured by the ITFP rests with ITFP during the commissioning of that infrastructure, and will be transferred to OT&V prior to the completion of the ITFP (in mid-2017). Interim investments have been made as needed, to ensure training campuses remain operational whilst the strategy for an effective water supply system at each campus is developed and implemented:


34


10. It is recommended that CFA review the use of firefighting water at regional training grounds and set, maintain and monitor recommended standards.

Action: Review the use of firefighting water supply at regional training grounds and set, maintain and monitor recommended standards. Current Status: In July 2012 CFA suspended the recirculation of training water at all campuses and switched to town mains water, except for Bangholme which has a purpose built water treatment system. The Training Campus Water Management Plan was reviewed in July 2012 and updated in accordance with the use of town mains water. Results of Training Campus water test results since July 2012 are posted on CFA’s website. On the 26

th

September 2013 pt Environmental delivered training to PAD Supervisors on water testing protocols, interpretation of results & consistency of approach to sampling. Actions for the future: Further / ongoing reviews of Training Campus water management are progressing in accordance with item 9 above.

Completed


35


11. It is recommended that CFA develop medical/physical standards or guidelines for trainees participating in arduous training regimes such as search and rescue.

Action: Develop medical/physical standards or guidelines for trainees participating in arduous training regimes. Status: This is a matter that spans Directorates and is a significant project. Accountability for this Lawrence recommendation does not fit within OT&V. OT&V cannot mandate a medical/physical fitness standard for trainees in isolation from Fire & Emergency Management and the ED People & Culture. In recognition of this, the ED OT&V will prepare a memo to the Chief Officer, F&EM and the ED People & Culture regarding an appropriate process for the development of this standard. It is anticipated this will take quite some time to resolve and will require significant consultation with key stakeholders. In the meantime, this matter was partially addressed via a Heat Stress Management Bulletin issued by the Chief Officer on 20/1/12. In addition, P&C in consultation with OT&V, have agreed to offer Health Support Teams (HSTs) to monitor trainees (including volunteers) whilst undergoing arduous training in particular at training campuses.

Open


36



12. It is recommended that CFA develop an appropriate state wide strategy for planning, construction and maintenance of practical hot fire training facilities including mobile facilities.

Action: Develop a state-wide strategy for planning, construction and maintenance of practical hot fire training facilities including mobile facilities Status: The formal Mobile Trial is now completed, and a feedback report has been finalised and distributed. Based on this feedback, a decision was made to procure mobile training props. The props are currently being manufactured at Geelong. In addition, the ED OT&V will create and fill a permanent, senior Facilities Manager position within the OT&V structure with responsibility for managing all training campuses across the state. This will include responsibility for developing and implementing a state-wide strategy for planning, construction and maintenance of practical hot fire training facilities including mobile facilities.

6

In Progress

Action: Preventative Maintenance Programme (PMP) to be developed as part of campus alignment process to enhance safety standards and reliability of infrastructure. Status: In June 2014 a Facilities Management System (FMS) was purchased for the Training Campuses. This system will provide central access to campus infrastructure thereby supporting the pursuit of a standardised approach across the State for planning, construction & maintenance. A significant 10 year funding bid has also been submitted to the Department of Treasury and Finance to support the strategy.

In Progress


37



EMV has since taken ownership of training campuses and whilst CFA retains responsibility for campus operations and ownership of the CFA training strategy, this issue is now being reconsidered in a broader context (from a state-wide strategic perspective encompassing all VEMTC campuses across agencies). The ED OT&V will create and fill a permanent, senior Facilities Manager position within the OT&V structure with responsibility for managing all training campuses across the state. This will include responsibility for developing and implementing a state-wide strategy for planning, construction and maintenance of practical hot fire training facilities including mobile facilities (in consultation with EMV).

7

13. It is recommended that an appropriate state wide data base be developed to ensure that the following information is officially recorded:-

Type of training conducted at each session;

Type of props used;

Name of each trainee and description of each training scenario and its duration;

Record the use of all flammable liquids, dangerous goods and types of fuel used for simulation; and

Names of instructing personnel, date and time of all training sessions.

