HMAS Cerberus PFAS MANAGEMENT AREA PLAN · 2018-10-11 · PFAS Management Area Plan - HMAS Cerberus ... 2. Working to protect the community from exposure while management actions

HMAS Cerberus

PFAS MANAGEMENT AREA PLAN

Revision 3 – 2 October 2018

PFAS Management Area Plan - HMAS Cerberus

1 2 October 2018

Contents

GLOSSARY ............................................................................................................................................ 4

1 INTRODUCTION ............................................................................................................................. 5

1.1 Purpose ................................................................................................................................... 5

1.2 Application ............................................................................................................................... 5

1.3 Background ............................................................................................................................. 6

1.3.1 PFAS and its use............................................................................................................. 6

1.3.2 The nature of PFAS ........................................................................................................ 6

1.4 Policy context .......................................................................................................................... 7

1.4.1 PFAS National Environmental Management Plan .......................................................... 7

1.4.2 Defence estate and environmental management ........................................................... 7

1.4.3 PFAS Response Management Strategy ......................................................................... 8

1.5 Scope ...................................................................................................................................... 9

1.6 Guiding principles .................................................................................................................. 10

1.7 Implementation process ........................................................................................................ 10

1.7.1 Approvals ...................................................................................................................... 11

1.7.2 Procurement phase ....................................................................................................... 11

1.7.3 Implementation timelines .............................................................................................. 11

1.7.4 A living document .......................................................................................................... 12

1.8 Roles and responsibilities ..................................................................................................... 12

1.9 Constraints and assumptions ................................................................................................ 13

2 PROFILE OF THE MANAGEMENT AREA ................................................................................... 16

2.1 Management Area description .............................................................................................. 16

2.2 Management Area setting ..................................................................................................... 19

Regional meteorology ................................................................................................................... 19

Topography and bathymetry ......................................................................................................... 19

Geology ......................................................................................................................................... 22

Hydrogeology ................................................................................................................................ 22

Soil landscape ............................................................................................................................... 24

Vegetation ..................................................................................................................................... 25

Management Area drainage .......................................................................................................... 25

Current and projected land uses surrounding the Management Area .......................................... 26

2.3 Management Area scale ....................................................................................................... 26

2.4 Extent of contamination ......................................................................................................... 27

Soil ................................................................................................................................................ 27

Surface water and groundwater .................................................................................................... 27

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2.5 Groundwater use ................................................................................................................... 28

On-site ........................................................................................................................................... 28

Off-site ........................................................................................................................................... 28

2.6 Relevant legislation and government policy .......................................................................... 29

2.7 Stakeholders ......................................................................................................................... 30

3 PMAP METHODOLOGY AND APPROACH ................................................................................. 32

3.1 Overview of approach ........................................................................................................... 32

3.2 Identify risks and consequences (Chapter 4) ........................................................................ 32

3.3 Prepare Ongoing Monitoring Plan (Chapter 5) ..................................................................... 32

3.4 Develop risk management options (Section 6.1) .................................................................. 32

3.5 Detailed options analysis (Section 6.2) ................................................................................. 33

3.6 Integrated options analysis (Section 6.3) .............................................................................. 33

3.7 Recommendations Analysis .................................................................................................. 33

4 IDENTIFIED RISKS AND CONSEQUENCES .............................................................................. 35

4.1 Source / pathway / receptor analysis .................................................................................... 35

4.2 Risk listing and consequences .............................................................................................. 48

5 ONGOING MONITORING PLAN .................................................................................................. 52

5.1 Overview ............................................................................................................................... 52

5.1.1 Objective and purpose .................................................................................................. 52

5.1.2 Impacted decisions ....................................................................................................... 52

5.1.3 Related documentation ................................................................................................. 52

5.2 OMP communications ........................................................................................................... 52

5.3 OMP summary ...................................................................................................................... 53

5.4 OMP review ........................................................................................................................... 53

6 OPTIONS IDENTIFICATION AND ANALYSIS ............................................................................. 54

6.1 Options identification and analysis ........................................................................................ 54

Context .......................................................................................................................................... 54

Approach ....................................................................................................................................... 55

Options identification ..................................................................................................................... 55

Construction methods and technology assessment ..................................................................... 57

6.2 Preliminary comparative analysis .......................................................................................... 59

Primary source control .................................................................................................................. 59

Secondary source and/or pathway control .................................................................................... 59

Administrative controls .................................................................................................................. 60

6.3 Integrated options analysis outcomes ................................................................................... 60

7 RECOMMENDED PMAP RESPONSE ACTIONS ........................................................................ 61

7.1 List of recommended PMAP response actions ..................................................................... 61

7.2 Comparative PMAP implementation timeframes .................................................................. 61

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8 REVIEW AND UPDATE ................................................................................................................ 63

APPENDIX A: Regulatory and policy analysis .................................................................................. 64

APPENDIX B: Interim response management analysis ................................................................... 68

APPENDIX C Source – pathway – receptor analysis ...................................................................... 69

Conceptual Site Model Visualisation ................................................................................................. 69

APPENDIX D Options analysis criteria ............................................................................................ 81

APPENDIX E Options listing and analysis ....................................................................................... 84

Options Assessment ..................................................................................................................... 84

1.1.1 OPT-001a Immobilisation of PFAS in soils ................................................................... 84

1.1.2 OPT-001b Capping of PFAS-impacted media .............................................................. 88

1.1.3 OPT-001c Excavation of PFAS-impacted soils, storage of material and replacement with clean fill .................................................................................................................................. 92

1.1.4 OPT-001d Engineering control - Excavation of PFAS in soils at primary source areas and either on or off-site treatment (destruction) ............................................................................ 95

1.1.5 OPT-003 Installation of a treatment system within PFAS-impacted creeks ............... 101

1.1.6 OPT-004a Administrative Control - No groundwater wells to be installed within the management area ....................................................................................................................... 104

1.1.7 OPT-004b Administrative Control - Advise Base to not use PFAS-impacted water to irrigate land.................................................................................................................................. 107

1.1.9 OPT-004c Administrative Control - Maintain no trespassing signs ............................. 110

1.1.10 OPT-004d Administrative Control – Require all on-site works to have PFAS specific EHSW protocols and procedures ................................................................................................ 112

1.1.11 OPT-004e Administrative Control – Base to maintain adequate records of PFAS impacted areas ............................................................................................................................ 114

Comparative Assessment ........................................................................................................... 116

APPENDIX F Ongoing monitoring plan ......................................................................................... 120

APPENDIX G References .............................................................................................................. 122

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GLOSSARY

Base A defined physical locality or geographical area from which Defence-related activities, operations, training or force preparations are managed, conducted, commanded or controlled.

DSI Detailed site investigation as identified in section 1.1.1

ERA Ecological Risk Assessment

Extended implementation period

Period when PMAP response actions are required beyond the primary implementation period. These actions include ongoing:

monitoring, leachate management, and maintenance of stockpiles

monitoring of Management Area for PFAS assessment of developments and technologies for application

to stockpiled PFAS impacted soils and materials

HHERA Human Health and Ecological Risk Assessment

HHRA Human Health Risk Assessment

Management Area The geographical area subject to Defence response actions as described in section 2.1

Off-site Off-Base

On-site On-Base

PFAS NEMP PFAS National Environmental Management Framework [January 2018] developed cooperatively between Australian jurisdictions

Primary implementation period

The period for completion of PMAP response actions characterised as primary implementation response actions.

Project site A defined site for construction and maintenance works within a Base

PWC Public works committee

Remediation Action Plan (RAP)

Defines the purpose and objectives of the remediation, evaluates and determines the remediation options, and sets out performance measures.

Response actions Actions identified as recommended or potential options to address potential risks

Response Management Strategy (RMS)

The Defence PFAS Response Management Strategy

Risk assessment(s) The HHERA, HHRA and/or ERA described in section 1.1.1

Source area An area within the Management Area that is, or has the potential to be, a source of contamination

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1 INTRODUCTION

1.1 Purpose

This PFAS Management Area Plan (PMAP) provides a roadmap for response management by Defence of potential risks arising from Per- and poly-fluoroalkyl substances (PFAS) contamination associated with HMAS Cerberus and surrounding areas (refer Figure ), consistent with the PFAS National Environmental Management Plan (NEMP).

Figure 1 HMAS Cerberus – site location

Defence’s management of the risks under the PMAP aims to avoid or minimise exposure to PFAS contamination from Defence property to human health and ecological receptors. In doing so, Defence prioritises the following combination of measures:

1. Implementing practicable solutions to prevent or minimise the migration of PFAS beyond the Defence property boundary through:

reducing the mass of the PFAS contamination source, and/or

blocking or diverting the migration pathway of the contamination from the source to a receptor

2. Working to protect the community from exposure while management actions addressing source areas and/or migration pathways are underway.

1.2 Application

This document will be used by Defence (including contractors) managing or carrying out the response actions set out in this PMAP.

This document may also be relevant for reference or aligning actions:

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By Defence environmental staff responsible for approving Environmental Clearance Certificates (ECCs) and any other similar approvals required for implementation of this PMAP.

By Defence (including contractors) carrying out construction and maintenance works on the Defence estate

During the development and delivery phases of response actions, including by Site Selection Boards.

1.3 Background

1.3.1 PFAS and its use

PFAS are a group of synthetic (i.e., ‘man-made’) compounds which include perfluorooctane sulfonate (PFOS), perfluorohexane sulfonate (PFHxS), and perfluorooctanoic acid (PFOA). PFAS have been widely used around the world since the 1950s to make products that resist heat, stains, grease and water. These include hydraulic fluid, stain resistant applications for furniture and carpets, packaged food containers, waterproof clothing, personal care products and cleaning products.

Due to its effectiveness in extinguishing liquid fuel fires, PFAS was also an ingredient in legacy aqueous film forming foam (AFFF) used extensively worldwide by both civilian and military authorities from about the 1970’s. Older formulations of AFFF contained a number of PFAS now known to be persistent in the environment and in humans.

Most people living in developed nations will have some level of PFAS in their body due to their widespread use. In June 2016, the Environmental Health Standing Committee (enHealth)1, published guidance statements advising that there is currently no consistent evidence that exposure to PFOS and PFOA causes adverse human health effects.2 However, since these chemicals remain in humans and the environment for many years, it is recommended that as a precaution, human exposure to PFAS be minimised.

PFAS contamination on and in the vicinity of the Defence estate arises primarily because of the historic use of AFFF for training purposes or incident control.

1.3.2 The nature of PFAS

PFAS has many qualities that combine to present particular challenges in locating, containing and remediating PFAS contamination:

Water is the prime method of PFAS contamination transferring from a source to a receptor - a person, animal, plant, eco-system, property or a waterbody.

PFAS is highly soluble and mobile and can rapidly leach through soils or disperse in waterways, travelling long distances. This may sometimes reduce the level of contamination of the original source material.

1 EnHealth is a subcommittee of the Australian Health Protection Principal Committee, and is responsible for providing agreed environmental health policy advice. Its membership includes representatives from the Health portfolios of Australian and New Zealand governments. 2 http://www.health.gov.au/internet/main/publishing.nsf/content/health-pubhlth-publicat-environ.htm

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PFAS can permeate some solid surfaces. This includes concrete and other building materials, particularly used in storage tanks, fire training grounds and other large surface areas.

PFAS is very chemically and biologically stable and has a low vapour pressure, so it is resistant to breakdown and evaporation.

Some PFAS (including PFOS and PFOA) are environmentally persistent and bioaccumulate. This means that some plants may be susceptible to PFAS, uptaking it through soil and water. It then bio-accumulates and becomes a part of the food chain. The same process applies to some animals and fish.

1.4 Policy context

The policy context for the PMAP consists of national guidance in the form of the [draft] PFAS National Environmental Management Plan, Defence estate and environmental strategies, and Defence PFAS-specific strategies and guidance.

1.4.1 PFAS National Environmental Management Plan

The NEMP aims to provide governments with a consistent, practical, risk-based framework for the environmental regulation of PFAS-contaminated materials and sites. The [draft] NEMP has been developed collaboratively by the Heads of EPAs Australia and New Zealand and the Commonwealth Department of Environment and Energy (DoEE) [and has been endorsed by the Commonwealth Government].

The PFAS Response Management Strategy and the requirements of the PMAP template and guidance conform to the NEMP.

1.4.2 Defence estate and environmental management

The Defence Estate Strategy 2016-2036 and the Defence Environmental Strategy 2016-2036 each provide strategic direction for the management of risks associated with PFAS contamination.

Under the Defence Estate Strategy 2016-2036, sustainability is one of five strategic aims for the management of the Defence estate.3 Under this strategy, the environment and its ongoing sustainable management is viewed as a critical enabler to Defence capability. For legacy contamination, including emerging contaminants such as PFAS, Defence is committed to minimising the impacts of the use of the estate on surrounding communities, proactively investigating and responding to contamination, and working with affected communities and State/Territory authorities.

The Defence Environmental Strategy 2016-2036 provides further strategic focus. Relevant strategic aims are:

Strategic Aim 1: Defence will deliver a sustainable estate. Strategic Aim 2: Defence will understand and manage its environmental impacts. Strategic Aim 3: Defence will minimise future pollution risks and manage existing contamination

risks

3 Defence Estate Strategy 2016-2036, Strategic Aim 4: http://www.defence.gov.au/EstateManagement/Governance/EstateStrategy.asp

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1.4.3 PFAS Response Management Strategy

The PFAS Response Management Strategy (RMS) is a high-level strategy document that sets out the approach and principles to be applied to PFAS response management. Under the RMS sit three integrated components:

PFAS Management Area Plan (PMAP) template and guidance

The template on which this PMAP is based, with embedded guidance for the comprehensive PFAS response plan for a Defence Base and its vicinity, based on the outcomes of the Detailed Site Investigations and the risk assessments.

PFAS Interim Response Management (IRM Guidelines)

Guidance to manage a specific risk rather than the set of risks associated with a property. These risks will generally emerge during the investigation phase. Where it is important that the risk be managed before the PMAP is in place to avoid or mitigate a significant risk to human health or the environment, the IRM guidelines provide a process for developing, assessing and recommending options, scalable from community-level actions through to PWC referral actions.

PFAS Construction and Maintenance Framework

Guidance on the management of PFAS risks when carrying out constructions and maintenance projects on the Defence estate for a site that is, or is likely to be, contaminated by PFAS.

Figure 2 below sets out a strategy and implementation map for Defence PFAS Response Management.

Figure 2 Defence PFAS response management and implementation map

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Figure at the end of this section presents the site-management process and the roles of the PMAP and related project documentation.

1.5 Scope

To inform risk identification and weighting for the Management Area, the PMAP relies on:

the detailed site investigation of August 2017 – May 2018, conducted by Aurecon, which included a review of reports documenting previous investigations by others.

Aurecon site visits and interviews.

.

The key parameters for the PMAP are set out below.

Management Area The Management Area comprises the investigation area (IA) used for the DSI conducted by Aurecon between August 2017 and May 2018 at HMAS Cerberus. The IA comprises the northern portion of the Base and Hanns Inlet (Refer Section 2.1 for details).

Issue/risk identification Findings from Tier 1 risk assessment undertaken as part of the DSI identified the following potentially elevated risks:

Environment

Exposure of terrestrial ecological receptors within on-Site tidal creeks, wetlands south of the Fire Ground, open drains, Fire Ground lagoon, and the Ornamental Lake.

Exposure of aquatic ecological receptors within on-Site tidal creeks and open drains, and the Ornamental Lake; and to higher order predators consuming these biota.

Exposure of terrestrial and aquatic ecological receptors within Hanns Inlet; and to higher order predators consuming these biota.

Human Health

No unacceptable risk to human health either on or off-Site was identified.

Issue/risk range A PMAP addresses the range of elevated risks identified in a DSI and the risk assessment, but excludes WHS PFAS exposure risks within the Management Area. They are appropriately managed by the relevant contractor in accordance with applicable work, health and safety legislation.

Management timeframe Short, medium and long-term response actions (refer section 7.2): comprehensive response document extending beyond primary implementation period to an extended implementation period, where appropriate

Remediation technology status

The response options in this PMAP consider only proven technologies at the appropriate scale, unless otherwise agreed by Defence.

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1.6 Guiding principles

When developing and recommending appropriate response actions, the principles considered (in accordance with the Defence PFAS Response Management Strategy and the NEMP) include:

whether an option is proportional to risks

the sustainability and longevity of an option (environmental, economic and social) in achieving an appropriate balance between benefits and effects

views of the affected community and the jurisdictional regulator

availability of best-practice management systems, treatments and technologies

site specific issues (including transference, cross-contamination, and remobilisation)

effectiveness and validation status of technology

success measures for the treatment or remediation outcomes

the need for ongoing operations, management, maintenance or monitoring

the net environmental benefit, after taking into account the environmental costs of the solution

Defence prioritises source management as preferable to pathway management and pathway management as preferable to receptor management but these components may be progressed concurrently.

1.7 Implementation process

Defence will undertake project management of the overall PMAP, including monitoring of implementation and progressive evaluation (six-monthly intervals in the first year, then annually) of the implementation.

This will inform any changes to, and re-alignment of, the PMAP.

Some interim response actions will be in progress or in the mid-point of approval processes at the commencement of this PMAP, having been transitioned from IRM actions (see section 2.7).

Actions under the PMAP will be subject to Defence approval and procurement processes, including where relevant, the processes of the Parliamentary Standing Committee on Public Works Committee (PWC) processes.

Source / Pathway / Receptor: categories of risk management for contamination

A risk occurs when a source of contamination (such as soil contaminated with PFAS) is linked to a sensitive receptor (such as a person) via an exposure pathway (such as stormwater flow to a local water supply).

Response to a risk may involve one or more of the following three principal components:

a) source management by removal, destruction, treatment, disposal and/or other methods leading to the source no longer being present.

b) pathway management by capping, containing, stabilisation, diversion, and/or other methods where the source remains in place but pathways are managed.

c) receptor management by relocation, institutional controls, behaviour management, point-of-use treatment and/or other methods focussed on the receptor.

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1.7.1 Approvals

a) Higher value public works

Larger public works (exceeding $15 million in expenditure) require a referral to the PWC. Under very limited circumstances, exemptions from the PWC process are available:4

urgency for defence purposes where that scrutiny could be contrary to the public interest, or for projects of a repetitive nature.

Medium works (exceeding $2 million but less than $15 million in expenditure) require a notification to the PWC. PWC assessment of a notification may result in:

approval to proceed approval to proceed, subject to specific conditions or requirements Committee deliberation postponed, pending further information, or Committee resolution to seek a referral.