Status: This information is being collected in spreadsheets by the RTC Service Centre for all Regional Training Campuses.

Completed


38

14. It is recommended that CFA establish a stringent system of procedures to ensure that any incidents that occur during hot fire training are investigated, documented and distributed to all regional training grounds for reference/implementation.

Action: CFA Safe reports to be completed for accidents and near misses. Completion of these reports is to be actively encouraged. Status: Reporting of accidents and near misses is actively encouraged. At every hot fire training scenario, a PAD operator is paid an allowance to act as a safety officer, and has the responsibility for reporting any near misses or incidents that occur into the CFA Safe system. This is monitored by the Training Campus HSE Committee. At Training Campus HSE Meeting on 25

th

September it was agreed that incidents to be tabled as part of standing agenda item for review and implementation of recommendations across all Campuses.

Completed

15. It is recommended that CFA review the use of flammable liquid fuels used in practical hot fire training and determine whether it is appropriate to utilise LPG or an equivalent instead.

Action: Undertake study into alternative fuels, in particular biodiesel to replace mineral diesel with a significant reduction in environmental impacts. Status: Biodiesel testing has been completed (see attached report from Environmental Advisor). The outcome resulted in a recommendation to move forward with Jet A1 and Kerosene as substitutes for Diesel and reduce the reliance on Unleaded Petrol. A review of campus infrastructure needs will now be undertaken to evaluate impact of this change. The preferred long term strategy will focus on moving to LPG as the preferred fuel for Hot Fire Training

Completed


39

16. It is recommended that CFA lay concrete in PAD areas exposed to flammable liquid fuels.

Action: Programme to be developed to rectify this exposure and funded by installing concrete PAD’s in areas exposed to flammable liquids as required. Status: Cardno Lane Piper has completed Environmental Site Assessments for each Training Campus. These assessments identify remediation works that may be required at Campuses prior to any concrete being laid. Based upon existing knowledge of campus operations we have plans to concrete at Longerenong, Penshurst and Huntly. Concrete has been poured at Longerenong for extinguisher and drum rack hot fire training props to address an urgent requirement. Concrete in PAD areas at campuses will be laid following remedial works and funding approval. A funding bid for the laying of concrete at regional training campuses has been submitted to the Department of Treasury and Finance for years FY2015-16.

In Progress

17. It is recommended that CFA accept and develop an implementation program for all recommendations made in the HAZCON Health & Safety Reviews (Report Nos. 12-0260).

Action: CFA to accept and develop an implementation program for all recommendations made in the HAZCON Health & Safety Reviews Status: The ED OT&V accepted all recommendations from Hazcon and engaged an independent contractor back in early 2012 to implement them. The visitation programme to Campuses has been completed and a status report has been prepared confirming that all physical works improvements have been finalised. There are systems improvements that are in varying states of completion and which are being addressed by Project 12 (HSEMS) of the Informing the Future Program. In April 2015 WorkSafe commenced visits to each campus to follow up on the recommendations made by HAZCON.

Physical works improvements

Completed

Systems improvements transferred to ITFP

project 12


40

18. It is recommended that CFA accept and develop an implementation program for all recommendations made in the Golder Associates Preliminary Site Assessment – CFA Regional Training Grounds- Independent Fiskville Investigation (Report No. 117613201).

Action: Accept and develop an implementation program for all recommendations made in the Golder Associates Preliminary Site Assessment – CFA Regional Training Grounds- Independent Fiskville Investigation Status: In July 2012, CFA engaged Cardno Lane Piper to assist with the implementation of the Golder’s recommendations. As part of this work, Cardno undertook targeted environmental site assessments of each of CFA’s Training Grounds. Cardno’s work addresses all the recommendations made by Golder Associates. It effectively closes out this Lawrence recommendation and recommends further actions to be undertaken. A single risk-based Action Plan for all Regional Training Grounds which addresses all of Cardno’s recommendations has been prepared the implementation of which will be undertaken as new projects within the Informing the Future Program.

Completed


41

Appendix “D “

Summary of recommendations from Cardno Lane Piper investigations and the 53V audit in respect of Fiskville.

Table 1. Summary of recommendations from Cardno Lane Piper investigations

IFI R

eco

mm

en

dat

ion

ID

Cardno Lane Piper Report Name

Cardno Lane Piper Recommendation

Recommendation being addressed by (CUP

Stage of the Clean Up Plan (CUP) or the ITFP

Project number)

1 Site History Review

1. Investigation of the potentially contaminated areas identified in Table 3-4 of this report, if they have not already been assessed in other reports such as the Surface Water & Sediment Contamination Assessment, Groundwater Contamination Assessment, Targeted Soil Assessment, Investigation of Risks at Former Landfills or Buried Drums Assessment and subject to the requirements of the Environmental Protection Authority Auditor.

This recommendation will be considered as we execute CUP Stage 2: Site

Assessments. The final scope of the Site

Assessments will be agreed with the EPA-appointed Auditor.

2. The scope of this further investigation and assessment should be confirmed with the Environmental Protection Authority Environmental Auditor and recorded in a Sampling and Analysis Quality Plan (SAQP) prior to commencement and should be undertaken at the same time as other assessment works to assist with the completion of the section 53X audit.

CUP Stage 2: Site Assessments.

3. The volumetric balance of the soil windrows in the soil compositing area should be assessed by a surveyor to confirm if it is all accounted for on-site (e.g. by comparing initial volume in windrows and current mounds in the driver education training practice area for drills also known as the four wheel drive area).

CUP Stage 2: Site Assessments .

4. It is recommended in relation to the Victoria University of Technology facility that they should discontinue any effluent discharge to Country Fire Authority property (including Dam 1) and be required to plan for management of their liquid effluent independently of Country Fire Authority in the future.

CUP Stage 5:Plans & Procedures


42

5. An Environmental Management Plan should be prepared and implemented by Victoria University of Technology to control and minimise all impacts on the environment including land and water on and off-site from their facility and for management of solid and liquid wastes.


1 Targeted Soil Assessment

1. The soil at the flammable liquid practice area for drills and former foam training pits should be further investigated to delineate the perfluorooctane sulfonate and potentially 6:2 fluorotelomer sulfonate contamination on the periphery of the area remediated in 1998. This includes lateral and vertical delineation at the base of the previously remediated area.


Assessments.

2. While risks to the health of the few persons potentially exposed to soil contaminated with perfluorooctane sulfonate in the flammable liquid practice area for drills and former foam training pits area is assessed to be low, exposures should be minimised through the use of appropriate Occupational Health and Safety procedures where direct contact with soil is likely, such as when cutting grass around Dam 1 or excavating soil near the adjacent oil-water separator.

Project 12 (HSEMS)

3. The potential risk to ecosystems outside the flammable liquid practice area for drills, former foam training pits and soil composting areas due to perfluorooctane sulfonate contaminated soils, as a result of migration of contaminants to stormwater drains, requires further assessment and management by improving the drainage system in the vicinity of Dams 1 and 2.


Assessments. (Note. Once the

assessments are complete any remedial actions will

be addressed by CUP Stage 4:Remediation)

4. The impacted soil at underground storage tank 1 and fuel mixing area should be further investigated to delineate the total petroleum hydrocarbons contamination. The contamination in these areas does not present a health risk, however it is odorous when exposed to air and should be managed by applying Occupational Health and Safety and environmental procedures (to be contained in the proposed Site Contamination Management Plan) if excavation occurs in these limited areas.

This recommendation will be considered as we execute CUP Stage 2: Site Assessments; and Project

12 (HSEMS)

5. The soil beneath aboveground storage tank 2 should be assessed as aboveground storage tank has now been removed.


Assessments.

6. All features listed in “Areas Not Yet Investigated” (refer to Section 4.1.2 of the Cardno Lane Piper’s Site History Review report) which are not included in this investigation, are also recommended for further assessment.


Assessments.

1

Surface Soil Assessment of 4WD drive mound

1. Exposure of trainees to soil (dirt and mud) and any potential contaminants contained within should always be minimised by the use of standard Occupational Health and Safety practices including the use of personal protective equipment.