For higher value public works, a timeframe of up to 12-24 months may apply commencement of the development phase of the project to approval to commence the delivery phase. The processes may include all necessary Government and Parliamentary approvals, including PWC. This may require interim measures to be implemented to manage the risks until the response action has received approval to commence.

b) Site Selection Board

Where relevant, the Defence Site Selection Board (SSB) is required to determine the location of response actions and any supporting infrastructure (for example, containment areas or water treatment plants).

The question as to whether a regional or full review is required will be determined in accordance with Defence Estate Quality Management System (DEQMS) guidance5

1.7.2 Procurement phase

Once the PMAP is approved by Defence (and subject to the approvals in 1.7.1), Defence will undertake procurement actions (in order of priority) for relevant specific response actions in accordance with the Commonwealth Procurement Rules and standard Defence procurement processes. These specific response actions will be implemented and evaluated in accordance with the terms (including timeframes) of the relevant procurement agreement.

1.7.3 Implementation timelines

The outcomes of the procurement processes will inform the detailed project implementation timelines.

The PMAP is divided into two implementation periods:

1. The primary implementation period applies to actions that can generally be addressed in the short to medium term (up to three years. Ref section 7.2).

4 Public Works Committee Act 1969, sections 18(8) and 18(8A) 5 http://www.defence.gov.au/EstateManagement/lifecycle/SiteSelection/Task4.asp

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2. The extended implementation period commences once the primary implementation period has completed. It applies to response actions required beyond the primary implementation period on an ongoing or long-term basis. These actions include ongoing:

monitoring, leachate management, and maintenance of stockpiles monitoring of the Management Area for PFAS ongoing operation of remediation technologies (e.g., a water treatment plant), as

required assessment of developments and technologies for application to stockpiled PFAS

impacted soils and materials.

Response actions under this PMAP are designated as forming part of:

a) the primary implementation period; b) the extended implementation period; or c) both the primary and extended implementation periods (e.g., monitoring of the Management

Area for PFAS).

1.7.4 A living document

The science of understanding PFAS impacts and ways of managing PFAS contamination are constantly evolving. There is still a lot that is not established about the impacts of PFAS contamination on human health and the environment. Similarly, remediation technologies, and of the required scale, are at various stages of research and development.

This PMAP has been prepared based on information available at the time of writing and relies on the findings of the DSI and the Risk Assessments. Defence recognises that there may still be gaps in information that will be progressively addressed while impacted sites are being managed.

This document will be reviewed and updated every six months for the first year, then annually (or earlier if required). As implementation of the PMAP progresses, detailed plans supplementary to this PMAP will be prepared (as required) to address the individual management actions that have been identified in this PMAP.

1.8 Roles and responsibilities

Roles PFAS Management Responsibilities

Capital Facilities Infrastructure (CFI)

Deliver Defence construction projects. PFAS management of construction projects under the Construction and Maintenance Framework is to be aligned with the PMAP.

Defence Environmental and Sustainability Officers including ADES, RESO, REO

Oversight of environmental and heritage issues for a specified base/s.

Review relevant Construction Environmental Management Plans.

Approve Environmental Clearance Certificates & Remediation Action Plans.

Environment and Engineering Branch

Defence SME and policy owner for environment, engineering, heritage, contamination management, pollution prevention, energy, water and waste management within Defence.

Approve construction and maintenance project specific documentation.

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Roles PFAS Management Responsibilities

Environmental Consultant Contracted by Defence or on behalf of Defence to undertake environmental testing, provide technical advice (including site auditing) or develop proposals/plans/certificates.

Lead Consultant Contracted to Defence to prepare the PMAP

PFAS Investigations Management Branch (PFASIM)

Project manages detailed PFAS environmental investigation and response programs at a specified base.

Provision of Defence and whole of government PFAS related policies.

Coordinate resolution of enquires within PFASIM Branch. Develop & promote PFAS guidance and management resources within Defence, including CFI & SDD stakeholders.

Project Manager/Contract Administrator (PMCA)

Contracted to Defence to provide project/contract management oversight of specific response actions.

Holds pertinent project and contract documentation.

Public Works Committee (PWC) Required to approve higher value public works (exceeding $15 million) and assess public works with a value of between $2 million and $15 million).

Site Selection Board Approve the siting of semi-permanent and permanent structures, including the location of response actions and any supporting infrastructure.

Service Delivery Division and its contactors (SDD)

Maintenance projects delivered by base service EMOS contractors.

PFAS management of maintenance projects under the Construction and Maintenance Framework is to be aligned with the PMAP.

Deliver some medium works projects

State/Territory environmental regulator

Approve licences for transportation of waste and storage/disposal of waste at licenced waste disposal facilities.

Sets limits or guidance values for soil and liquid waste disposal or discharge.

Consultation or inform on remediation activities within state/territory jurisdictions.

1.9 Constraints and assumptions

This document has been developed on the basis of the following assumptions:

Assumptions for preparation of this document comprise information collected as part of the investigation works to date (sourced from the DSI)

Conceptual site model (refer Section 11.8, DSI report) detailing the source-pathway-receptor linkages (Aurecon 2018)

site geology and hydrogeology (Aurecon, 2018)

water use survey of local area, collected for the DSI (Aurecon, 2018)

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site history and historical use of PFAS (Aurecon, 2018)

Tier 1 assessment of human health and ecological risks (Aurecon, 2018)

Constraints on preparing this document comprise:

Availability of proven technologies for the successful treatment and destruction of PFAS

Current limited Australian vendor capacity to implement proven technologies for treatment and destruction of PFAS

Current regulatory restriction (prohibition) on the off-site disposal of PFAS solids to landfill

Technologies that are not considered economically viable or feasible for use at HMAS Cerberus have been excluded (as recommended in NEMP 2018)

PFAS MANAGEMENT AREA PLAN – HMAS Cerberus

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Figure 3 Defence PFAS management process and indicative timeline

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2 PROFILE OF THE MANAGEMENT AREA

2.1 Management Area description

HMAS Cerberus is located between Somers and Bittern / Crib Point, on Western Port Bay, approximately 70 km south of Melbourne, Victoria (refer to Figure 1). The Site surrounds Hanns Inlet, which is located off the north arm of Westernport Bay, the latter being an internationally significant wetland listed under the Ramsar Convention on Wetlands (refer Figure 4). Site identifying details are summarised in Table 1.

Figure 4 Site Vicinity

Table 1 Summary of Site identifying details

Item Relevant Site Information Site address HMAS Cerberus, VIC, 3920

Site area 1,517 ha (15.17 km2)

Current Site owner Department of Defence

Municipality Mornington Peninsula Shire

Council Property Number 80160

Current Land Use Zoning Commonwealth Land (CA)

Current Site Occupier Department of Defence (RAN)

Lot and Plan Number 45 parcels of land (refer to DSI for full citation of land titles)

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The investigation area (IA) for the intrusive component of the DSI works is identified in Section 2 of the DSI report and includes Hanns Inlet (refer to the blue polygon shown on Figure 4. Note that the southern portion of the Site was excluded from the DSI works owing to the presence of unexploded ordnance (UXO), however it is not considered that this would affect the completeness of the DSI as there are no known or suspected AFFF sources or pathways within this portion of the Site. Specifically, bush fires that had occurred along the southern shore of Hanns Inlet were not fought because of UXO was present in this area, which was confirmed based on detonations heard as the bushfire advanced through the area between the rifle range and the shoreline. Site details referred to in this document are presented on Figure 5.

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Figure 5 Site details

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The assignment of the IA within the boundary of the Site has been informed by the results and findings of preliminary investigations conducted by Aurecon including the review of background information and the results and findings of prior environmental and / or Site contamination investigations undertaken on-site by others. The body of knowledge to date identifies that:

Topographically, the Site is located within a broad valley that slopes to the south-east towards Hanns Inlet and the North Arm of Westernport Bay

Surface water comes onto Site via several drains along the northern and western Site boundaries which are topographically up-gradient of the Site

Groundwater flow direction underlying the Site is in a general south to south easterly direction and groundwater is anticipated to discharge to Hanns Inlet and the North Arm of Westernport Bay

Known and suspected source areas of existing AFFF impact and operational areas where AFFF is known to have been used, stored and generated wastes are all located topographically and hydraulically downgradient of the northern and western Site boundaries (noting these are the boundaries to the adjacent residential and commercial properties)

Existing groundwater monitoring data indicates significantly decreasing concentration of AFFF sourced PFAS in groundwater along transects extending in up- or cross-hydraulic gradient locations

2.2 Management Area setting

Regional meteorology

Climate data for the site available from the Site weather station (Bureau of Meteorology station number 086361) between 1986 and 2017 indicates the following:

Annual rainfall is approximately 723 mm, which occurs over approximately 178 days of rain.

Highest average monthly rainfall is approximately 75 mm, which occurs in August

Lowest average monthly rainfall is approximately 38 mm, which occurs in January and February

Average maximum temperatures range between 14ºC in the winter and 25ºC in the summer. Average minimum temperatures range between 6ºC and 14ºC. Average annual wind speed is approximately 15 km/hr in the morning and 20 km/hr in the afternoon.

Migration of PFAS in surface water is more likely to occur in the wetter months as stormwater captures PFAS from across the site and there is an increased risk of overflow of the former sewage treatment plant. Any effluent overflowing from the former (now decommissioned) STP would have previously discharged into the creek flowing between the STP lagoons, which in turn discharges into Hanns Inlet.

Topography and bathymetry

Topographically, the Site is located within a broad valley that slopes to the southeast towards Hanns Inlet and the North Arm of Westernport Bay. The highest portion of the broad valley ranges in elevation between 50 mAHD and 90 mAHD (refer to Figure 7). The main operational area of the Site is between sea level and approximately 10 mAHD on a low ridge flanked by two drainages that flow to

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the southeast towards Hanns Inlet. On-site, higher ridges with remnant vegetation (up to approximately 20 mAHD) are located north and south of the two main drainages.

Hanns Inlet, which is a tidally influenced estuary, connects to the North Arm of Western Port Bay. Water depths in Hanns Inlet varies with tide level. The tidal flats are often exposed during low tides; while at high tides water depths can be up to 2 m. Within the access channel to the Site marina water depths range between 2 m and 4 m over tide cycles.

With a tidal range of approximately 2 m, most of Hanns Inlet consists of a broad tidal flat with a main tidal channel extending out from the two main natural drainages (South Creek and East Creek) located south and east of the main operational area of the Site. Typically, the tidal flat is inundated twice a day with high tides rising to approximately 1 mAHD and low tides falling to around -1 mAHD. To provide ship access to the Site, a man-made channel between 2 m and 3 m deep is maintained. This access channel was last dredged (to remove weed and marine vegetation) in 2006 with the spoil placed in a sullage pit located on the north shore of Hanns Inlet (refer Figure 4).

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Figure 7 Surface water catchment (purple line) and topographical (black contours) map of HMAS Cerberus where Site boundary is indicated by yellow line.

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Geology

Interrogation of the GeoVic6 and Visualising Victoria Groundwater (VVG)7 websites indicated that geology at and near the Site comprised the following strata (refer Table 2).

Table 2 Regional Geology

Strata Characteristics Thickness (m)

Recent dune, river, swamp and alluvial deposits

Dune sands (Sandy Point), predominantly silts and clays with some interbedded sands

0 - 15

Tertiary Brighton Group (river and near-shore marine deposits) (lateral equivalent to Baxter Sands)

Sandy clays to clayey sands with localised iron staining and cement

1 - 20

Tertiary Yallock Formation and Sherwood Marl (marine) (lateral equivalent to the Fyansford Formation)

Sand and clays with some limestone layers 50 - 60

Tertiary Childers Formation (coastal/near-shore marine) (lateral equivalent to the Werribee Formation)

Lignite and clay with some sand 10 - 15

Interbedded with the Werribee Tertiary Older Volcanics (terrestrial deposits)

Variably weathered and fractured basalt lava flows

10 - 20

Silurian Bedrock (marine deposits) Siltstones and sandstones >100

Hydrogeology

Shallow aquifers below the Site fall within a groundwater basin coincident with the local surface-water catchment shown on Figure 9. Shallow groundwater (less than 20 m in depth) occurs in the Recent alluvial sediments (Quaternary Aquifer under the Victorian Aquifer Framework, SKM, 2009) and the Tertiary sands and clays (Upper Tertiary Aquifer (fluvial), and Upper Mid-Tertiary Aquifer). A water-table aquifer is developed in the Recent alluvial soils (mainly silts and clays) deposited in the drainages south and east of the operational portion of the Site (south of the Fire Ground and east of the Fire Station) and in fill soils in the marina area. A semi-confined aquifer is developed in the Tertiary sediments.

6 http://earthresources.vic.gov.au/earth-resources/maps-reports-and-data/geovic 7 http://www.vvg.org.au/

23 2 October 2018

Figure 9 Regional groundwater flows

These shallow aquifers are predominantly recharged directly by rainfall within the local catchment; and to a lesser degree by irrigation of sports fields or agricultural land. Groundwater discharges via either evapotranspiration, surface-water features, such as the local drainages and Hanns Inlet, or extraction wells.

Within the operational area of the Site, standing water levels (SWLs) measured between 2016 and 2017 (Agon, 2016 and Golder, 2017) were typically between 2 and 11 m deep. Reduced water levels (RWLs) at the Fire Ground are approximately 3 mAHD, while RWLs for wells located between the Fire Ground and the drainage channel south of the Fire Ground are less than 1 mAHD, which suggests that shallow groundwater beneath the Fire Ground flows to the southwest. Across the central and eastern part of the operational area the RWLs suggest that groundwater flows to the south or east and discharges directly into Hanns Inlet. Note that the inferred directions of are from private extraction bores onto the operational area of Site. This means that the private extraction bores are inferred to be located hydraulically up- or cross-gradient (east, north and west) of the Site.

Interrogation of the VVG portal indicates that there are 66 wells located within 1 km of the Site boundary. A breakdown of these wells by usage is presented in Table 3.

24 2 October 2018

Table 3 Summary of surrounding groundwater uses

Use Number of Wells

Domestic and Stock 48

Industrial 1

Irrigation 2

Groundwater Investigation 7

Not indicated 8

Total 66

The majority of the wells are categorised as being for the purpose of domestic and stock usage. The well listed under industrial use is located on Site to the northeast of the permanent residences. Base staff indicated that this well has not been used for decades. Of the two wells used for irrigation, one well is located east of the Site near the Crib Point pool; while the other well is located to the northwest of the Site. These irrigation wells are approximately 20 m deep; hence, likely to be completed in the Brighton Group aquifer (Tertiary sands and clays).

Approximate hydraulic conductivity of the geology on site was assessed during the DSI (Aurecon,2018), which concluded that the shallow Brighton Group aquifer typically had a hydraulic connectivity of less than 0.1 m/day. Interpretations of short-term aquifer tests for wells in some areas, such as at the former STP with value ranging between 0.9 and 5 m/d, suggest higher conductivities that reflects thin, coarser-grained aquifer material in some wells.

Groundwater quality parameters measured during the DSI investigation are summarised in Table 4 below. Detailed groundwater quality information is provided in the DSI (Aurecon 2018).

Table 4 Groundwater quality parameters

Area pH Temperature (°C)

Electrical conductivity (μS/cm)

Dissolved oxygen (mg/L)

Total dissolved solids (mg/L)

Redox (mV)

On site 4.78 - 8.42 15 - 22 200 – 42,200* 0.4 - 8 120 – 25,300* -154.6 - 2,205

* Based on a 0.6 conversion factor between EC and total dissolved solids

Based on measurements of EC (as a proxy for salinity), the groundwater EC measured in MW216 (near the marina shoreline) indicated brackish groundwater (rather than sea water), which suggests that while there are hydraulic effects from tidal fluctuations in Hanns Inlet, salty seawater is not intruding inland to the location of MW216 (approximately 50 m landward). In contrast, EC values measured in wells along the east shoreline of the operational area completed in fill material (refer DSI report Appendix A -Figure 6) indicate seawater is intruding into the fill material. This indicates that saline groundwater (in the Fill aquifer) overlies fresher groundwater (within the Brighton Group aquifer).

Soil landscape

Regionally, the State soils database indicates that the Site comprises the Bittern soil complex comprising brown and yellow Chromosols with some Sodosols. Surface soils comprise dark brown, slightly acidic loamy sands to fine sandy clay loams. Subsoils comprise moderately acidic, yellow-brown heavy clay.

25 2 October 2018

The regional soil characteristics were evident in the surface soils sampled during the DSI (Aurecon, 2018), which typically comprised silty sands to clayey sands, coloured grey to brown with moist to wet moisture conditions. Acid sulphate soils are likely to be present in the wetlands soils (hydrosols) deposited along the tidally influenced portions of the Site creeks. In the tidal flats swamp deposits occur, which are wet for most of the year and are dark grey clays or silty clays, which become bluish grey with depth. These soils can be described as Extratidal Hydrosols.

Fill soils comprising Brighton Group sediments excavated from the northern portion of the Site were used to reclaim tideland along the marina area. Logs for boreholes in this area indicate approximately 4 m of clayey fill material was placed in this area.

Vegetation

SKM (2006) conducted a baseline vegetation survey within HMAS Cerberus in February and March 2006 to provide baseline data relating to the presence of threatened ecological species and communities. The site comprises the following vegetation:

Remnant vegetation (12%)

Regenerating native vegetation (9%)

Maintained cleared grassland and Defence infrastructure (78%)

No Commonwealth or State listed threatened ecological species were recorded on site, although several species are considered to potentially occur (SKM 2006). Some areas of vegetation were considered to be Endangered Ecological Communities listed under the Threatened Species Conservation Act 1995 (NSW) (TSC Act) (SKM 2006), including the Illawarra Lowlands Grassy Woodland and Lowland Rainforest.

Management Area drainage

The storm-water network for the operational areas of the Site consists of a combination of open drains and an engineered concrete pit-and-pipe network.

Surface water is conveyed onto and out of Site by a storm-water drainage system constructed during early development of the Site. The general topography of the Site indicates that the surface water at the boundary of the Site flows in a general south-east direction away from off-Site residents.

The pipe sizes in the network do not meet current Australian standards for capacity, size and configuration, such that there are areas where a one-in-ten-year storm event cannot be discharged by the network, thus resulting in localised flooding. It is understood that the proposed redevelopment includes plans to replace collapsed areas of the storm-water trunk infrastructure and install four bio-retention basins on key storm-water mains prior to the outfalls into the wetlands of Hanns Inlet.

The current potable water service to the Site consists of mains water supplied by South East Water (SEW). The potable water mains servicing the Site were upgraded in 2004. A significant percentage of the current pipe network has been assessed to be in poor condition. The network provides water for both domestic and fire-fighting requirements. However, the water pressure is inadequate for fire-fighting purposes. It is understood that the proposed HMAS Cerberus redevelopment includes plans to upgrade the potable water supply by providing a new potable water storage tank.