This has been communicated to campus management and will be included in the HSEMS (being developed by Project 12 (HSEMS))


43

2. The entire area of the driver education training practice area for drills (Feature 21a) or four wheel drive training facility at Fiskville should be assessed for contamination in accordance with the recommendations of the Cardno Lane Piper report on Site History.


Assessments.

1 & 2 Groundwater assessments Fiskville

1. Further work is recommended to investigate the extent of perfluoro compounds contamination in the shallow, perched water in the fill near Dams 1 and 2 and the flammable liquids practice area for drills, and its potential to seep to the stormwater drainage system.

CUP Stage 2: Site Assessments.

2. An assessment of the feasibility of remediating perfluoro compounds contamination in the perched water should be completed after the further investigation of the area, including hydraulic testing of the fill.

CUP Stage 4: Remediation

3. It is possible that some of the new bores installed during 2012 may ‘gain’ groundwater over time. During the next monitoring round, it is recommended that all bores should gauged for water level and, if sufficient water is present, the bores should be developed and sampled to establish a scope for the investigation of regional groundwater.

CUP Stage 2: Site Assessments .

4. While further investigation of the regional aquifers is not required at this time, the Environment Protection Authority Environmental Auditor, engaged recently to audit the site in compliance with an Environment Protection Authority Clean Up Notice, should be consulted to ascertain his requirements for any further investigations.


Assessments.

5. In the event that a Reverse Osmosis water treatment plant is installed at the site, the feasibility of using the plant to treat the deep saline groundwater as a water supply for fire fighter training should be considered.


(RO will be evaluated as part of the procurement process, if RO is selected)

7(1 & 2 )

Buried Drums Assessment

1. In the event that further information becomes available regarding possible drum burial or any discoveries of buried drums are made, the proposed Site Contamination Management Plan and its protocols should be implemented to investigate and manage the issue.


2. Should additional drums be uncovered in the future outside of areas already assessed, further investigation of groundwater is required including the perched water areas if identified.

CUP Stage 5:Plans and Procedures.

3. Perched water identified in drum burial area 1 and drum burial area 2 should also be further investigated as per the recommendation discussed in the Groundwater Contamination Assessment Report, Fiskville Training College to further investigate the presence and quality of the perched water areas at the site.


Assessments.

3

Surface Water and Sediment Contamination Assessment

1. All reasonable measures should be undertaken to reduce or stop further discharge of contaminated water from the water management system at the site, including Lake Fiskville, from discharging to surface waters downstream.

CUP Stage 1: Containment andCUP Stage 4: Remediation.


44

2. Surface soil sampling and testing should be conducted along the ‘former’ drainage lines which connected Dam 1 to Lake Fiskville noted in Section 3.1.


Assessments.

3. Further sediment sampling and testing be undertaken to confirm the extent of perfluoro compounds contamination in the Creek, as well as sediment sampling and testing of farm dams located on the Creek downstream of the Site, to at least sample location CKE on Beremboke Creek.

This was addressed by Cardno with the

downstream assessment that was completed

subsequent to this report - Project 3.

4. The data in this report on water and sediment quality be taken into account in the assessment of ecological or human health risk undertaken for the site or downstream.

This was addressed by Cardno as they completed the three HHRAs and the Ecological assessment -

Project 3a.

5. Assess the potential for nutrients from the sewerage treatment plant (the existing or upgraded unit) to impact on the water quality of Lake Fiskville.


Assessments.

6. Assess the perfluoro compounds contribution from leaching of residual aqueous film forming foam adsorbed onto infrastructure in the practice area for drills;


Assessments.

7. Further surface water and/or sediment assessments should include a selective screening for extended perfluoro compounds also present at the Site.

CUP Stage 2: Site Assessments and

CUP Stage 6: Monitoring.

8. Remediation works should be carried out based on the assessments of risk and the feasibility of remediation, work which is currently underway. Following the conclusion of the feasibility assessment, the most suitable option for remediation and management of surface water and sediments in the on-site water bodies should be implemented.


3

Supplementary Surface Water and Sediment Sampling Downstream

1. As noted in the Surface Water and Sediment Contamination Assessment - it is reiterated here that all reasonable measures should be undertaken to reduce or stop further discharge of contaminated water from the water management system at the Site, including Lake Fiskville, from discharging to surface waters downstream, including monitoring data of surface water flows from Lake Fiskville (time, volumes and duration).

CUP Stage 4: Remediation and

CUP Stage 6: Monitoring

2. Consideration should be given to include extended PFC analysis for future surface water and sediment assessment at the Site.

CUP Stage 2: Site Assessments and


3. Delineate the level of perfluoro compounds concentrations in water and sediment extending downstream between sample location CKE and the confluence of the Beremboke and Eclipse Creeks.


Assessments.


45

3 Aquatic Ecology Assessment

Take all reasonable measures to:

1. Reduce or stop further discharge of contaminated water from the water management system at the site, including Lake Fiskville, from discharging to surface waters downstream. As noted (in Section 6.3) it is understood that plans are being developed to divert creek flow around the lake and undertake remedial works within it.

CUP Stage 1: Containment and

CUP Stage 4: Remediation.

2. Ensure that there is no stocking of fish into Lake Fiskville.

This has been communicated to campus

staff and management and will be formally

documented by CUP Stage 5: Plans and Procedures

Additional work:

1. Undertake further investigations in relation to Moorabool River in the reach downstream of its confluence with Eclipse Creek (and if necessary at appropriate reference locations). Investigations that should be considered include chemical analysis of aquatic biota, quantitative surveys of aquatic macroinvertebrates and ecotoxicological experiments.


Assessments.

2. Undertake further investigations of Beremboke and Eclipse creeks, including the confluence of Eclipse Creek at Moorabool River (this would require access to private property). This investigation would help to facilitate ecological risk assessment and may provide more data on PFOS in aquatic biota to help define a gradient between the Fiskville Training College and Moorabool River. Key objectives would be to: • Confirm presence or absence of any fish in farm dams (or any large, natural pools) occurring downstream of Lake Fiskville • Collect aquatic biota for analysis of contaminants, particularly PFCs • Describe in-channel and riparian habitats • Undertake rapid assessment of in-stream habitats (as described in ANZECC 2000) • Investigate selection of sites for possible longer term quantitative monitoring.


Assessments.

3 & 5

Human Health Risk Assessment - CFA Training Personnel

1. Maintenance activities on Dam 1 and 2 should be designed to involve minimal contact with water and wet sediments. Where maintenance of the dams is required with high potential exposure to sediments, such as clearing vegetation, specific Occupational Health and Safety measures should be implemented that minimise contact with sediments, consistent with existing Site procedural requirements.

Project 12 (HSEMS)

Note. This was initially addressd by ITFP Project 6 and the deliverable now forms part of the HSEMS.

2. OHS protocols should be implemented for workers and visitors accessing the dams for maintenance or monitoring purposes. The minimum procedure would involve the use of waterproof gloves, safety glasses, rubber boots and waders in place of or in addition to normal personal protective equipment used by workers accessing the practice area for drills. This is consistent with Site procedural requirements.

Project 12 (HSEMS)Note. This was

initially addressd by ITFP Project 6 and the

deliverable now forms part of the HSEMS.


46

3. All water used for fire-fighting training must be disinfected prior to use to prevent risk of exposure to microbial pathogens that are likely to be present. This includes the current temporary storage tank system as well as any new system involving other water treatment with or without recirculation of treated water for use in training drills.


4. Routine monitoring of algae should be added to the Water Management Plan for the Site.


N/A Fire Fighting Water Quality Criteria

Nil

3 HHRA - Downstream Users

There are no recommended actions given the conclusions of this HHRA.

3

Human Health Risk Assessment - ONSITE FISKVILLE COMMUNITY

There are no recommended actions given the conclusions of this HHRA and CFA have already implemented relevant management initiatives as listed in Section 1.3. The management initiatives are as follows:• Banning of recreational activities (e.g. fishing, swimming) in water bodies at the site. Lake Fiskville and the dams have been signposted accordingly;• Management authorisation required prior to hunting activities being conducted on The Site;• Investigation into the feasible options for remediation of water bodies at The Site including Lake Fiskville;• Development of a water management strategy to provide clean water and treat contaminated water generated during training; • Altering the training program at the site to minimise the potential contaminant load in to Lake Fiskville; and• Construction of a bypass channel to divert Beremboke Creek around Lake Fiskville. This will prevent its flow through Lake Fiskville so as to minimise discharges from the lake.