It is understood that no groundwater is extracted on site for any purpose. Potable, irrigation and sewer water supplies are all provided by water mains.

Land surrounding HMAS Cerberus is currently used for the purposes detailed in Table 5 below.

26 2 October 2018

Table 5 Surrounding land uses

Direction Details

North North: residential, industrial facilities (BlueScope Steel and Long Island Point petroleum storage and processing facilities), natural bushland, urban reserves, closed Crib Point municipal landfill on Lens St, Bittern.

East Hanns Inlet and the North Arm of Western Port Bay, fishing, fire tugboat berthing and support facilities.

South Agricultural, residential and natural bushland, Western Port Bay.

West Agricultural (grazing and dairy), residential and South-East Water (SEW) Somers RWTP.

Current and projected land uses surrounding the Management Area

Land surrounding the Management Area is generally zoned as rural landscape, large lot residential and environmentally sensitive areas. Land uses of properties within the surrounding area include:

Conservation and natural environment (RAMSAR Wetlands)

Dryland agriculture

Grazing

Irrigated agriculture

Other intensive uses (i.e., commercial businesses)

Urban / residential suburbs

2.3 Management Area scale

The scale of the Management Area is rated as small in accordance with the table below.

Characteristics Consequences

Very Large

High number of identified risks Multiple areas of contamination, both on-

Base and off-Base hydrogeological profile facilitates rapid

migration of contamination large impacted community

PMAP complex Development / implementation

timeframe: highly extended

Large Medium number of identified risks Multiple areas of contamination, both on-

Base and off-Base Medium-sized impacted community

PMAP moderately complex Development / implementation

timeframe: extended

Medium Small-medium number of identified risks Localised areas of contamination both on-

Base and off-Base

PMAP simplified Development / implementation

timeframe: medium

Small Small number of identified risks Contamination currently confined to isolated

locations on-Base Potential risk of contamination to a small

number of sensitive receptors

Basic PMAP Development / implementation

timeframe: medium

27 2 October 2018

2.4 Extent of contamination

Soil

Residual PFAS in soils were identified and generally delineated, with respect to the adopted screening criteria, within and surrounding the key areas where known AFFF use, storage and waste management has occurred. Hence, the major source areas (i.e., areas of more significant residual PFAS impact and/or mass) were identified as:

The Fire Training Ground and the nearby South Creek and associated wetlands (which both received stormwater runoff from the Fire Training Ground)

Fire Station / Ornamental Lake

Residual PFAS in soils were identified and generally delineated, with respect to the adopted screening criteria, within and surrounding the following minor source areas:

Fire Ground water filter washdown area (north of the Fire Ground)

Former Sewage Treatment Plant (STP)

Sports Fields that were irrigated with Class C recycled water

Site of a bushfire along a portion of the eastern Site boundary

Sullage Pit

Closed Rifle Range Road and outdoor swimming pool landfills

Communications School

Some of the areas with aboveground and underground fuel storage tanks

Former powerhouse

Former dry-cleaning facility

In addition, based on PFAS-impacted water discharging from most of the stormwater outlets in the MA, it is considered that PFAS is likely to be sorbed to the drain pipes and act as a minor source.

Surface water and groundwater

PFAS impacts at these locations have in turn caused PFAS impact to surface waters and groundwater within the Site. These surface waters and groundwater provide the transport pathways for ultimate discharge into Hanns Inlet.

Groundwater impacted by Site-derived PFAS is present across the operational portion of the Base. The plumes associated with Site sources are generally migrating in a southerly to easterly direction and discharges into Hanns Inlet or interacts with surface water within the tidal creeks within the low lying tidal sections of the Site, which ultimately discharge to Hanns Inlet

Surface water within the Site is primarily impacted with Site-derived PFAS however PFAS impacted surface water was reported entering the Site from unknown off-Site source(s) at two locations along the northern and western Site boundaries.

28 2 October 2018

Overall the findings of the DSI identify a relatively low but diffuse total mass of PFAS predominantly within the soil, surface water and groundwater within the Site.

2.5 Groundwater use

On-site

Groundwater is not abstracted or used on-Base.

Off-site

A water use survey was issued to properties within 1 km of the Site boundary between 28 July and 7 August 2017 to determine water use and land use activities on properties adjacent to HMAS Cerberus. The format of the water use survey was provided by Defence to ensure consistency with other Defence Sites where DSI works were being conducted.

A total of 280 surveys were completed using hard copy or online (Survey Monkey) format, between 1 August 2017 and 27 November 2017.

To summarise the results of those returned surveys:

243 identified as private residential properties

28 identified as rental properties

12 identified as hobby farms

1 identified as industrial

1 identified as horticultural

identified as food production

1 identified as aquaculture

1 identified as other

Water supply and use on those properties comprised:

239 used mains water

145 used rain water

33 used bore water (exact locations cannot be shown due to privacy laws)

used recycled water

195 had rain water tanks

6 users currently mixed bore water with rain water in tanks for mixed use (see below) and 9 users have previously mixed bore water with rain water

Water use surveys identified bore water was used directly or via tank top up for:

1 for domestic use

5 for household purposes

2 for drinking

1 for washing

2 for watering animals

3 for livestock

29 2 October 2018

1 for vines

5 for gardens

1 for vegetables

3 for swimming pools

1 for toilets

1 for firefighting

1 for wetlands

1 for contingency livestock watering

It was determined that sampling of these bores was not required as previous sampling of such off-site bores reported PFAS concentrations below drinking water guidelines (GHD 2016). This was further supported by sampling and analysis of groundwater undertaken for this investigation at locations along the Site boundary which likewise reported PFAS concentrations in groundwater below NEMP (2018) drinking water screening criteria (refer Section 9 for further discussion).

2.6 Relevant legislation and government policy

The PFAS National Environmental Management Plan (NEMP) aims to provide governments in Australia with a consistent, practical, risk-based framework for the environmental regulation of PFAS-contaminated materials and sites. It is framed as an adaptive plan, able to respond to emerging research and knowledge.

The PFAS NEMP provides the guiding framework for the management of PFAS. For further information, see: http://www.epa.vic.gov.au/PFAS_NMP.

Legislation and policy instruments relevant to the development of options for PFAS management in the Management Area is set out and discussed in Appendix A.

Other key drivers and constraints impacting upon response management include8:

Currently there is limited Commonwealth legislation on the designation of waste disposal criteria. Whilst the PFAS NEMP indicates potential criteria to be adopted at the State level for a State based receiving site, there is no approved landfill disposal site in Victoria that is licensed to receive PFAS impacted solids.

The PFAS NEMP document outlines the preferred framework for PFAS management including containment, remediation, treatment and disposal. The document acknowledges that each site is unique, and any management response must consider site-specific conditions in determining the best approach to the management of PFAS. Overall the document presents the hierarchy of options for site clean-up, which is consistent with the policy intent of the Victorian waste management requirement, being any clean-up of land will reflect the order of preference set out in the waste hierarchy (i.e., treatment and reuse on–site is preferred to treatment and reuse off- site, while long-term containment off-site is least preferred).

Key constraints in Victoria for off-site options to manage PFAS impacted solids and liquids is the lack of guidance on disposal criteria or the provision of licensed solid waste

8 As adapted from the PFAS Management Area Plan prepared for RAAF Base East Sale (Senversa,2018)

30 2 October 2018

treatment options. Currently PFAS impacted liquid wastes are considered Category A Prescribed Industrial Wastes and there are limited options for handling small volumes of liquids in Victoria.

The Industrial Waste Resource Guidelines currently do not have threshold criteria for PFAS impacted soil and such soils cannot be transported off-site, without an EPA exemption or approvals. The Victorian EPA does not have a formal position on the soil hazard categorisation of PFAS impacted soils and there are currently no facilities licensed to receive the waste. The EPA has indicated that they consider PFAS impacted soils to be a prescribed industrial waste as discussed here: http://www.epa.vic.gov.au/your-environment/land-and-groundwater/pfas-in- Victoria/managing-pfas-impacted-wastes-in-victoria .

Any option to manage PFAS impacted solids in an off-site facility is generally treated as a landfill operation and requires consideration under local government regulations and referral to the EPA to consider the Environment Protection (Scheduled Premises) Regulations. Typically, this involves Works Approval with associated community consultation. The requirements of the PFAS NEMP would be considered in such reviews.

2.7 Stakeholders

Project stakeholders as identified in the Communication and Stakeholder Engagement Plan included:

Stakeholder category Stakeholder Commonwealth Minister for Defence Hon Marise Payne Commonwealth Minister for Health Hon Greg Hunt MP Commonwealth Minister for the Environment Hon Josh Frydenberg MP State Minister for Health Hon Jill Hennessy State Minister for Water Hon Lisa Neville MP Members of Parliament State Member for Hastings Hon Neale Burgess

Federal Member for Flinders Hon Greg Hunt Mornington Peninsula Shire Mayor/ Councillors

CEO Relevant council officers

EPA Victoria Helen Szabo & Marleen Mathias Key Base Stakeholders Senior ADF Officer (SADFO)

Executive Officer A/Base Support Manager (A/BSM) Base Support Operations Manager (BSOM)

Residents Residents on and within 1km of HMAS Cerberus, including residents of Somers/ Balnarring, Crib Point/ Bittern.

Businesses Businesses generally within 1km of HMAS Cerberus site.

Interest/ environment groups Local groups with an interest in the project, including environmental and human health focused groups.

Community groups Local community groups that have an interest in the project and speak on behalf of the community.

Utilities United Energy (electricity and gas) South East Water

Emergency services Mornington Fire Brigade Mornington Police Station Ambulance Victoria Vic State Emergency Service (SES)

Media Local media outlets from the Mornington Peninsula

Two community information sessions (CWIS) have been conducted as part of the HMAS Cerberus PFAS investigation, including:

31 2 October 2018

An initial project commencement CWIS was held in April 2017

A subsequent CWIS was held on 31st August 2017 at Stony Point Community Hall;

DSI Report findings and PMAP presentation are scheduled for August 2018.

32 2 October 2018

3 PMAP METHODOLOGY AND APPROACH

3.1 Overview of approach

This PMAP conforms with the PFAS National Environmental Management Plan. EPA Victoria has been consulted in the development of the PMAP.

Stakeholder engagement associated with specific response actions recommended through the development of the PMAP will be addressed as relevant in the detailed implementation documents for those actions.

The PMAP methodology steps through the following stages set out in this section.

3.2 Identify risks and consequences (Chapter 4)

The list of risks to be managed in this PMAP are identified as ‘elevated’ in either the DSI and/or the risk assessments. A source / pathways / receptor analysis based on the CSM in the DSI was used to identify the relevant source (primary and secondary), pathways and receptors for the risk. For each risk, the range of potential consequences if the risk is realised have been identified.

3.3 Prepare Ongoing Monitoring Plan (Chapter 5)

An ongoing monitoring plan (OMP) forms a mandatory part of the PMAP and is therefore provided separately and has not been subject to the options analysis.

3.4 Develop risk management options (Section 6.1)

Management option/s were identified to address each of the risks identified in Chapter 4. The list of options has been informed by a range of information and research, both general and specific to the Management Area. Management Area-specific information including:

Risk assessments, CSM and DSI; Relevant Commonwealth and State/Territory legislation Feedback from stakeholder consultation (impacted community and jurisdictional regulator) IRM actions undertaken or continuing in the Management Area IRM or PMAP actions undertaken or considered by Defence on other properties

33 2 October 2018

3.5 Detailed options analysis (Section 6.2)

For each risk, the following analysis was undertaken

A. Cost / effectiveness / impact analysis

1 Cost range estimate 2 Effectiveness rating 3 Implementation period / timeframe 4 Potential impacts 5 Estimated net environmental benefit

B. Risk-based analysis

6 Proportion of action to risk 7 Best-practice status 8 Verification status 9 Technology assessment 10 Risks and mitigation 11 Key dependencies

C. Defence implications

12 Defence capability 13 Project fit 14 Scalability

D. Stakeholder impacts, views and consents

15 Jurisdictional regulator/s 16 Owner / occupier consents and views 17 Community

E. Comparative analysis

Comparative analysis comparing the available options to manage an identified risk.

Details of the analysis for each of these factors are set out in Appendix D.

3.6 Integrated options analysis (Section 6.3)

Cost savings and efficiencies may be found by looking for synergies that optimise outcomes, in particular

analysing the outcomes of the comparative analysis for each identified risk for synergies in the Management Area, and

assessing extended implementation actions for suitability in a Base’s existing maintenance framework (consultations with Defence)

Where these synergies have been found, they are presented as an integrated package addressing the relevant sets of risks.

3.7 Recommendations Analysis

The recommended PMAP response actions for each identified risk are based on the comparative analysis and the integrated analysis from Parts C and D of the methodology. They are supported by a comparison of PMAP response action implementation timeframes.

34 2 October 2018

A recommended sequential implementation schedule was then developed, taking into account:

the nature, immediacy, severity, and extent of the consequences identified in the Part A of the methodology

the comparative options analysis

the integrated options analysis.

35 2 October 2018

4 IDENTIFIED RISKS AND CONSEQUENCES

4.1 Source / pathway / receptor analysis

The analysis of complete source, pathway and receptor linkages in discussed section 11.8 of the DSI report and is summarised in Table 6, where such complete linkages were found and the concentration of PFAS constituents were found to exceed the adopted Tier 1 screening criteria.

A graphical representation of the CSM is provided in Appendix C.

A critical observation from the DSI is the absence of identified PFAS contamination beyond the terrestrial and operational boundary of the Base, which includes Hanns Inlet.

Key outcomes from the DSI were:

No unacceptable risk to on- or off-Site human health was identified except potentially to on-site intrusive construction/maintenance workers primarily through incidental ingestion of PFAS-impacted soil or water.

Potentially elevated risk was identified to on-site terrestrial and aquatic ecological receptors through direct contact or uptake and/or bioaccumulation within impacted media or secondary poisoning.

Risks associated with precluded Victorian beneficial uses of land, surface water, and groundwater:

o Based on exceedances of respective screening levels the following beneficial uses are precluded:

Land SEPP: Maintenance of ecosystems (MoE) On-Site

Land SEPP: Human health – Intrusive / Maintenance Workers On-Site

Groundwater SEPP: Maintenance of ecosystems (MoE) (99% species protection) On-Site

Groundwater SEPP: Agriculture, parks and gardens On-Site

Groundwater SEPP: Stock watering On-Site

Groundwater SEPP: Industrial water use On-Site

Water SEPP: Aquatic plants and animals (99% species protection) On-Site

Water SEPP: Water suitable for aquaculture and edible seafood On-Site

Water SEPP: Water-based recreation

Note that the risks associated with these precluded beneficial uses will be mitigated as part of the management options addressing intrusive construction/maintenance workers and ecological risks.

36 2 October 2018

Table 6 CSM: Assessment of known and potential human and ecological receptors

Exposure Media Exposure Pathway

Human Receptors Ecological Receptors

Off-Site On-Site Off-Site1 On-Site2

Off

-Sit

e R

esid

ents

WP

B F

ish

C

on

sum

ers

Tem

po

rary

On

-S

ite

Res

iden

ts

Per

man

ent

On

-S

ite

Res

iden

ts

Ch

ildca

re

Att

end

ees

Sit

e V

isit

ors

3

Bas

e W

ork

ers

o

r T

rain

ees3

Intr

usi

ve

Co

nst

ruct

ion

W

ork

ers

Off

-Sit

e A

qu

atic

B

iota

Off

-Sit

e T

erre

stri

al B

iota

On

-Sit

e A

qu

atic

B

iota

(in

clu

din

g

Inle

t)

Ter

rest

rial

Bio

ta

Soil (Fire Ground and wetlands straddling the South Creek)

Inhalation of dust or particulates

Incidental Ingestion

Dermal Contact

Direct Contact or Uptake

Bioaccumulation or Secondary Poisoning #

Soil (Fire Station and Ornamental Lake)



Dermal Contact


Bioaccumulation or Secondary Poisoning #

Soil (Former STP and West Creek)



Dermal Contact


Bioaccumulation or Secondary Poisoning # 1 Note that this is defined as an off-Site exposure scenario (i.e., the biota are located off-Site when in contact with media). Fauna, such as birds and mammals, that can move on and off Site are covered in the on-Site Terrestrial Biota scenario as the exposure scenario occurs on-Site. 2 Hanns Inlet is part of the investigation area and considered to be on-Site for this exposure pathway assessment. 3 Includes users of Sports Fields. # There is the potential for movement on-site and off-site for mobile wildlife (birds, mammals, reptiles), this risk is considered low and acceptable Assessment of known and potential human and ecological receptors, continued



37 2 October 2018


Off

-Sit

e R

esid

ents

WP

B F

ish

C

on

sum

ers

Tem

po

rary

On

-S

ite

Res

iden

ts

Per

man

ent

On

-S

ite

Res

iden

ts

Ch

ildca

re

Att

end

ees

Sit

e V

isit

ors

3

Bas

e W

ork

ers

o

r T

rain

ees3

Intr

usi

ve

Co

nst

ruct

ion

W

ork

ers

Off

-Sit

e A

qu

atic

B

iota

Off

-Sit

e T

erre

stri

al B

iota

On

-Sit

e A

qu

atic

B

iota

(in

clu

din

g

Inle

t)

On

-Sit

e T

erre

stri

al B

iota

Soil (Sports Fields)



Dermal Contact


Bioaccumulation or Secondary Poisoning

Soil (Site land boundaries)



Dermal Contact



Soil (potential minor sources in operational area)



Dermal Contact


Bioaccumulation or Secondary Poisoning 1 Note that this is defined as an off-Site exposure scenario (i.e., the biota are located off-Site when in contact with media). Fauna, such as birds and mammals, that can move on and off Site are covered in the on-Site Terrestrial Biota scenario as the exposure scenario occurs on-Site. 2 Hanns Inlet is part of the investigation area and considered to be on-Site for this exposure pathway assessment. 3 Includes users of Sports Fields.

38 2 October 2018

Assessment of known and potential human and ecological receptors, continued




Off

-Sit

e R

esid

ents

WP

B F

ish

C

on

sum

ers

Tem

po

rary

On

-S

ite

Res

iden

ts

Per

man

ent

On

-S

ite

Res

iden

ts

Ch

ildca

re

Att

end

ees

Sit

e V

isit

ors

3

Bas

e W

ork

ers

o

r T

rain

ees3

Intr

usi

ve

Co

nst

ruct

ion

W

ork

ers

Off

-Sit

e A

qu

atic

B

iota

Off

-Sit

e T

erre

stri

al B

iota

On

-Sit

e A

qu

atic

B

iota

(in

clu

din

g

Inle

t)

Ter

rest

rial

Bio

ta

Soil (Sullage Pit)



Dermal Contact



Groundwater

Ingestion (potable use)

Incidental Ingestion (non-potable use)

Dermal Contact (potable and other uses)

Direct Contact or Uptake ##

Surface Water (Fire Ground Leak-Repair-Live facility, Fire Ground lagoon, and South Creek wetlands)

Ingestion (potable use) + +

Incidental Ingestion (non-potable use) + +

Dermal Contact (potable and other uses)

Direct Contact or Uptake 1 Note that this is defined as an off-Site exposure scenario (i.e., the biota are located off-Site when in contact with media). Fauna, such as birds and mammals, that can move on and off Site are covered in the on-Site Terrestrial Biota scenario as the exposure scenario occurs on-Site. 2 Hanns Inlet is part of the investigation area and considered to be on-Site for this exposure pathway assessment. 3 Includes users of Sports Fields. ## Groundwater ecological criteria are for marine and freshwater protection, which are not directly applicable to terrestrial biota (such as grass and trees). + The sample from the Leak-Repair-Live facility at the Fire Ground was below screening levels for primary contact recreation.

3

39 2 October 2018





Off

-Sit

e R

esid

ents

WP

B F

ish

C

on

sum

ers

Tem

po

rary

On

-Sit

e R

esid

ents

Per

man

ent

On

-Sit

e R

esid

ents

Ch

ildca

re A

tten

dee

s

Sit

e V

isit

ors

3

Bas

e W

ork

ers

or

Tra

inee

s3

Intr

usi

ve

Co

nst

ruct

ion

W

ork

ers

Off

-Sit

e A

qu

atic

B

iota

Off

-Sit

e T

erre

stri

al

Bio

ta

On

-Sit

e A

qu

atic

B

iota

(in

clu

din

g

Inle

t)

On

Sit

e T

erre

stri

al

Bio

ta

Surface Water (Fire Station and Ornamental Lake)4

Incidental Ingestion ++

Dermal Contact ++



Surface Water (Former STP including West Creek)4


Dermal Contact ++



Surface Water (Sullage Pit)


Dermal Contact

Direct Contact or Uptake +++ +++


1 Note that this is defined as an off-Site exposure scenario (i.e., the biota are located off-Site when in contact with media). Fauna, such as birds and mammals, that can move on and off Site are covered in the on-Site Terrestrial Biota scenario as the exposure scenario occurs on-Site. 2 Hanns Inlet is part of the investigation area and considered to be on-Site for this exposure pathway assessment. 3 Includes users of Sports Fields. 4 There are no screening criteria available for PFHxA, however these levels are in excess of PFOA human health screening criteria in surface water at the Fire Ground and Former STP and groundwater at the Fire Ground. ++ Existing administrative controls and PPE are in place to prevent exposure. The screening value is based on consumption of 0.2L every day over decades, which is not likely due to the transient nature of construction works. +++ 99% species protection screening level exceeded for bioaccumulation but not 95% species protection screening level for direct contact.

40 2 October 2018





Off

-Sit

e R

esid

ents

WP

B F

ish

C

on

sum

ers

Tem

po

rary

On

-Sit

e R

esid

ents

Per

man

ent

On

-Sit

e R

esid

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Surface Water (Closed RRR Landfill and nearby South Creek)


Dermal Contact ++



Surface Water (storm-water drainage system)


Dermal Contact ++



Surface Water (Hanns Inlet)


Dermal Contact

Direct Contact or Uptake *** +++ +++


1 Note that this is defined as an off-Site exposure scenario (i.e., the biota are located off-Site when in contact with media). Fauna, such as birds and mammals, that can move on and off Site are covered in the on-Site Terrestrial Biota scenario as the exposure scenario occurs on-Site. 2 Hanns Inlet is part of the investigation area and considered to be on-Site for this exposure pathway assessment. 3 Includes users of Sports Fields. ++ Existing administrative controls and PPE are in place to prevent exposure. The screening value is based on consumption of 0.2L every day over decades, which is not likely due to the transient nature of construction works. +++ 99% species protection screening level exceeded for bioaccumulation but not 95% species protection screening level for direct contact. *** Multiple non-detects below LOR at entrance to Hanns Inlet indicate incomplete pathway to Western Port Bay. Note that surface water was not observed on-site at any other locations (some of the storm-water flows indicated in the table are ephemeral).

41 2 October 2018





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Sediment (Fire Ground, wetlands and South Creek)5


Dermal Contact ++



Sediment (Fire Station and Ornamental Lake)5


Dermal Contact ++



Sediment (Sullage Pit)6


Dermal Contact ++



1 Note that this is defined as an off-Site exposure scenario (i.e., the biota are located off-Site when in contact with media). Fauna, such as birds and mammals, that can move on and off Site are covered in the on-Site Terrestrial Biota scenario as the exposure scenario occurs on-Site. 2 Hanns Inlet is part of the investigation area and considered to be on-Site for this exposure pathway assessment. 3 Includes users of Sports Fields. 5 There are currently no reliable criteria for Tier 1 assessment of sediment, but PFAS was detected in sediments in these areas. 6 There are currently no reliable criteria for Tier 1 assessment of sediment, PFAS was not detected above LOR in sediments in these areas. ++ Existing administrative controls and PPE are in place to prevent exposure.

42 2 October 2018





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Sediment (storm-water drainage system)5


Dermal Contact ++



Sediment (Hanns Inlet)6


Dermal Contact ++



Sludge/biosolids (Former STP lagoons)5


Dermal Contact ++



1 Note that this is defined as an off-Site exposure scenario (i.e., the biota are located off-Site when in contact with media). Fauna, such as birds and mammals, that can move on and off Site are covered in the on-Site Terrestrial Biota scenario as the exposure scenario occurs on-Site. 2 Hanns Inlet is part of the investigation area and considered to be on-Site for this exposure pathway assessment. 3 Includes users of Sports Fields. 5 There are currently no reliable criteria for Tier 1 assessment of sediment, but PFAS was detected in sediments in these areas. 6 There are currently no reliable criteria for Tier 1 assessment of sediment, PFAS was not detected above LOR in sediments in these areas. ++ Existing administrative controls and PPE are in place to prevent exposure.

43 2 October 2018





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Pore Water (Hanns Inlet)7


Dermal Contact ++



Fish (Hanns Inlet)Ingestion

1 Note that this is defined as an off-Site exposure scenario (i.e., the biota are located off-Site when in contact with media). Fauna, such as birds and mammals, that can move on and off Site are covered in the on-Site Terrestrial Biota scenario as the exposure scenario occurs on-Site. 2 Hanns Inlet is part of the investigation area and considered to be on-Site for this exposure pathway assessment. 3 Includes users of Sports Fields. 7 Limited sample size resulted in LOR above screening level. ++ Existing administrative controls and PPE are in place to prevent exposure.

44 2 October 2018

The locations of on-site source areas are on Figure 10 below.

Figure 10 CSM: Graphical representation of identified source areas

Further detail on the magnitude of concentrations recorded for different environmental media sampled at the risk source areas is provided in Table 7 to aid in understanding which source areas are contributing to the risk, and where management response may focus in these areas. The relative contribution of PFAS impacts from each of these areas to the potentially elevated risks identified is discussed below.

Table 7 Risk contribution based on Source Area

Source Area

Risk Contribution Mechanisms

Relative Contribution to Risk

Fire Training Ground,

Confirmed PFAS presence in surface water, groundwater, sediment and soil

Majority of PFAS contained in soils at the Fire Training Ground consists of PFOS and is present within the top 3 – 4m of the soil profile, however, there is an unresolved data gap in regards to the underlying soil and suspected residual soil impacts below the base liner of the current lagoon.

From the available data 71% of the total PFAS mass in soil within the Fire Training Ground (estimated at 6.3 kg) is present as PFOS, with 23% PFHxS and 6% PFOA.

The lateral extent of impacted soils covers the entire Fire Ground area and the downhill area to the southwest of the Fire Ground connecting with South Creek.

Primary pathway of PFAS migration is surface water run off to South

Significant – major source area

45 2 October 2018

Source Area



Creek (which then discharges to wetlands and Hanns Inlet) and surface infiltration and direct impact to groundwater (which then discharges to wetlands and Hanns Inlet). The latter pathway is assumed from available data and an inferred groundwater/PFAS impacted soil interface. Surface soil PFAS in southern wetlands concentrations are an order of magnitude above those detected in the Fire Ground.

Interpolation of PFAS groundwater impacts indicates a contiguous plume between the Fire Ground and the Hanns Inlet Wetlands. Groundwater flow is both to the south and to the east from the Fire Ground, and although a separate groundwater source has been inferred at Hann’s Inlet Wetlands, over time these two plumes are believed to have migrated and become contiguous, resulting in a PFAS “front” migrating southeast with groundwater.

Potential direct contact or uptake and/or bioaccumulation or secondary poisoning risks were identified to on-site aquatic and terrestrial biota (soil and surface water)

Potential direct contact or uptake risks were identified to on-site aquatic biota (groundwater)

South Creek and Receiving Wetlands


South Creek and the receiving wetlands receive surface water and sediment runoff from the Fire Training Ground.

From the available data 93% of the total PFAS mass in soil within south Creek and the receiving wetlands (estimated at 9.7 kg) is present as PFOS, with 7% PFHxS and a negligible contribution of PFOA.



Significant – major source area

Fire station and Ornamental Lake


Soil results indicate a hotspot of soil bound PFAS impact immediately south adjacent to the Fire Station concrete hardstand, the interpolated extent of which extends to cover the ornamental lake and down into the ground near MW110.

From the available data 93% of the total PFAS mass in soil within the Fire Station and Ornamental Lake (estimated at 0.5 kg) is present as PFOS, with 7% PFHxS and a negligible contribution of PFOA.

PFOS impacts are interpolated to be confined to the shallow geology, and covering the northern half of the ornamental lake. As most samples in this area were shallow, there is a degree of uncertainty as to the vertical extent, however the interpolated extent shows PFOS impacts extending to approximately 2.5 m bgl.

PFOA soil impacts are confined to the immediate area south adjacent to the Fire Station concrete hardstand with an interpolated vertical extent of 2.5 mbgl.

PFHxS impacts show a similar lateral distribution to that of PFOS, but covering the entire Ornamental Lake and a greater area to the east of the Fire Station. The interpolated vertical extent of PFHxS is greater than that of PFOS, extending up to approximately 6 mbgl and was detected in soil samples recovered from the depth of the screened intervals in MW110 and MW111.

As PFHxS soil impact is present in the saturated zone, this is a likely pathway

towards dissolved phase groundwater impacts in this area. Surface water

Minor source area

46 2 October 2018

Source Area



samples were collected at two locations near the Fire Station, including the

Ornamental Lake and a storm-water drain outfall. The sample from the

Ornamental Lake (SW019) contained combined concentrations of PFHxS and

PFOS above the environmental and human health recreational screening

criteria (total 1.8 μg/L). In addition, both surface water samples also contained

combined concentrations of PFHxS and PFOS above the screening criteria

for marine protection (0.01 and 1.8 μg/L).

Sediment samples were collected at the two locations, co-located with surface

water samples in the Ornamental Lake (SD019) and the unnamed creek to

the east (SD020). The sample from the creek was non-detect for all

compounds and SD019 recorded a PFOS concentration of 0.005 mg/kg with

no other PFAS detected.

Groundwater dissolved phase PFHxS is being detected in groundwater from

MW110, consistent with the interpolated connection with soil bound PFHxS at

this area. The interpolated plume extends out into the northern section of the

Hanns Inlet Wetlands to the east of the Fire Station. Approximately 10% of the

interpolated soil impact is below the water table in this area, therefore the

contribution of PFAS to the groundwater is minimal and primarily consists of

PFHxS.



Former STP and West Creek

Confirmed PFAS presence in surface water, groundwater, sludge/sediment

and soil

Surface soils in the former STP (operated between circa1970 – 2001) area

are showing PFAS impacts consisting of PFOS and PFHxS with minor

concentrations of PFOA and shorter chain perfluoroalkyl carboxylates,

indicative of an aged source area where PFAS impacts were either

incremental in nature or did not occur recently. PFAS concentrations at

greater than 1 mbgl are below LOR, typical of PFAS impacts in source areas

such as at the former STP where soil impacts are often due to overflow

events. Interpolation of soil PFAS concentrations indicates a larger area of

PFAS impact surrounding the former STP area, however as soil sampling in

this area was opportunistic (i.e., co-located with monitoring well installation

and incidental soil samples) the lateral extent of PFAS impacts in soils

remains to be defined.

As PFAS impacts are contained to shallow soils, it is unlikely that shallow soil

PFAS impacts are contributing to the groundwater detections in this area.

Eight opportunistic sludge samples of biosolids were collected from four

separate locations, when the north-west and south-west lagoons dried out.

These samples all reported PFAS concentrations below the adopted biosolids

screening levels for agricultural application, however there were exceedances

Minor source area

47 2 October 2018

Source Area



of the human health screening levels

Previous investigations have highlighted a PFAS source entering the Site

directly above the Former STP, where the maximum inflow surface water

concentration was 0.008 µg/L PFOS in Inflow 6 (SW023). This location is on

the western boundary, where surface water runoff is originating from adjacent

farms and residential properties.

Surface water samples were collected at four samples from four separate

locations at the Former STP. The results indicate PFAS detected above LOR.

All surface water samples contained combined concentrations of PFHxS and

PFOS above the 99% marine protection and human health recreational

screening criteria (ranging from 2.96-10.5 μg/L).

Three sediment samples were collected from the wet lagoons in August 2017,

not that these samples may be more appropriately categorised as sludge

samples. These samples allowed the assessment of PFAS accumulation in

the sludge at the bottom of the Former STP lagoons. These samples

contained predominantly PFOS, but there were also a range of other PFAS

compounds detected at lower concentrations. The detectable PFOS + PFHxS

ranged from 0.067-1.544 mg/kg, with the highest detect at SD013



Stormwater drains

Confirmed PFAS presence in surface water and sediment

Potential direct contact or uptake and/or bioaccumulation or secondary poisoning risks were identified to on-site aquatic and terrestrial biota (surface water)

Low – minor diffuse source area

Sullage Pit Confirmed PFAS presence in ground water and surface water


Low – minor source area

Closed Rifle Range Landfill

Confirmed PFAS presence in ground water


Low – minor source area

Surface water Hanns Inlet

Confirmed PFAS presence in surface water.

The surface water samples collected from Hanns Inlet closest to the Marina

contained combined concentrations of PFHxS and PFOS above the adopted

screening criteria. The maximum detections were 0.0108 and 0.0109 µg/L at

SW036 and SW054 on the ebb tide. Most of the detects were close to the

LOR. The samples near Westernport Bay were all non-detects. There were no

Unquantifiable – Surface water in Hanns Inlet is primarily considered as a receptor

48 2 October 2018

Source Area



PFOA detects in Hanns Inlet.

While Aurecon is aware of AFFF storage and use in other parts of Western

Port Bay, such as the fire-fighting tug boats berthed north of Stony Point,

PFAS concentrations in Westernport Bay are not known at this stage.

Potential bioaccumulation or secondary poisoning risks were identified to on-site aquatic and terrestrial biota (surface water)

Based on the information presented in the DSI, and summarised above, the key source areas that are considered to have a significant contribution to the potentially elevated risks and potential future risks identified in the DSI, which require primary consideration of management response options comprise:

Fire Training Ground and nearby wetlands at South Creek

4.2 Risk listing and consequences

Table 8 below provides details of the potential elevated risks and potential risk sources requiring monitoring or management, including the potential consequences if the risks were to be realised

49 2 October 2018

Table 8 Risk contribution based on Source Area

9 It is noted that this exposure period is brief in comparison to human health recreational water screening criteria, which is based on daily ingestion of 0.2 L over a period of decades

Risk Identification

Risk to on-site ecological receptors (R001) Risk to Intrusive Construction Workers (R002)

Nature of Risk

Description

Direct or indirect exposure of soil, groundwater, sediment or surface water.

Accidental ingestion and/or dermal contact of soil, sediment, surface water and groundwater by Construction Workers is considered a potential exposure pathway during intrusive works requiring excavation below groundwater level.

This exposure scenario is brief with consideration to the human health recreational screening criteria 9 and should furthermore be mitigated by the incorporation of appropriate safe work practices and relevant personal protective equipment. These controls are understood to be a mandatory requirement of all contractors who are engaged for the purpose of undertaking construction and maintenance activities on the site.

Pathways Direct contact or uptake and/or bioaccumulation or secondary poisoning.

Source media from DSI works includes; onsite soils, surface waters, groundwater.

Incidental ingestion and/or dermal contact. It is however noted that dermal

contact is reported as being a minor exposure pathway because dermal

absorption is slow and does not result in significant absorption (National

Centre for Environmental Health 2017).

Source media from DSI works includes: soil, sediment, surface water and groundwater

Receptors Risks are considered in respect of onsite aquatic biota, (including crabs and worms living in the soils and sediments in Site wetlands or Hanns Inlet, and fish in Hanns Inlet) and onsite terrestrial biota vegetation, birds, mammals (including kangaroo, rabbits, cats, and dogs).

Noting that in terms of fauna the onsite biota is either native or feral and does not include any introduced grazing or livestock or primary production stock.

All contractors who are engaged for the purpose of undertaking construction and maintenance activities on the site.

50 2 October 2018

Primary Sources

Major source areas comprise:

Fire Training Ground, and South Creek and receiving wetlands

Minor sources areas comprise

Fire Station and Ornamental Lake Former STP Sullage Pit and Former Rifle Range Landfill

Source media includes; onsite soils, surface waters, groundwater

Major source areas comprise:

Fire Training Ground, and South Creek and receiving wetlands

Minor sources areas comprise

Fire Station and Ornamental Lake Former STP Sullage Pit and Former Rifle Range Landfill

Source media includes; onsite soils, surface waters, groundwater

Secondary Sources

Surface soils, sediments and surface waters within South Creek and downstream wetlands, West Creek (low risk secondary source), others including stormwater drain pipes.

Surface soils, sediments and surface waters within South Creek and downstream wetlands, West Creek (low risk secondary source), others including stormwater drain pipes.

Contributing Sources

Sediment in drainage lines, overland surface water flow from impacted surface soil areas and diffuse site wide groundwater impacts.

Sediment in drainage lines, overland surface water flow from impacted surface soil areas and diffuse site wide groundwater impacts.

Current Impacts

No current impacts of consequence are observed other than detectable concentrations of PFAS within edible fish species caught within the confines of Hanns Inlet. It is noted that the reported concentrations in the liver and flesh of all edible fish sampled were below relevant screening criteria protective of human health.