The final dot point is addressed by CUP Stage 1 of civil works. All others were completed prior to

the completion of the HHRA.

8 & 9 Landfill assessment

1. The Environmental Protection Authority Environmental Auditor be consulted with regard to the potential requirement for further characterisation of the perched water found within some areas of LF2.


Assessments.

2. The Environmental Protection Authority Environmental Auditor be consulted with regard to the need for any further soil testing at the base of the landfill to demonstrate lack of migration of contamination from the landfill.


Assessments.

3. The adequacy of the Landfill Environmental Management Plan be discussed and agreed with the Environmental Protection Authority Environmental Auditor.


4. Subject to Auditor review, the Country Fire Authority adopts the Landfill Environmental Management Plan, presented in Appendix J of this report, as a guide to the rehabilitation and management of the former landfill area in the south western area of the Country Fire Authority Fiskville Training College.



47

N/A Additional

During remedial works following the Cardno Lane Piper assessments, perched water was also identified in the vicinity of the southern end of Lake Fiskville. This area required further assessment and possibly remediation to identify the extent and contamination status of perched water in this area. Based these findings and on the conclusions and recommendations of s53V Audit, prepare a SAQP sufficient to satisfy the requirement of a s.53X audit of the site.

CUP Stage 2: Site Assessments

and CUP Stage 4: Remediation

Note. There is no

corresponding Auditor rec in the 53V audit report,

however the Auditor has recommended that this be undertaken as part of the

CUP.

Table 2. Summary of recommendations from 53V audit

53V Audit Report

Audit Recommendation

Recommendation being addressed by (CUP

Stage of the Clean Up Plan (CUP) or the ITFP

Project number)

High Priority

1. Undertake measures to cease water from the water management system at the Site (including Lake Fiskville) from discharging to downstream surface waters.

CUP Stage 1: Containment

2. Undertake measures to ensure that the quality of water discharging to waters protected in accordance with SEPP (WoV) meets the appropriate surface water quality criteria.



3. Implement measures to remediate water and sediments in Dams 1 to 4 and Lake Fiskville (including perched water in scoria fill near Dams 1 and 2) so that they are no longer sources of potentially unacceptable ecological risk for ecological effects and contaminated water to downstream waterways.


Fire Water Management

4. Implement measures to remove perched water in the scoria fill sourced from the dams and prevent outflow of Dams 1 and 2 into the scoria fill in future.


5. Monitor the water quality within Dam 1 to Dam 4, Lake Fiskville and downstream waterways as part of an on-going surface water monitoring program to be implemented at the Site in accordance with the WQMP.


6. Implement measures to monitor the volume of water and available storage capacity, as well as timing / duration and volume of discharge to Lake Fiskville and Lake Fiskville to Beremboke Creek.



48

7. Although the quantitative health risk assessment concluded that risks to people on-Site posed by exposure to the reported concentrations of PFCs is low and acceptable, as a precautionary measure it is recommended that existing measures to prevent or minimise exposure to firewater in Dams 1 to 4 and Lake Fiskville be maintained until the water and sediments have been remediated. This includes identifying these water bodies as hazards to all people entering the Site, maintaining signs (no drinking, no swimming, no fishing) and barriers, restricting public access to the Site, as well as regularly reinforcing the hazards to CFA staff.

Measures have been implemented; CFA will

maintain them as recommended

8. As a precautionary approach, it is recommended that water should not be extracted from Lake Fiskville for any use and fish should not be stocked in Lake Fiskville.

Measures have already been

implemented. CFA will implement procedures to

reinforce them in CUP Stage 5: Plans &

Procedures

9. Although human consumption (i.e. drinking) of water from Beremboke and Eclipse Creeks downstream of the Site is considered to be unlikely, the reported concentrations of PFOS in surface water in Beremboke Creek and Eclipse Creek are such that the Auditor recommends that, as a precautionary measure, potential users of water from Beremboke Creek and Eclipse Creek (downstream of the Site) are advised that the water should not be used for human consumption (i.e. drinking water).