No current impacts or consequences are known to have been experienced and reported.

Potential Impacts

Potential adverse effects to ecological health from higher order bioaccumulation within food web. Assessment of these potential risk were outside of the scope of the DSI.

Potential impacts are unlikely owing to the anticipated short duration of any potential exposure, the absence of a concentrated source of PFAS i.e., there is no AFFF present on site anymore, and the PFAS within the environs is significantly diluted and dispersed, and the expected adoption of appropriate date work practices and relevant personal protective equipment.

Temporal Risks

Ongoing source(s) of PFAS within the terrestrial portion of the Site (including groundwaters) which will continue remain on and within the site and will to discharge to Hanns Inlet in the absence of control or mitigation measures.

Ongoing source(s) of PFAS within the terrestrial portion of the Site (including groundwaters) which will continue remain on and within the site and will to discharge to Hanns Inlet in the absence of control or mitigation measures.

Extent

Location Source zones within soil and groundwater are identified and sufficiently delineated within the DSI, with the exception of the underdetermined potential residual PFAS mass in soil beneath the base liner in the current Fire Training Ground.

Source zones within soil and groundwater are identified and sufficiently delineated within the DSI, with the exception of the underdetermined potential residual PFAS mass in soil beneath the base liner in the current Fire Training Ground.

51 2 October 2018

Spatial Extent As identified in the DSI. As identified in the DSI.

Existing Management Controls

Defence Use of 3M Lightwater and Ansulite ceased on Site in 2006 and 2008 respectively.

The waters of Hanns Inlet are under Commonwealth (Defence) Control and access for recreational use, including fishing is strictly prohibited.

Use of 3M Lightwater and Ansulite ceased on Site in 2006 and 2008 respectively.

All contractors all contractors who are engaged for the purpose of undertaking construction and maintenance activities on the site are required to have in place adequate safe work practices and method, including the use of appropriate PPE.

Stakeholders None. Contractors will generally have in place adequate safe work practices and method, including the use of appropriate PPE as part of the general risk management and compliance with Work, Health and Safety legislation and regulation requirements.

Potential Additional Controls

The site is subject to a significant redevelopment program which will occur between 2018 and 2028. The redevelopment works will comprise, in part:

Decommissioning of the existing Fire Training Ground and construction of a new Fire Training Ground

Modification to the Ornamental Lake and immediate surrounding land

Construction of new deep sewer lines and infrastructure.

The redevelopment works will result in the removal of PFAS impacted materials within the Fire Training Ground, the Ornamental Lake and adjacent to the Fire Station. The current design solution incorporates the consolidation of impacted materials within a containment cell which will be designed in general accordance with the Defence Per- And Poly-Fluoroalkyl Substances (PFAS) – Engineered Stockpile Facility Performance Specification.

Further details on the specific nature and extent of any remediation works that will be achieved through the redevelopment program are yet to be determined.

The site is subject to a significant redevelopment program which will occur between 2018 and 2028. The redevelopment works will comprise, in part:

Decommissioning of the existing Fire Training Ground and construction of a new Fire Training Ground

Modification to the Ornamental Lake and immediate surrounding land

Construction of new deep sewer lines and infrastructure.

The redevelopment works will result in the removal of PFAS impacted materials within the Fire Training Ground, the Ornamental Lake and adjacent to the Fire Station. The current design solution incorporates the consolidation of impacted materials within a containment cell which will be designed in general accordance with the Defence Per- And Poly-Fluoroalkyl Substances (PFAS) – Engineered Stockpile Facility Performance Specification.

Further details on the specific nature and extent of any remediation works that will be achieved through the redevelopment program are yet to be determined.

52 2 October 2018

5 ONGOING MONITORING PLAN

5.1 Overview

The Management Area ongoing monitoring plan (OMP) monitors changes to the contamination plume and surface water contamination characteristics.

Changes may result from the specific or cumulative impact of remediation or containment actions, existing transportation trends, changes to hydrogeology, or weather events.

The ongoing monitoring plan (OMP) for the Management Area is set out in Appendix F. An OMP forms a standard component of all PMAPs.

5.1.1 Objective and purpose

The objective of the OMP is to provide information on changes in PFAS contamination originating from a Defence Base to inform risk management decisions by Defence and State/Territory agencies to protect human health and the environment.

Data on changes in the distribution, concentration, transport (pathways and flow rates) and transformation of the contaminants and assessment against appropriate guideline values provides:

an evidence base for targeted and effective risk management of PFAS contamination to protect human health and environmental receptors currently impacted by PFAS.

an early warning that additional management of PFAS contamination may be warranted in areas not currently affected by PFAS.

5.1.2 Impacted decisions

Changes detected through the implementation of the OMP may inform a number of risk-management decisions including:

additional investigations

re-assessment of one or more remediation or containment actions

additional remediation or containment actions

changing risk management actions at receptor level (e.g., provision or cessation of alternate drinking water supplies)

changes to State/Territory advice on types of exposure-minimisation behaviours (e.g., consumption of home produce or seafood)

changes to State/Territory advice on boundaries of a designated management area and the management zones within

changes or refinements to the monitoring network, frequency and parameters

5.1.3 Related documentation

One or more specific remediation action plans (RAPs) may be developed for the Management Area. The RAPs will contain specific on-going monitoring actions to assess and validate the impact of that remediation plan.

5.2 OMP communications

The following will be shared with relevant Victorian authorities (including EPA Victoria) and made publicly available:

53 2 October 2018

OMP monitoring data collected during the implementation of the OMP decisions made in response to the data collected during implementation of the OMP changes to the OMP in response to incoming data over the implementation period

5.3 OMP summary

The OMP includes monitoring of both surface and groundwater at locations which were identified during the DSI and where baseline conditions have been established for comparison. The OMP also identifies gaps where additional groundwater monitoring points should be incorporated. Locations of existing and proposed monitoring points are summarised in Appendix F.

The HMAS Cerberus ongoing monitoring plan aims to achieve the following:

Monitor and assess variation in PFAS concentrations in groundwater and surface water over time

To collect further baseline data in groundwater and surface water, for comparison during and after remediation of sources to assess the success of the remediation and management methods

To further delineate the migration of PFAS in groundwater from the site, and collection of additional groundwater data at the sites northern boundary

Conduct surface water sampling during a worst-case scenario (e.g. extreme rainfall events)

Ongoing monitoring of surface and groundwater requirements will vary through the implementation period of the PMAP as detailed in Table 9. Due to the primary PFAS migration pathway being the flow of surface water off site (Aurecon 2017), the OMP will focus the efforts on the monitoring of surface water bodies. Migration of PFAS in groundwater from source areas is considerably slower compared to surface water, as such a less intensive, lower frequency monitoring regime is proposed.

Table 9 Risk listing

Matrix Location Interval* Analytical Suite

Surface Water On and off base Biannual Physical parameters (pH, electrical conductivity, turbidity, DO, temperature, redox potential)

PFAS

Groundwater Groundwater on base Biannual Physical parameters (pH, electrical conductivity, turbidity, DO, temperature, redox potential)

PFAS

* Specific remediation action plans (RAPs) may require more frequent monitoring

5.4 OMP review

The OMP will be reviewed regularly. The review frequency will be based on site-specific characteristics and the existing trend data available. The review frequency may be revised during the implementation period as more data becomes available.

54 2 October 2018

6 OPTIONS IDENTIFICATION AND ANALYSIS

6.1 Options identification and analysis

Context

HMAS Cerberus is in a relatively unique situation in that the Site is subject to a major capital works and redevelopment program that will occur over the next 5 years and will have a significant influence on the identified risks and the overall management of residual PFAS impacts within the Site.

The redevelopment works will in part facilitate the decommissioning of the Fire Training Ground (and the construction of a new Fire Training facility), the modification and realignment of the Ornamental Pond (and immediate surrounds), and the construction of a new deep sewer system and associated infrastructure. These works will result in the generation of surplus soils which will be impacted by PFAS, which the project will need to identify suitable management and/or remediation and/or treatment measures for. Whilst not a primary objective of the redevelopment works program, these works will achieve a significant reduction in the residual uncontrolled PFAS mass loading within the soil. At present, the design of these works is not sufficiently advanced to allow an understanding of the extent (locations, dimensions and volume) of PFAS impacted soils, and other construction materials, that will be removed as part of these works or the end fate of these materials.

In the following sections management and/or treatment options have been developed to provide practical solutions to prevent or minimise the migration of PFAS beyond the Defence boundary which can potentially be incorporated into the site redevelopment works as well as implemented as stand-alone options if warranted.

Key considerations in the identification and analysis of response and/or management options, other than potential integration with the redevelopment program are as follows:

The scale of the Management Area is rated as small

No PFAS contamination and no likely transport pathways (other than in surface waters in Hanns Inlet) beyond the terrestrial and operational boundary of the Base, which includes Hanns Inlet) have been identified

The identified potential risks which require consideration of response and/or management options are:

o risk to on-Site ecological receptors in the management area through direct contact or uptake and/or bioaccumulation within impacted media or secondary poisoning

o Risk to on-Site intrusive construction workers primarily through incidental ingestion of PFAS impacted media.

The major residual source areas (PFAS in soil) are identified as the Fire Training Ground, South Creek and the receiving wetlands

The primary transport vector for the migration of PFAS is transport by way of:

o Surface waters (including discharge through drainage channels), through dissolution PFAS in soils and/or carriage of PFAS absorbed to sediment;

o Groundwater, through leaching of impacted soils and/or dissolution resulting from direct contact with impacted soils

PFAS concentrations in groundwater are relatively elevated within the immediate proximity of the major and to a lesser extent the minor residual source areas but are otherwise generally diffuse across the site, particularly in respect of PFHxS

Surface waters and groundwater ultimately discharges into Hanns Inlet.

55 2 October 2018

Approach

To reduce or mitigate the identified on-site risks the observed complete linkages between PFAS sources, exposure pathways and receptors at risk need to be broken or eliminated. In the context of the identified risks to onsite ecological receptors, noting that the fauna which is present is native and potentially migratory, and does not include grazing or primary production livestock, the primary avenues to break these linkages will be through source and/or pathway control.

The development of management and/or treatment options and the options assessment approach is consistent with:

Defence’s guiding principles presented in Section 1.6; and PFAS National Environment Management Plan, Australian and New Zealand Heads of EPA

The NEMP identifies the following preferred hierarchy of treatment and remediation options which will be used to guide the options identification and analysis:

1. Separation, treatment and destruction: on-site or off-site treatment of the contamination so that it is destroyed, removed or the associated risk is reduced to an acceptable level

2. Onsite encapsulation in engineered facilities with/without immobilisation: if the source site is hydrogeologically appropriate, onsite encapsulation will acceptably manage risk to the on- and offsite beneficial uses (direct and indirect) for soils, surface water and groundwater

3. Offsite removal to a specific landfill cell: leachate should be captured, treated and the removed PFAS destroyed. This may or may not include immobilisation prior to landfill disposal, noting that the conditions in the landfill may reverse or diminish the immobilisation chemistry in ways that are difficult to predict. Immobilisation prior to landfill disposal may require environmental regulatory approval.

Options identification

The following management and treatment options (Table 10) have been identified as being of potential relevance to reduce or mitigate the identified on-site risks

Table 10 Summary of management options to be considered

PFAS Management Options Focus and objective

Potential to reduce or mitigate

identified risk

Base case: Do-nothing option -

Source Control

Option 1a: Engineering control - Immobilisation of PFAS in soils at primary source areas

Focus of engineering control would be at the major source areas i.e., the Fire Training Ground and South Creek and receiving wetlands. Objective is to immobilise PFAS within soil mass through the ex-situ addition of reagents and blending with impacted to soils, with subsequent replacement or reuse of stabilised soil.

Option 1b: Engineering control - Capping of PFAS in soils at primary source areas

Focus of engineering control would be at the major source areas i.e., the Fire Training Ground and South Creek and receiving wetlands. Objective is to provide a permanent low permeability cap over PFAS impacted soils to prevent mobilisation by surface water and/or leachate generation and/or dissolution and migration into underlying groundwater

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identified risk

Option 1c: Engineering control - Excavation of PFAS in soils at primary source areas and storage within on-site engineered repository

Focus of engineering control would be at the major source areas i.e., the Fire Training Ground and South Creek and receiving wetlands. Objective is to remove residual mass of PFAS impacted soils (to the extent practicable) and consolidate within an engineered repository with appropriate leachate collection and capping system.

Option 1d: Engineering control - Excavation of PFAS in soils at primary source areas and either on or off-site treatment (destruction)

Focus of engineering control would be at the major source areas i.e., the Fire Training Ground and South Creek and receiving wetlands. Objective is to remove residual mass of PFAS impacted soils (to the extent practicable) and treat through destruction means either on or off-site.

Secondary source control and/or pathway control

Option 2: Engineering control - Treatment of surface water at drain discharge points

Focus of engineering control would be at the drainage discharge points adjacent Hanns Inlet. Objective is to remove residual mass of PFAS from surface water prior to discharge to Hanns Inlet.

Option 3: Engineering control - Installation of a permeable reactive barrier within PFAS impacted creeks

Focus of engineering control would be at or near terminal point of South Creek adjacent Hanns Inlet. Objective is to remove residual mass of PFAS from surface water prior to discharge to Hanns Inlet.

Option 4a: Administration control – Prohibit installation of groundwater bores within the management area for on-site use.

Focus would be in areas with the management area where PFAS concentrations exceed drinking water screening levels, such as at the Fire Ground and South Creek wetlands. This option would also mitigate risk posed to precluded groundwater beneficial uses, such as stock watering or irrigation. Installation of bores for monitoring or temporary construction dewatering would be permitted with appropriate risk management (such as set out in the ECC for the activity).

Option 4b: Administration control – Prohibit on base use of PFAS impacted irrigation water

Focus would be to evaluate any new sources of water that may be used for Site irrigation.

Option 4c: Administration control – Maintain no trespassing signs / prohibit recreation access to Hanns Inlet waters

Focus would be to maintain the exclusion zone around Hanns Inlet to prevent fishing in Hanns Inlet.

Option 4d: Administration control – Ensure all on-site workers undertaking intrusive construction or maintenance works within PFAS-impacted areas have adequate health-and-safety procedures and protocols in place in regards to potential exposure to PFAS, including provision of adequate PPE

Focus is to break any potential connection between PFAS-impacted media in the management area and workers undertaking intrusive and/or maintenance activities.

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identified risk

Option 4e: Administration control – Ensure and maintain adequate record of PFAS impacted areas within Base e.g. use of the CSR and PFAS IMB database

Focus is to ensure that the locations of PFAS-impacted material are captured in a centralised database (ideally, a spatial database) to allow rapid identification of the nature of any PFAS-impacted materials that could be encountered during Site activities; in particular, intrusive works.

Receptor control

In the context of the identified risks to on-Site ecological receptors the following is noted:

- Flora: the flora which is present is predominantly native, and is not for human consumption - Fauna: the fauna which is present is predominantly native and potentially migratory, and does

not include grazing or primary production livestock

Options for risk reduction or mitigation through receptor control or management are not reasonable or practicable and accordingly will not be considered in the further options assessment with the focus being directed to effecting change at the source and/or pathway levels.

Detailed consideration of each of these options is presented in Appendix E.

Construction methods and technology assessment

The following management and treatment options have been identified as being of potential relevance to reduce or mitigate the identified on-site risks, and for potential application in conjunction with the redevelopment works. Table 11 details the engineering construction methods and treatment technologies that are presented in the NEMP 2018 (amended from Appendix C, NEMP 2018). Each option has been assessed on its commercial viability and feasibility for implementation for treatment of PFAS at HMAS Cerberus. Commercial viability relates to technologies that have been proven to be effective at an appropriate scale. Technologies are considered feasible if they are suitable for implementation at HMAS Cerberus to address the source and/or pathway. Additional treatment technologies have been included that are not detailed in the NEMP 2018 which are considered as options for the management of PFAS.

For consistency across the Defence portfolio Aurecon has reviewed (for temporal relevance and currency) and has adopted the outcomes of the technology screening which was applied in the design of the PMAP for HMAS Albatross10.

10 PFAS Management Area Plan – HMAS Albatross, dated 1 May 2018, prepared by Aurecon.

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Table 11 Summary of potential construction methods and remediation technologies

Source Process Definition Media Commercially viable Feasible Technology

considered as part of HMAS Cerberus PMAP

Indirect reference in NEMP 2018

Surface capping / engineered repository

Physical containment of PFAS

Engineered containment

Soil and waste Yes Yes Yes

Technologies available in Australia, as presented in NEMP 2018

Adsorption (stabilisation / immobilisation)

Containment of PFAS Adhesion of PFAS to the surface of an absorbent

Water and wastewater Yes Yes Yes

Stabilisation/ immobilisation

Containment of PFAS Addition of a binding agent to soil to reduce the mobility of PFAS

Soil and waste Yes Yes Yes

Reverse osmosis and nanofiltration

Concentration of PFAS for offsite disposal Removal of PFAS from water using semi-permeable membranes

Water and wastewater No No No Requires high

concentration and large volumes of media

Pyrolysis and oxidative thermal destruction

Destruction of PFAS Alteration of chemical composition using high temperature in the absence or presence of oxygen

Soil, aqueous film-forming foam concentrates, solid concentrates from adsorption, liquid concentrates from reverse

osmosis, nanofiltration and ion exchange

No Yes No

Thermal desorption Concentration of PFAS for offsite disposal Separation of PFAS from solid materials using high temperatures to increase the volatility of the PFAS

Soil and waste Potentially

Trials underway at time of writing

Potentially. Proof of Treatment trial

underway

No

In-situ oxidation or reduction

Destruction of PFAS Application of chemicals and often heat to break down the PFAS into more environmentally friendly forms

Soils and groundwater No Trials underway at time

of writing

No No

Foam fractionation/ separation

Removal and concentration Separation of PFAS from groundwater and wastewater into a foam.

Surface, groundwater and wastewater No Trials underway at time

of writing

No No

Ultrasonication/ zoochemistry

Destruction of PFAS Treatment using intense ultrasonic wave energy to change the PFAS compounds into more environmentally friendly forms.

Water and wastewater No No No

Electrochemical oxidation/reduction

Destruction of PFAS Defluorination of PFAS using electrodes

Water and wastewater No Trials underway at time

of writing

No

No

Additional technologies considered as part of the HMAS Cerberus PMAP

Bio-engineered wetland

Concentration of PFAS for offsite disposal Bio-accumulation and/or biotransformation of PFAS within an engineered ecosystem

Water and wastewater No Trials scheduled at time

of writing

No No

Permeable reactive barrier (PRB)

Containment of PFAS In situ adhesion of PFAS to the surface of an absorbent(aquifer)

Groundwater Yes Yes Yes

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The detailed identification and analysis of an option or set of options for each risk is set out in Appendix E, using the criteria set out in Appendix D.

6.2 Preliminary comparative analysis

Following completion of the construction method and technology assessment all of the potential management options identified in Table 11 were carried through for a preliminary comparative analysis with the exception of Option 1d - Excavation of PFAS in soils at primary source areas and either on or off-site treatment (destruction), which was discounted on the basis of the present absence of EPA licensed treatment facilities in Victoria, although noting that two companies are understood to currently be undertaking proof of treatment trails for thermal desorption / thermal destruction.

The preliminary comparative analysis comprised using the criteria set out in Section 3.5, a ranking was undertaken of each option for site sources of PFAS is presented in Table 6 (Appendix E). The ranking used a simple numerical rating of between 1 and 5 (5 as most desirable for that criterion). For each source area posing an elevated risk the total for relevant options were used to evaluate the overall ranking against the other options.

The following summarises the outcomes of the preliminary comparative analysis:

Primary source control

In terms of the engineering control options the comparative analysis generally scored the immobilization of residual PFAS in soils ahead of the excavation and containment of PFAS impacted soils, and likewise ahead of the capping of surface impacted soils for all source areas (major and minor), however, the absolute difference in scoring was marginal.

The application of these engineering source control options relative to the major source areas i.e., the the Fire Training Ground, South Creek and the receiving wetlands, is practically only applicable to the former i.e., the Fire Training Ground, as the undertaking of any significant excavation and soil disturbance works within South Creek and the receiving wetlands would not provide a net environmental benefit and would serious impact upon if not destroy the current terrestrial ecosystem. It is also noted the wetlands are identified as environmentally sensitive as nationally important wetlands listed on the EPBC search tool web site.

The potential applicability of all three engineering options for application at the Fire Training Ground provides some flexibility in the coordination with the redevelopment program.

The implementation of engineering source control outside of the Fire Training Area i.e., directed towards the minor source areas, is not considered to provide sufficient relative risk reduction for the likely expenditure that would be required to implement, owing to the relatively low mass of residual PFAS within these areas compared with the Fire Training Ground. The incorporation of engineering source control measures within and adjacent the Ornamental Lake (and Fire Station) are only justified on the basis of the redevelopment works that will occur within these areas.

Secondary source and/or pathway control

In terms of the capture and passive treatment of surface water at drain discharge points and at the South Creek/Wetlands interface with Hanns Inlet, both options scored equally and are considered worthy of potential implementation but only following; the implementation of the engineering source control opportunities that will be brought about by the redevelopment works, and in the event that there is not an observed reduction on PFAS discharging from these points over time as determined through the implementation of the OMP.

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Administrative controls

Each of the administrative controls generally received an equivalent score and ranking and are considered worthy of implementation.

6.3 Integrated options analysis outcomes

Implementation of response measures in the form of engineering source control should be undertaken where opportune to do so through integration with the redevelopment works, and with the areas directly involved with or affected by the redevelopment works i.e., the Fire Training Ground and the Ornamental Pond and land adjacent the Fire Station.

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7 RECOMMENDED PMAP RESPONSE ACTIONS

7.1 List of recommended PMAP response actions

Based on the comparative analysis and the integrated analysis, and being cognisant of the above key considerations the recommended actions for the identified risk are set out below:

Continue the use of PFAS-free training foam (such as Solberg) for all training exercises within the Fire Training Ground – already implemented.

Undertake source removal and/or treatment of residual PFAS within the Fire Training Ground, as part of the Base Redevelopment Project. The current design solution incorporates the consolidation of impacted materials within a containment cell (option 1c - on-site engineered repository) which will be designed in general accordance with the Defence Per- And Poly-Fluoroalkyl Substances (PFAS) – Engineered Stockpile Facility Performance Specification.

Manage any residual soil and sediment impacts encountered during the Base Redevelopment Project in accordance with the Defence PFAS Framework - Construction and Maintenance projects. It is noted that this will entail the testing and treatment of groundwater and surface water from dewatering trenches and open excavations, and the containment or sensitive reuse of soils and demolition waste.

Mitigate risk to on-Site intrusive/maintenance workers through the continuing imposition of administrative control measures, most of which are already in place, from both Defence’s and the professional contractor’s perspectives.

Mitigate risks associated with precluded beneficial uses, such as stock watering or irrigation, through administrative control measures, such as banning of groundwater extraction except for monitoring or temporary construction dewatering.

Implementation of the OMP to assess the effectiveness of the cessation of AFFF and to assess temporal trend in residual PFAS concentrations in surface water and groundwater.

7.2 Comparative PMAP implementation timeframes


Short term:

o Prepare and implement administrative control measures (Options 4a through 4d)

o Implement OMP

Medium term:

o Review implemented administrative control measures with regards to effectiveness

o Ongoing surface water and groundwater monitoring as per OMP


Long term:

o Implement preferred integrated source control option for Fire Training Ground and Ornamental Pond with Base Redevelopment Project.

Note that estimated timeframes are indicative only at this stage and that priority of these actions needs to be revisited in later versions of this PMAP. Priority of management actions may change based on a range of variables including:

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the outcomes of earlier PMAP response actions

the development of relevant legislation, policy and guidelines

changes in land use surrounding the site

feedback received from the local community and stakeholders

the availability of new relevant science and technology

timeframes for approvals (e.g., PWC) and procurement processes.

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8 REVIEW AND UPDATE

This PMAP has been developed on the basis of existing knowledge, current government policy settings, and available scientific methodologies and technology. PFAS management is a field that is rapidly evolving.

Over the primary implementation period, Defence will review and update (where necessary) the PMAP at intervals of 12 months to ensure currency of the document and the validity of is current its recommendations.

Performance measures for individual response actions under this PMAP will be contained in the relevant approval or procurement documentation.

Over the extended implementation period, the Defence branch responsible for the remaining response management actions, will review/update the PMAP (or its successor document) at intervals of 12 months to ensure that the document is current and its recommendations are valid.

An earlier review/update may be triggered where circumstances demand it. Examples of circumstances that may trigger a review/update include:

a performance evaluation of specific PMAP response actions that recommends changes or advises that its objectives are not being met.

updated information obtained from PMAP response actions involving further investigations or monitoring outcomes.

feedback and information received as a result of the on-going community and/or stakeholder consultation.

any significant changes of land use which may occur in the area within the Management Area or adjoining land.

changes in legislation, policy and guidelines/standards that could have a direct bearing on the project.

changes to Defence’s strategic approach to managing PFAS contamination.

on-going research and development of management/remediation technologies to address PFAS impacted soil and groundwater.

changes to water supply options available to land owners and residents in the area surrounding the site.

progress in risk management and remediation activities that may require realignment or further calibration.

new scientific findings that update the knowledge or assumptions underlying the PMAP or specific PMAP response actions.

any other new information that has the potential to positively or negatively impact the objectives of the PMAP.

Any proposed changes to this PMAP will be communicated and discussed with the community and key stakeholders including Federal and State/Territory government agencies and the local Council.

.

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APPENDIX A: Regulatory and policy analysis11

This Appendix identifies relevant legislation, policy and standards applicable to the development and prioritisation of management options for the Management Area. It further identifies key drivers and constraints affecting that development and/or prioritisation.

A1 Commonwealth legislation, policy and standards

A1.1 Outline

The following Commonwealth legislation and policy is relevant to the risk management of the Management Area:

Commonwealth legislation

Environment Protection and Biodiversity Conservation Act 1999

Work Health and Safety Act 2011

Water Act 2007

National Environment Protection (Assessment of Site Contamination) Measure 1999, as amended in 2013. (NEPM 2013)

Commonwealth policy, standards and guidance

Defence policy, standards and guidance

Defence Environmental Policy

Defence Estate Strategy 2016-2036

Defence Environmental Strategy 2016-2036

Defence Construction and Maintenance Framework 2018

Defence PFAS Response Management Strategy 2018

Defence Interim Response Management Guidelines 2018

Defence PMAP Template and Guidance 2018

Commonwealth whole-of-government policy, standards and guidance

PFAS National Environmental Management Plan 2018 (NEMP), HEPA January 2018

The Australian and New Zealand Guidelines for Fresh and Marine Water Quality, ANZECC 2000

Final Health Based Guidance Values (HBGV) for PFAS for use in site investigations in Australia, FSANZ February 2017

A1.2 Key drivers and constraints impacting on development/prioritisation of options

Currently there is limited Commonwealth legislation on the designation of waste disposal criteria. Whilst the PFAS NEMP indicates potential criteria to be adopted at the State level for a State based

11 For consistency across Defence Portfolios the text has been adopted from the PFAS Management Area Plan prepared for RAAF East Sale (Senversa, 2018).

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receiving site, there is no approved landfill disposal site in Victoria that is licensed to receive PFAS impacted solids.

The PFAS NEMP document outlines the preferred framework for PFAS management including containment, remediation, treatment and disposal. The document acknowledges that each site is unique and any management response must consider site-specific conditions in determining the best approach to the management of PFAS. Overall the document presents the hierarchy of options for site clean-up, which is consistent with the policy intent of the Victorian waste management requirement (refer below), being any clean-up of land will reflect the order of preference set out in the waste hierarchy (i.e., treatment and reuse on–site is preferred to treatment and reuse off-site, while long-term containment off-site is least preferred.

A2 State/Territory Legislation and Policy

A2.1 Outline

The following State legislation and policy is relevant to the risk management

of the Management Area:

Environment Protection Act 1970 – The Act was established to provide a regulatory framework for the protection of the environment in Victoria having regard to the principles of environment protection. Under the EP Act discharges to the environment must be managed so that they do not adversely affect the receiving environment.

Water Act 1989 – Provides the framework for allocating surface water and groundwater resources throughout Victoria. Under the Act, regional water corporations have been delegated the responsibility for the licensing of groundwater in Victoria. Under the Act, the Crown retains the right to use, flow and control of groundwater.

Planning & Environment Act 1987 – The Act sets out the framework for Victoria’s planning system and importantly requires development to consider the effects on the environment and the state of the environment’s potential to affect a development.

State Environment Protection Policy (Groundwaters of Victoria) (SEPP (GoV)), Victoria Government Gazette, No. S 160 (17 December 1997) - Identifies protected environmental values of the groundwater resources of Victoria and present attainment goals to restore those values where pollution has occurred.

State Environment Protection Policy (Prevention and Management of Contamination of Land) (SEPP (PMCL)), Victoria Government Gazette, No. S 95 (4 June 2002) - Identifies protected environmental values of land in Victoria and present attainment goals to restore those values where pollution has occurred. Presents the waste management hierarchy which places treatment and reuse above off-site landfill disposal when managing wastes.

State Environment Protection Policy (Waters of Victoria) (SEPP (WoV)), Victoria Government Gazette, No. S 107 (4 June 2003) - Identifies protected environmental values of the water resources of Victoria and present attainment goals to restore those values where pollution has occurred.

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Environment Protection (Scheduled Premises) Regulations 2017 – Identifies activities considered to represent higher environmental risk and deems them to be Scheduled for the purposes of the Environment Protection Act and requires Works Approval and Licensing by the Victoria EPA for facilities to be permitted to emit or deposit wastes to the environment.

Environment Protection (Industrial Waste Resource) Regulations 2009 – Identifies the industrial waste categorisation process and details the requirements for the storage, transport and disposal of prescribed industrial wastes (including soil), which includes the following key guidelines:

EPA Publication IWRG621 – Industrial Waste Resource Guideline – Soil Hazard Categorisation and Management, (June, 2009).

EPA Publication IWRG701 – Industrial Waste Resource Guideline –Sampling and Analysis of Waters, Wastewaters, Soils and Wastes, (June, 2009).

EPA Publication IWRG702 – Soil Sampling, (June 2009).

EPA Publication IWRG821 – Waste Transport Certificates, (June 2009).

A.2.2 Key institutional drivers and constraints impacting on development/prioritisation of options

Key constraints in Victoria for off-site options to manage PFAS impacted solids and liquids is the lack of guidance on disposal criteria or the provision of licensed solid waste treatment options. Currently PFAS impacted liquid wastes are considered Category A Prescribed Industrial Wastes and there are limited options for handling small volumes of liquids in Victoria.

The Industrial Waste Resource Guidelines currently do not have threshold criteria for PFAS impacted soil and such soils cannot be transported off-site, without an EPA exemption or approvals. The Victorian EPA does not have a formal position on the soil hazard categorisation of PFAS impacted soils and there are currently no facilities licensed to receive the waste. The EPA has indicated that they consider PFAS impacted soils to be a prescribed industrial waste as discussed here: http://www.epa.vic.gov.au/your-environment/land-and-groundwater/pfas-in-victoria/managing-pfas- impacted-wastes-in-victoria.

Any option to manage PFAS impacted solids in an off-site facility is generally treated as a landfill operation and requires consideration under local government regulations and referral to the EPA to consider the Environment Protection (Scheduled Premises) Regulations. Typically, this involves Works Approval with associated community consultation. The requirements of the PFAS NEMP would be considered in such reviews.

A3 Planning Instruments or environmental permitting/licence controls

A3.1 Outline

Any option to manage PFAS impacted solids in an off-site facility (treatment or disposal) requires consideration under local government planning controls and referral to the EPA to consider the Environment Protection (Scheduled Premises) Regulations. Typically, this involves Works Approval, planning permit and

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associated community consultation. The requirements of the PFAS NEMP would be considered in such reviews.

Transport of large quantities of wastes to a treatment or disposal facility may require local government (Council) consent

A3.2 Key drivers and constraints impacting on development/prioritisation of options

Currently there are no licensed PFAS impacted solid waste treaters or disposal sites. This presents significant limitations to the consideration of off-site options for managing PFAS impacted solids.

It is understood that two companies RENEX and EnviroPacific are seeking to undertake and/or undertaking proof of performance trials for high temperature thermal PFAS destruction. At present neither companies are licensed by the EPA to receive PFAS wastes.

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APPENDIX B: Interim response management analysis

This Appendix sets out Interim Response Management (IRM) actions relevant to the Management Area, determines whether the actions address an identified risk (in whole or part), and applies the assessment of the relevant project director on whether the action has been effective in meeting its objective. As a result of that assessment, IRM actions may be recommended for continued implementation and progressed for inclusion in the PMAP options analysis. At this time no IRM actions have been identified.

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APPENDIX C Source – pathway – receptor analysis

Conceptual Site Model Visualisation

The known and potential sources, receptors and pathways that are discussed above form a CSM. A visualisation of the CSM is presented in the following set of figures, which show the known and potential exposure media and pathways for the nine potential PFAS sources12 on the Site:

Fire Ground and associated wetlands (Figure C-1)

Fire Station and Ornamental Lake (Figure C-2)

Former STP (Figure C-3)

Sullage Pit (Figure C-4)

Sports Fields (Figure C-5)

Potential minor sources, including Closed Rifle Range Road landfill, Closed outdoor swimming pool landfill, Closed indoor swimming pool landfill, Former Dry-Cleaning facility, former fuel storage areas and Coal Loading area (Figure C-6)

Bushfire Zone (Figure C-7)

Hanns Inlet Sediment and Pore Water (Figure C-8)

Storm-water drains (Figure C-9)

It is important to note that anecdotal information has been relied upon, and the data gaps are to be assessed in the field work program.

12 The potential minor sources have been grouped for clarity

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Figure C-1 Visualisation of the Conceptual Site Model at the Fire Ground (Exposure pathways and receptors)

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Figure C-2 Visualisation of the Conceptual Site Model at the Fire Station (Exposure pathways and receptors)

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Figure C-3 Visualisation of the Conceptual Site Model at the Former Sewage Treatment Plant (Exposure pathways and receptors)

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Figure C-4 Visualisation of the Conceptual Site Model at the Sullage Pit (Exposure pathways and receptors)

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Figure C-5 Visualisation of the Conceptual Site Model at the Sports Fields (Exposure pathways and receptors)

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Figure C-6 Visualisation of the Conceptual Site Model at the potential minor sources (Exposure pathways and receptors)

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Figure C-7 Visualisation of the Conceptual Site Model at the Bushfire Zone (Exposure pathways and receptors)

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Figure C-8 Visualisation of the Conceptual Site Model at the Hanns Inlet Sediment and Pore Water (Exposure pathways and receptors)

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Figure C-9 Visualisation of the Conceptual Site Model at the storm-water drains (Exposure pathways and receptors)

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APPENDIX D Options analysis criteria

This Appendix sets out the criteria for the detailed options analysis.

Cost / effectiveness / impact analysis

1 Cost range estimate

Estimate a cost range for implementation of the option, accompanied by an explanation of the basis of that estimate.

The cost ranges below have overlapping values: this is to avoid a scenario where a borderline cost may distort the analysis. Where a cost estimate falls into an overlapping range, but effectiveness of the option in 1.2 is assessed as ‘high’, use the lower cost range to adjust the margin of error in favour of the ‘effectiveness’ criterion.

Category 1 PWC approval required above $15 million.13

> $13,000,000

Category 2 Medium works notification to PWC required above $2 million

> $1,500,000 < $15,000,000

Category 3 Project actions > $450,000 < $2,000,000

Category 4 Community level actions14 < $500,000

Cost ranges should include direct, indirect, recurrent costs and the costs of mitigating any secondary risks identified in 2.5 below.

Where there will be a need for ongoing operations, management, maintenance and monitoring beyond the Primary Implementation Period, a separate risk should be identified, and a separate options analysis applied.

2 Effectiveness rating

Assign an effectiveness rating in accordance with the following criteria:

High The option is projected to meet all its objectives ormeet a ‘best available’ standard

High with supplementary option

The option, together with a supplementary option, is projected to meet all its objectives or meet a ‘best available’ standard

Medium The option is projected to make significant progress towards meeting its objectives.

Medium with supplementary option

The option, together with a supplementary option, is projected to make significant progress towards meeting its objectives

Low The option cannot reliably be projected to make significant progress towards meeting its objectives or may only do so in a timeframe that isnot aligned with effective management of the

13 http://www.defence.gov.au/estatemanagement/governance/Committees/pwc/Default.asp 14 Accommodates a range of community level response actions such as arranging alternative grazing for impacted agricultural businesses or providing fencing. The value of community-level actions may also exceed $500,000.

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identified risk.

3 Implementation period / timeframe

Designate an indicative timeframe for implementation:


Short term: Medium term:


Long term:

Where an action extends across both the primary and extended implementation period, both should be designated. Different procurement actions may apply.

4 Potential impacts

List any potential environmental and socio-economic impacts (positive and negative).

Negative impacts should be further analysed and addressed in section 10 below.