CUP Stage 3: Off-site works

Controls on Foams Used

10. Once a foam product has been selected for use at the Site based on the nominated criteria in the Foams review, consideration should be given to undertaking independent chemical validation of the absence of PFC in foam products prior to use on-Site to confirm that the foam does not contain PFOS, PFOA or compounds that break down to PFOS or PFOA in the environment.

CUP Stage 5: Plans & Procedures

11. Consideration should also be given to undertaking independent chemical validation of the absence of PFC in foam products currently stored at the Site to confirm that the foam does not.


Groundwater

12. As a minimum, it is recommended that existing groundwater wells are re-gauged. If they contain sufficient groundwater, the wells will need to be developed, then sampled in accordance with EPA Publication 669 (Groundwater Sampling Guidelines).


13. Undertake further investigation of the potential for live fire training to contaminate regional groundwater, particularly in the vicinity of the PAD, Dams 1 and 2 and Lake Fiskville.


14. It is recommended that the extent and quality of contaminated perched water identified in scoria fill in the vicinity of Dams 1 and 2 and its potential to discharge to the surface (including stormwater drains) be investigated


Buried Drums

15. It is recommended that information regarding the potential for discovery of buried drums at the Site (as well as other waste / sludge disposal) and proposed actions be included in a Site Contamination Management Plan (SCMP).


Note. It may be inferred that this Rec also applies

to CLP Rec 20.


49

Landfills

16. It is recommended that a cover be placed over the Former Landfill Areas. The cover would include placement of compacted clay, a geogrid and top soil followed by revegetation with grass.


17. Following the placement of the cover, it is recommended that the Landfill Environmental Management Plan (LEMP) be implemented.


Storage and Management of Chemicals

18. The storage of all chemicals, drums and props containing chemicals (e.g. vehicles prior to debugging), as well as the debugging of props be undertaken on a sealed and bunded surface.


19. A procedure for managing leaks / ruptures of fuel pipelines should be developed and implemented.


Data Gaps

20. It is recommended that a program of further soil investigation be prepared to address the identified data gaps and enable the degree and extent of soil contamination to be determined.


21. It is recommended that an assessment of the volume of soil remaining in the SCA and the potential fate of the remainder of the remediated material be undertaken.


22. It is recommended that the potential for residual PFCs (from historical live fire training) to leach from existing infrastructure (concrete, pipes, hoses) into storm water and fire water run-off be assessed.


23. It is recommended that further investigation of dioxins and furans in sediments in Lake Fiskville be undertaken to confirm that the limited reported concentrations are representative of sediment within the Lake (and therefore confirm the conclusions relating to human health and ecological risk regarding dioxins and furans).


24. It is recommended that the presence of Bis(2-ethylhexyl)phthalate in various media at the Site and potential implications for beneficial uses be further assessed.


Site History

25. The VUT facility (Feature 31) should discontinue effluent discharge to the CFA property and plan for the management of liquid effluent independently of CFA in the future.

CUP Stage 1: Containment


26. An Environmental Management Plan should be prepared and implemented by VUT to control and minimise all impacts on the environment including land and water on and off-Site from their facility, and for management of solid and liquid wastes.


Additional

27. During remedial works following the Cardno Lane Piper assessments, perched water was also identified in the vicinity of the southern end of Lake Fiskville. This area required further assessment and possibly remediation to identify the extent and contamination status of perched water in this area. Based these findings and on the conclusions and recommendations of s53V Audit, prepare a SAQP sufficient to satisfy the requirement of a s.53X audit of the site.



Note. There is no such rec in the 53V audit report, however subsequent to

the Audit the Auditor has recommended that this be undertaken a part of the

CUP.

Documents

ENVIRONMENT, NATURAL RESOURCES AND …...Version: 1.3 Date: 23/02/2016 2154309_22\C ENVIRONMENT, NATURAL RESOURCES AND REGIONAL DEVELOPMENT COMMITTEE Inquiry into the CFA’s Training