5 Estimated net environmental benefit

Whether the impacted environment as a whole would experience a net benefit. Rate as negative / marginal / moderate / significant

Risk-based analysis

6 Proportion of action to risk

Assess the scale (timing/implementation logistics/impact on Defence capability) and cost of the action in comparison to the likelihood and scale of the risk.

7 Best-practice status

Consider whether there is a recognised ‘best-practice’ standard available for the category of the proposed solution and whether the solution meets a relevant standard.

8 Verification status

Where an action involves a remediation technology, provide information on the verification status.

9 Technology assessment

Where an option involves a remediation technology:

infrastructure and energy requirements ability to construct and operating technology reliability of technology ability to monitor effectiveness ability to obtain any necessary approvals availability of services and materials

10 Risks and mitigation

List primary, secondary15 and residual16 risks of implementation and associated mitigation options, such as:

potential environmental impacts, including PFAS transference, cross-contamination, and remobilisation; and presence of contaminants other than PFAS

the availability of treatment/storage management options to manage waste streams

15 Secondary risks are risks that emerge from implementation of a risk management response 16 Residual risks comprise that component of the identified risk that is not addressed by the option.

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impact on existing infrastructure (including bores) potential social and economic impacts (eg land use or

employment.)

Specify whether mitigation options form a part the same option or whether they are developed separately (provide option identification number).

11 Key Dependencies

List any key dependencies, including the implementation of any other options, and any external factors.

Defence implications

12 Defence capability

The extent to which an aspect of Defence capability will be impacted by the process or outcome of implementation of the option and the availability and cost of alternatives (consultations with Defence)

13 Project fit Whether the project outcomes complement the outcomes of response management actions for the same or other sites (consultations with Defence)

14 Scalability Whether the outcomes of the project can be scaled up or down to address similar needs in the same or other Bases.

Stakeholder impacts, views and consents

15 Jurisdictional regulator/s

List jurisdictional authorisations required to implement the option. Note the views of any relevant jurisdictional regulator

16 Owner / occupier consents and views

List any owner / occupier consents required to implement the option.

Note the views of any relevant landowner or occupier.

17 Community Defence’s understanding of the views of the impacted community.

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APPENDIX E Options listing and analysis

This Appendix provides the analysis of the management options identified as available to address the range of risks identified in the DSI and risk assessments.

Options Assessment

The following sets out the analysis of the identified options relative to the Defence required criteria set out in Appendix D.

1.1.1 OPT-001a Immobilisation of PFAS in soils

No # OPT-001a

Title (functional) Immobilisation of PFAS in soils

Description Addition of a binding agent to the soil profile to immobilise/stabilise PFAS contained within the soil matrix and prevent leaching of PFAS to surface or groundwater.

Objective To immobilise the PFAS source and associated contaminant load within the soil profile. Potential intervals for immobilisation for site source areas follow:

Fire Ground: 2 to 6 m of PFAS-impacted soil beneath the Fire Ground (including the lagoon) with approximately 4 kg of total PFAS. Note that it is likely that the most PFAS-impacted soil is beneath the lagoon at the Fire Ground, which could not be evaluated as part of the DSI but could be evaluated as part of decommissioning of the Fire Ground.

Wetlands straddling South Creek: Up to 2 m of PFAS-impacted wetlands sediments with approximately 9 kg of total PFAS.

Ornamental Lake: 1 to 2 m thickness of PFAS-impacted sediment and soil beneath the lake and approximately 100 m by 20 m by 1 m deep layer of PFAS-impacted soil north of the Ornamental Lake with approximately 0.4 kg of total PFAS.

Lagoons at the former STP: 3 to 6 m of PFAS-impacted sediment and soil beneath the lake with likely lower total PFAS compared to the Fire Ground.

Closed Rifle Range Road landfill: Waste and cap thicknesses not documented, but likely to be between 2 and 5 m. Weight of total PFAS is likely to be much compared to the weight of total PFAS at the Fire Ground. Weight of total PFAS is likely to be much less compared to the weight of total PFAS at the Fire Ground.

Closed outdoor saltwater pool landfill: Waste and cap thicknesses not documented, but likely to be between 2 and 4 m. Weight of total PFAS is likely to be much less compared to the weight of total PFAS at the Fire Ground.

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Sullage pit landfill and spoil: Landfilled waste thicknesses not documented, but likely to be between 1 and 3 m beneath 1 to 2 m of spoil from the 2008 channel reinstatement program. Weight of total PFAS is likely to be much less compared to the weight of total PFAS at the Fire Ground.

How this objective contributes to managing the identified risk

This option directly breaks the linkage between the source of PFAS in soil and the migration pathway by preventing the leaching and run-off of PFAS from soils to surface and groundwater.

Management option directly address the following risks:

R001 and R002 (primary)

The extent to which this option is expected to meet the objective

Use of binding agents in soils have been proven to be effective in immobilising/stabilising PFAS and eliminating the potential to generate leachate containing PFAS.

Validation sampling will be required to confirm that PFAS concentrations in soil leachates have been reduced to the adequate concentrations.

Whether the option addresses

source, pathway receptor, and/or extended

implementation period requirements

This management option removes the pathway component by making the PFAS within the soil immobile and preventing it from being leached and migrating from the source area.

The PFAS will remain in-situ within the soil in a stable form indefinitely.

Supplementary / complementary options

During management of soil at the Fire Ground, works should also incorporate treatment of PFAS-impacted sludge in the oil-water separator that drains into the Fire Ground lagoon, and which contains high concentration of PFAS.



Category 3 Project actions > $450,000 < $2,000,000 per source area


High The option is projected to meet all its objectives or meet a ‘best available’ standard



Medium term:

86 2 October 2018

4 Potential impacts Environmental and socio-economic impacts

Positive o Secondary source area immobilised/stabilised o In situ treatment available o No operation and maintenance costs

Negative o PFAS remains within the soil (in a stable form, non-

leachable, non-bioavailable) o Additional treatment or disposal may be required if area is

to be subject to future development


Significant as this option will control one of the main source area of PFAS on site, reducing downstream exposures and impacts to human health and the environment.

Risk-based analysis


Estimated lead time of 3-6 months to engage a contractor and to run bench scale testing to establish the dosing requirement specific for the site conditions.

Works would occur after commissioning of the new fire training area, so will not affect Defence capabilities.


Under the management options currently available under the NEMP, this option would be considered best practice until treatment and containment facilities become available.


Technology used to successfully treat PFAS contaminated soils in Australia.


Infrastructure and energy requirements

remediation contractor to supply and use specialised plant to apply treatment to soil

No energy or maintenance requirement following application of remedial treatment

Reliability of technology

test shown to reduce the detectable concentration of leachable PFAS by approximately 99%

bench tests will be conducted to evaluate leachability of PFAS from treated soils

ability to monitor effectiveness

Soil leachate analysis will confirm effectiveness within 7 days of applying treatment

ability to obtain any necessary approvals

No external regulatory approval required

availability of services and materials

Technology readily available with remediation contractors experienced with use on remediation projects in Australia


Soils to be identified as containing stabilised concentrations of PFAS within the soil and are not suitable for reuse on site and to remain undisturbed without further remediation treatment options.

87 2 October 2018

11 Key Dependencies

Coordination with decommissioning of the Fire Ground as part of base redevelopment.



No Defence capabilities affected by implementation of the option

13 Project fit At the Fire Ground these remediation works are scheduled to be undertaken as part of the Base redevelopment program.

14 Scalability Remedial option valid for use on treatment of stockpiles to major earthworks.

Remedial works can be completed on soil in-situ or ex-situ.

Suitable on all soil types. Site specific assessment of soil type are required to refine dosing requirements



No regulatory approvals required


HMAS Cerberus

17 Community No community impacts identified.

88 2 October 2018

1.1.2 OPT-001b Capping of PFAS-impacted media

No # OPT-001b

Title (functional) Capping of PFAS-impacted soils at site source areas.

Description Construction of a physical or chemical capping layer to the surface soil profile to reduce surface water ingress and reduce leaching of PFAS-impacted soils (such as beneath the Fire Ground lagoon) to groundwater.

Cap will also protect site users and maintenance workers from direct contact risks provided the cap remains intact.









This option directly breaks the linkage between the source of PFAS in soil or sludge and the migration pathway by preventing the leaching and run-off of PFAS from soils or sludges to surface and groundwater.


89 2 October 2018



Physical or chemical capping layers have been proven to remove the pathway for exposure to a contaminant source. The PFAS will remain in situ, with no pathway to move from the source area.




This management option removes the pathway component by making the PFAS within the soil immobile and preventing it from being leached and migrating from the source area.

The PFAS source will remain in-situ within the soil while the capping layer remains intact.





Category 4 Community level actions < $500,000 per source area





Medium term:


Positive o Secondary source area present from releasing PFAS from

soil profile o In situ treatment of impacted soils beneath the cap

available o Minimal operation and maintenance costs (maintain

vegetation on the cap) Negative

o PFAS contamination remains within the soil with no pathway to receptors (while the cap remains intact)

o Additional treatment or disposal may be required if area is to be subject to future development


Significant as this option will control the main source area of PFAS on site, reducing downstream exposures and impacts to human health and the environment.

90 2 October 2018

Risk-based analysis



Works will be completed after commissioning of the new Fire Training Area and will be outside of main operational area so will not affect Defence capabilities.




Technology used to successfully manage PFAS contaminated soils in Australia.



Minimal energy on maintenance requirement following application of remedial treatment (maintenance of cap vegetation)


Capping/isolation of contaminants is a proven methodology to isolate contaminants, leaving them in situ, but removing pathways to receptors


Groundwater monitoring in the area will enable measurement of effectiveness






PFAS remains in the soil in a mobile form, isolated while the capping layer remains intact.

The area to be managed must remain undisturbed without further remediation treatment options.

11 Key Dependencies






14 Scalability Remedial works can be completed on a wide range of areas. However, capping of large areas could pose a challenge with regards to natural materials, such as clays, for the capping system.

91 2 October 2018





HMAS Cerberus


92 2 October 2018

1.1.3 OPT-001c Excavation of PFAS-impacted soils, storage of material and replacement with clean fill

No # OPT-001c

Title (functional) Excavation and storage of material and replacement with clean fill

Description Excavation of PFAS impacted soil and transport and storage in on-site designated containment cell.









This option directly breaks the linkage between the source of PFAS in soil or sludge and the migration pathway by removing PFAS-impacted soils from a secondary source area.



The extent to which this option is expected to meet the

Removal of PFAS impacted soil from the Fire Ground to a containment cell on site will prevent the migration of PFAS

93 2 October 2018

objective to the environment and off site




This management option removes the pathway component by preventing the mobilisation of PFAS-impacted soils by erosion and the formation of PFAS leachate that could migrate from the source area.

The PFAS source will remain on site within a containment cell requiring future management or treatment.










Medium term:


Positive o Secondary source area removed and contained o No operation and minor maintenance costs (maintenance

of cap vegetation) Negative

o PFAS contamination remains within the soil (but contained such that non-leachable, non-bioavailable)

o Additional treatment or disposal may be required to reuse stored PFAS-impacted soil on site in the containment cell



Risk-based analysis








94 2 October 2018





Excavation and storage of contaminants in a designed designated storage facility is a proven methodology to isolate contaminants, by removing pathways to receptors


Validation of excavation at the source will confirm excavation effectiveness

Surface water and groundwater monitoring in the containment cell area will enable measurement of effectiveness the cell design







11 Key Dependencies













HMAS Cerberus


95 2 October 2018

1.1.4 OPT-001d Engineering control - Excavation of PFAS in soils at primary source areas and either on or off-site treatment (destruction)

No # OPT-001d

Title (functional) Excavation and destruction of PFAS-impacted soils

Description Excavation of PFAS-impacted soils with either on- or off-Site treatment (destruction)

Objective To remove the PFAS source and associated contaminant load within the soil profile. Potential intervals for excavation and removal for site source areas follow:








This option directly breaks the linkage between the source of PFAS in soil or sludge and the migration pathway by removing PFAS-impacted soils from a secondary source area.



The extent to which this option is expected to meet the

Removal of PFAS impacted soil from the Fire Ground to a containment cell on site will prevent the migration of PFAS

96 2 October 2018

objective to the environment and off site




This management option removes the pathway component by preventing the mobilisation of PFAS-impacted soils by erosion and the formation of PFAS leachate that could migrate from the source area.

The PFAS source will remain on site within a containment cell requiring future management or treatment.










Medium term:


Positive o Secondary source area removed and contained o No operation and minor maintenance costs (maintenance

of cap vegetation) Negative

o PFAS contamination remains within the soil (but contained such that non-leachable, non-bioavailable)

o Additional treatment or disposal may be required to reuse stored PFAS-impacted soil on site in the containment cell



Risk-based analysis








97 2 October 2018





Excavation and storage of contaminants in a designed designated storage facility is a proven methodology to isolate contaminants, by removing pathways to receptors


Validation of excavation at the source will confirm excavation effectiveness

Surface water and groundwater monitoring in the containment cell area will enable measurement of effectiveness the cell design







11 Key Dependencies













HMAS Cerberus


98 2 October 2018

OPT-002 Treatment of surface water at drain discharge points

No # OPT-002

Title (functional) Treatment of surface water at drain discharge points

Description Treatment system to target surface water discharge into Base creeks and drains or into Hanns Inlet.

Management option to have both storage and treatment components as there is no current proven technology available to passively treat flowing surface water in situ.

Surface water treatment system to treat PFAS in situ, with an operational efficiency targeting periods of low flow.

The storage component will allow a finite amount of storage to capture the “first flush” of surface water generated during the initial period of a major rain event. Once the storage capacity has been reached the remaining flood waters, will be directly discharged to surface water bodies.

Objective Prevent release of PFAS-impacted surface water from the site into Hanns Inlet.

Treatment of PFA- impacted water during low-flow periods and capture (and treatment) of the first flush of surface water generated during the rainfall event and discharging from stormwater drains ultimately into Hanns Inlet.


The primary pathway for PFAS from the site is via surface run-off either, the major PFAS discharge point into Hanss Inlet.


R001

Management option indirectly address the following risks:

R001


Pilot testing is required to investigation the feasibility of this application of proven technology.




The option addresses the migration pathway between the sources on site and the sensitive receptors downstream in site tidal creeks and Hanns Inlet.


At the time of writing this option had not been confirmed as a feasible commercial option, further research is required.

The ongoing monitoring plan would be to assess the effectiveness of the treatment system.

Supplementing this with OPT-001 (immobilisation of PFAS in soil) to assist in reducing concentrations of PFAS that

99 2 October 2018

enter the receiving environment.



Category 4 Community level actions < $500,000


High with supplementary option

The option, together with a supplementary option, is projected to meet all its objectives or meet a ‘best available’ standard



Medium term:

Extended implementation period (ongoing operation)

Long term

4 Potential impacts

Environmental and socio-economic impacts

Positive o Primary migration pathways to be treated/managed

Negative o Ongoing operational/maintenance costs


Significant as it breaks a major source-pathway linkage and will reduce the amount of PFAS in migration pathways.

Risk-based analysis


Estimated lead time of 12 months to investigate options and conduct a pilot study.

Works outside of the operational area and will not affect Defence capabilities



Future detailed design and pilot testing required to prove commercial feasibility of the management methodology.


Infrastructure and energy requirements First flush capture system (dam or tanks required) along with water

treatment facility and ongoing electricity requirements. Ability to construct and operating technology

Readily available technology, previously constructed. Reliability of technology

Proven reliability Ability to monitor effectiveness

Treatment of water readily monitored to assess effectiveness. Ability to obtain any necessary approvals

None required Availability of services and materials

Readily available, potential for some minor lead in/setup times.


Area target for management are points of the stormwater piping network that discharge into Hanns Inlet or adjacent tidal creeks and drains.

Design of remedial system will need to consider ephemeral flows in the stormwater system.

100 2 October 2018

11 Key Dependencies

Pilot testing of a suitable surface water treatment technology.



Not anticipated to affect Defence capability.

13 Project fit Complements redevelopment works that includes renovation of the stormwater system, which might include capping and abandonment of the portions of the existing network.

14 Scalability Treatment will focus on first-flush discharges rather than peak flows.



Discharge limits for surface water to be confirmed in consultation with the EPA Victoria, but likely to be non-detect of PFAS.


HMAS Cerberus

17 Community Treatment of surface water discharging from the site boundaries will have a positive impact on water quality in Hanns Inlet.

101 2 October 2018

1.1.5 OPT-003 Installation of a treatment system within PFAS-impacted creeks

No # OPT-003

Title (functional) Installation of a treatment system, such as a permeable reactive barrier, within South Creek at the Rifle Range Road bridge where PFAS-impacted surface water discharges to Hanns Inlet.

Description Installation of a treatment system, such as a permeable reactive barrier, within South Creek to passively remove PFAS from surface water discharging to Hanns Inlet during the out-going tide.

Recommended to be installed at the bridge over South Creek on Rifle Range Road.

Objective Reduce the flux load of PFAS in surface water discharging to Hanns Inlet.


Surface water is major pathway for PFAS to migrate into Hanns Inlet. This option would reduce the flux loading of PFAS migrating along this pathway.


R001


Treatment systems, such as permeable reactive barriers using granulated activated carbon, have been proven to be effective in capturing PFAS and prevent further migration in surface water.

Once PFAS adheres to the permeable reactive barrier it will be bound within the a medium, such as activated carbon.




The option addresses the migration pathway between the sources on site and the sensitive receptors located downstream in Hanns Inlet. This option effectively cuts the pathway via surface water between site sources of PFAS at the Fire Ground and South Creek wetlands and receptors in Hanns Inlet.


This option should be supplemented with Option OPT-001a through OPT-001c implemented at the Fire Ground to reduce source concentrations of PFAS that enter the receiving environment.

The ongoing monitoring plan would be used to monitor and assess the effectiveness of the system.





High with supplementary option The option, together with a supplementary option, is projected to meet all its objectives or meet a

102 2 October 2018

‘best available’ standard

This option will prevent migration of PFAS down gradient of the treatment system.

The treatment system would not be installed in all site creeks and will be concentrated in the areas of concern only.



Medium term:

4 Potential impacts


Positive o Surface water migration pathway removed o In situ treatment o Minimal waste generated if in-situ regeneration of

treatment substrate occurs. o Minimal operation & maintenance costs

Negative o Contamination remains (in a stable form) sorbed to the

treatment system medium within the creek


Moderate

Impact of treatment system would be localised to the South Creek area, which is a disturbed area.

Risk-based analysis


Estimated lead time of 3-6 months to engage a contractor and to run bench scale testing to establish the optimal design for the treatment system, which will focus on treating surface water discharging during the end of the out-going tide.


Under the management options currently available under the NEMP, this option would be considered best practice.


Technology used to successfully manage PFAS contaminated waters in Australia.



Minimal energy for maintenance (regeneration of the treatment medium)


PFAS removal using activated carbon or resins is a proven methodology to remove contaminants from water

Ability to monitor effectiveness

Monitoring of surface water discharging from the treatment system will enable measurement of effectiveness

Ability to obtain any necessary approvals


Availability of services and materials

Technology readily available with remediation contractors experienced with use on remediation projects in Australia.

103 2 October 2018


Any co-contaminants (e.g., hydrocarbons) in the creek water will reduce the effectiveness of the treatment system. Ongoing monitoring plan to include monitoring for organic contaminants to assess any additional contaminant load in the creek water up stream of the treatment system.

Source of PFAS remains but remediation technology removes the pathway.

11 Key Dependencies

None anticipated since remediation of the South Creek wetlands is not part of the redevelopment works.




13 Project fit Approach is consistent to the HMAS Cerberus of containment, OPT-001.

This technology is likely applicable to a range of Defence sites with similar Conceptual Site Model conditions

14 Scalability Technology suitable for use on a small scale for protection of a specific flow system.

Technology can be implement on a large-scale site down to a single location or a sequence of multiple treatment systems in cases where contaminant load is high.



Defence.


HMAS Cerberus


104 2 October 2018

1.1.6 OPT-004a Administrative Control - No groundwater wells to be installed within the management area

No # OPT-005a

Title (functional) No groundwater bores to be installed within the management area for purposes of drinking /potable water, stock watering or irrigation.

Description No licences to be issued by the Southern Rural Water for the installation of new groundwater bores within the management area, exclusions apply for groundwater monitoring bores or re-injection bores.

Objective Prevent Base from accessing PFAS-impacted groundwater for drinking/potable purposes.


PFAS-impacted groundwater should not be used for drinking/potable water. Preventing the installation of new groundwater wells in PFAS-impacted groundwater will remove the risk to human health from consumption of groundwater.


R001 and R002


This option will be effective when implemented and is a low cost, administrative control. It requires input and cooperation with the Base and Victorian Government.




This option removes the migration pathway from groundwater to human consumption and removes the exposure risk to human health. In isolation, this option would require an extended implementation period.


This option should be supplemented by Options OPT-001a to OPT-001c to assist in reducing concentrations of PFAS that enter the receiving environment.

Option should be reassessed based on outcomes of PFAS ongoing monitoring plan





Option will prevent the ingestion of PFAS-impacted water, however will not treat or remove the source of PFAS

105 2 October 2018



Short term:

4 Potential impacts


positive o Prevention of consumption of PFAS-impacted

groundwater Negative

o Restriction placed on Base preventing access and use of groundwater


No net environmental benefit from this option.

Risk-based analysis


During the DSI noon-Base human consumers of groundwater were identified through the water use survey. It is understood that all neighbouring residential properties are located hydraulically up- or cross-gradient to Base sources of PFAS. Most residences are connected to town potable water supplies. The groundwater was not of a suitable quality for human consumption due to elevated salinity levels.

Option is not likely to change current practices regarding the unlikely consumption and use of groundwater.


This option is short term management option which will be superseded by the effective implementation of management options which aim to remove PFAS from the environment, but require a longer implementation period.


Prevention of ingestion of groundwater with known concentrations of PFAS will prevent the bioaccumulation of PFAS in potentially affected human receptors.


This is an administrative control on property controlled by Defence.


Potential social and reputational risks for Defence. Mitigation measures include ongoing community engagement, communication of other remediation/management measures being implemented and the temporary nature of the administrative controls (Options OPT006a-f)

11 Key Dependencies

The timeframes required to cease this option depend on the implementation of options listed which treat and remove the sources of PFAS migrating off HMAS Cerberus




13 Project fit This action does not interfere with Base redevelopment or operations.

14 Scalability Administrative control can be scaled depending on success of other management options.

106 2 October 2018



Southern Rural Water EPA Victoria


Owner/occupier consent not required.

17 Community Community concerns are unlikely to be raised about impact to property prices and resale value.

107 2 October 2018

1.1.7 OPT-004b Administrative Control - Advise Base to not use PFAS-impacted water to irrigate land

No # OPT-005b

Title (functional) Advise Base to not use PFAS impacted water to irrigate produce.

Description Sports fields and landscaped areas should not be irrigated with PFAS-impacted Class C recycled water. Base should be advised against using PFAS-impacted Class C recycled water for irrigation and should use rainwater or mains water as an alternative.

Objective Eliminate runoff of and recharge by PFAS-impacted Class C recycled water used to irrigate the sports fields at the Base.


Removing the secondary source of PFAS (Class C recycled water) that exposes receptors in Hanns Inlet and the Ornamental Lake via groundwater and surface-water pathways. for accumulation in produce irrigated by PFAS impacted surface water will reduce PFAS concentrations in produce, thereby reducing the risk to human health.


R001 and R002


This option will be effective when implemented and is a low cost, source-removal remediation measure., however it requires input and cooperation with residents.




This option removes a secondary source of PFAS (Class C recycled water) that was impacting Base groundwater and surface water discharging into Hanns Inlet and removes the exposure risk to ecosystems in Hanns Inlet.


This option should be supplemented with Options OPT-001a through OPT-004 to assist in reducing concentrations of PFAS that enter the receiving environment.





Option will reduce the discharge of PFAS-impacted groundwater and surface water into Hanns Inlet. Will reduce the loading of PFAS in soils that had been irrigated with Class C recycled water.



Short term:

108 2 October 2018

4 Potential impacts


Positive o Reduction in PFAS in runoff from irrigation water applied

to the sports fields. o Reduction in PFAS sources at the sports fields, which

are a secondary source of PFAS that leaches into groundwater.

Negative o Ongoing monitoring of surface water and groundwater. o Financial implications of relying on rain water or mains

water to replace Class C recycled water supply.


No net environmental benefit from this option as the benefit of removing a secondary source of PFAS was diminished due to the use of mains water instead of recycled water.

Risk-based analysis


Cessation of irrigation with Class C recycled water had already occurred in January 2018. Implementation of using mains water rather than recycled water has proceeded smoothly. Hence, impact on Defence capability is not anticipated. Implementing this action is proportional much higher than the risk mitigated.


This option can be implemented in the short but removal of secondary PFAS from the environment will require a longer implementation period.


Reducing concentrations of PFAS in groundwater collected from wells located between the sports fields and Hanns Inlet would indicate that the flux of PFAS leaching from the secondary source beneath the sports fields is reducing.


This is an engineering control that replaces Class C recycled water with mains water, which is a proven supply for irrigation at the Base.


Social and reputational risks for Defence are low. .

11 Key Dependencies

The timeframes required to cease this option depend on the implementation of options listed which treat and remove the source PFAS migrating off HMAS Cerberus




13 Project fit Implementation of this action will not affect Base operations or redevelopment.




EPA Victoria

109 2 October 2018


Base-controlled property

17 Community Community concerns unlikely to be raised about impact to property prices and resale value.

110 2 October 2018

1.1.9 OPT-004c Administrative Control - Maintain no trespassing signs

No # OPT-005c

Title (functional) Maintain no trespassing signs regarding no trespassing on the Base.

Description Maintain no trespassing signs regarding not trespassing on the base, which would preclude fishing in Hanns Inlet.

Objective Reduce the risk to on site workers and general public from exposure to surface waters in Hanns Inlet. Also helps to mitigate the risk of recreational fishing and consumption of edible fish (although noting that Tier 1 screening level risk criteria were not found to be exceeded for this exposure pathway).


Management option directly address the exposure risk to human health (on-site workers and others).


This option reduces the risk to sensitive receptors,




This option removes the sensitive receptor (e.g., fishers).


This option should be carried out in conjunction with Options R001 and R002, which aim to reduce the quantity of PFAS leaving the base and entering the surrounding surface water.





Option will cut the ingestion pathway of PFAS-impacted biota (fish); however, will not treat or remove the source of PFAS



Short term:

4 Potential impacts


Positive o Prevention of consumption of PFAS-impacted biota (fish)

Negative o Negative socio-economic impact on local community and

commercial fishing-tour industry o Ongoing community and stakeholder engagement

requirements

111 2 October 2018


No net environmental benefit outcome from this option

Risk-based analysis


This option has already been implemented, but needs on-going maintenance, which is covered by the current security provider. Hence, this option would not impact on Defence capability. This option is cost effective with regards to cutting the pathway by effectively removing the receptor from exposure through eating fish caught in Hanns Inlet.


This option reflects the permanent ban on public access for fishing and recreation in naval waters in Hanns Inlet and Western Port Bay.


Prevention of consumption of biota aquatic produce with known concentrations of PFAS (but below screening levels) will prevent the bioaccumulation of PFAS in potentially affected humans.


NA This is an administrative control by Defence and landholders.


Trespassing continues in spite of well-maintained fences and warning signs. Security patrols the area periodically, but the frequency could be increased, particularly during favourable fishing times.

11 Key Dependencies

Relies upon regular inspection of the fences and signs along the eastern boundary




13 Project fit Implementation of this option would not interfere with general Base operations or Base redevelopment.




EPA Victoria Fisheries Victoria


Owner/occupier consent not required as this option relates only to Base property.

17 Community Community concerns may be raised about impact to recreational and commercial fishing tours, but the fishing ban within naval waters is likely to improve the stocks of fish as Hanns Inlet is a refuge from fishing.

112 2 October 2018

1.1.10 OPT-004d Administrative Control – Require all on-site works to have PFAS specific EHSW protocols and procedures

No # OPT-005d

Title (functional) All on-site works to have PFAS specific EHSW protocols and procedures

Description Recommendation to formally require all on-site workers undertaking intrusive construction or maintenance works to have adequate ESHW protocols and procedures in place in regards to potential exposure to PFAS.

Objective To minimise risk of exposure to PFAS impacted media to persons involved in intrusive construction or maintenance works


Management option directly address the exposure risk on-site workers undertaking construction or maintenance works within areas where PFAS impacted media are present.


This option reduces the risk to human receptors,




This option targets the receptor.


This option should be carried out in conjunction with other proposed administrative options.





Option will reinforce effectiveness of other proposed administrative controls



Short term:

4 Potential impacts


Positive - option will reinforce effectiveness of other proposed administrative controls.

o Negative – Nil.



113 2 October 2018

Risk-based analysis


This option has already been implemented (in part) through the requirement of contractor safe works / EHSW protocols but this option is in direct response to the known presence of PFAS impacted media within the Base.,


This is should be a mandatory requirement to comply with relevant Work, Health Safety legislation and regulation..


Nil verification required other than competent review of works EHSW protocols which is a function generally performed by the relevant Base REO/RESO.


NA This is an administrative control by Defence.


Nil.

11 Key Dependencies

Relies upon competent review of works EHSW protocols which is a function generally performed by the relevant Base REO/RESO.








Defence.



17 Community Nil. .

114 2 October 2018

1.1.11 OPT-004e Administrative Control – Base to maintain adequate records of PFAS impacted areas

No # OPT-005e

Title (functional) Base to maintain adequate records of PFAS impacted areas

Description Recommendation to maintain adequate records of PFAS impacted areas within Base. .

Objective To provide and maintain current records identifying PFAS impacted areas and media within the Base for communication to person(s) who may need to undertake intrusive works within the Base e.g. construction and/or maintenance and or emergency response workers.


Management option directly address the exposure risk on-site workers undertaking construction or maintenance works within areas where PFAS impacted media are present.


This option reduces the risk to human receptors,




This option targets the receptor.


This option should be carried out in conjunction with other proposed administrative options.





Option will reinforce effectiveness of other administrative controls.



Short term:

4 Potential impacts


Positive option will reinforce effectiveness of other proposed administrative controls.

Negative – Nil.



115 2 October 2018

Risk-based analysis


This option has already been implemented (in part) through the use of the Base CSR.


This is already a mandatory Defence requirement for other contaminants within the Defence estate.


Nil.


NA This is an administrative control by Defence.


Nil.

11 Key Dependencies

Relies upon Base and REO/RESO being able to access PFAS DSI And PMAP.








Defence.



17 Community Nil.

116 2 October 2018

Comparative Assessment

Two main elevated risks were identified by the DSI. Intrusive / maintenance workers were at risk of unacceptable PFAS exposure during intrusive activities, such as excavating PFAS impacted soils or pumping of PFAS-impacted groundwater for construction dewatering. Ecological receptors (terrestrial and aquatic on- and off-site) were identified as being at risk of unacceptable PFAS exposure associated with site sources of PFAS. Options to manage these risks are presented in Appendix E. Using the criteria set out in Section 3.5, a ranking was undertaken of each option for site sources of PFAS, which is presented in Table E-1. The ranking used a simple numerical rating of between 1 and 5 (5 as most desirable for that criterion). For each source area posing an elevated risk the total for relevant options were used to evaluate the overall ranking against the other options.

Consistent with Defence instructions the ‘Do Nothing’ option for each source area was not evaluated.

117 2 October 2018

Table E-1 Comparative assessment of management options for each source area

Remediation Option \ Criteria

1. C

ost

2. E

ffec

tive

nes

s

3. Im

ple

men

tati

on

per

iod

/ t

imef

ram

e

4. P

ote

nti

al im

pac

ts

5. E

stim

ated

net

en

viro

nm

enta

l ben

efit

6. P

rop

ort

ion

of

acti

on

to

ri

sk

7. B

est-

pra

ctic

e st

atu

s

8. V

erif

icat

ion

sta

tus

9. T

ech

no

log

y as

sess

men

t

10 R

isks

an

d m

itig

atio

n

11. K

ey d

epen

den

cies

12. D

efen

ce c

apab

ility

13. P

roje

ct f

it

14. S

cala

bili

ty

15. J

uri

sdic

tio

nal

re

gu

lato

r/s

16. O

wn

er /

occ

up

ier

con

sen

ts a

nd

vie

ws

17. C

om

mu

nit

y

Ran

kin

g T

ota

l

Engineering and Treatment Controls

Fire Ground

Do nothing

Soil immobilisation 2 5 3 5 5 4 4 4 4 4 2 5 4 5 5 5 5 71

Capping 3 4 3 3 4 4 4 4 4 4 2 5 4 4 5 5 5 67

Excavation & containment 2 5 3 4 5 4 4 4 4 4 2 5 4 5 5 5 5 70

South Creek Wetlands

Do nothing

Soil stabilisation 2 4 2 3 2 3 4 4 4 4 2 5 2 5 3 5 5 59

Capping 3 3 2 2 1 1 4 4 4 4 2 5 2 4 3 5 5 54


Former STP Lagoons

Do nothing 1


Capping 3 3 3 3 2 3 4 4 4 4 2 5 4 4 5 5 5 63


Ornamental Lake

Do nothing


Capping 3 3 3 3 3 3 4 4 4 4 2 5 4 4 5 5 5 64


118 2 October 2018


1. C

ost

2. E

ffec

tive

nes

s

3. Im

ple

men

tati

on

per

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Sullage Pit

Do nothing


Capping 3 2 3 2 2 2 4 4 4 4 2 5 4 4 5 5 5 60


Closed Rifle Range Road Landfill

Do nothing


Capping 5 2 3 2 2 3 4 4 4 4 2 5 4 4 5 5 5 63


Drain Discharge Points

Do nothing

Surface water treatment and discharge 5 4 4 5 4 4 4 4 4 4 2 5 4 4 5 5 5 72

South Creek Discharge

Do nothing

Surface water treatment and discharge 5 4 4 5 4 4 4 4 4 4 2 5 4 4 5 5 5 72

119 2 October 2018


1. C

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Administrative Controls

Administrative control: No on-site groundwater extraction

Do nothing

Implement ban on groundwater extraction 5 417 5 4 4 4 4 5 0 5 3 5 5 5 5 5 5 64

Administrative control: Use of Class C recycled water for irrigation

Do nothing

Cease using Class C recycled water 5 418 5 4 4 4 4 5 0 5 3 5 5 5 5 5 5 64

Administrative control: No trespassing signs

Do nothing

Maintain no trespassing signs 4 4 5 3 219 5 3 5 0 4 3 5 5 5 5 5 5 66

Administrative control: Require all on-site works to have PFAS specific EHSW protocols and procedures

Do nothing

All on-site works to have PFAS specific EHSW protocols and procedures 5 4 5 4 4 4 4 5 0 5 3 5 5 5 5 5 5 73

Administrative control: Base to maintain adequate records of PFAS impacted areas

Do nothing

Base to maintain adequate records of PFAS impacted areas 5 4 5 4 4 4 4 5 0 5 3 5 5 5 5 5 5 73

17 Use of rainwater or mains water would still cause local mounding of groundwater beneath the sports fields, which would continue to leach PFAS from soils and drive PFAS-impacted groundwater towards Hanns Inlet. However, runoff from irrigated sports fields would be removed as a source of PFAS entering Hanns Inlet. 18 Use of rainwater or mains water would still cause local mounding of groundwater beneath the sports fields, which would continue to leach PFAS from soils and drive PFAS-impacted groundwater towards Hanns Inlet. However, runoff from irrigated sports fields would be removed as a source of PFAS entering Hanns Inlet. 19 Effective ban on fishing resulting from enforcement of no trespassing for fishing in Hanns Inlet would help maintain the fish stocks in Hanns Inlet, but overall a marginal net benefit.

120 2 October 2018

APPENDIX F Ongoing monitoring plan

HMAS Cerberus PFAS DSI Ongoing Monitoring Plan Department of Defence Reference: 256337

Revision: 2

Date 12 September 2018

Project 256337 File 0066_HMAS_Cerberus_OMP-Rev2-final.docx 12/09/2018 Revision 2

Document control record Document prepared by:

Aurecon Australasia Pty Ltd ABN 54 005 139 873 Aurecon Centre Level 8, 850 Collins Street Docklands, Melbourne VIC 3008 PO Box 23061 Docklands VIC 8012 Australia T F E W

+61 3 9975 3000 +61 3 9975 3444 [email protected] aurecongroup.com

A person using Aurecon documents or data accepts the risk of: a) Using the documents or data in electronic form without requesting and checking them for accuracy against the original hard copy

version. b) Using the documents or data for any purpose not agreed to in writing by Aurecon.

Document control

Report title Ongoing Monitoring Plan

Project number 256337

File path PW_Filepath

Client Client

Client contact Client Contact Client reference Reference

Rev Date Revision details/status Author Reviewer Verifier (if required)

Approver

R0 22 July 2018 Issued to Auditor and Defence for comment

MJ ST ST

R1 8 August 2018 Incorporated Auditor and Defence comments

MJ ST ST

R1 12 September 2018 Incorporated Auditor and Defence comments

MJ ST ST

Current revision Rev2

Approval

Author signature Approver signature

Name Mike Jorgensen Name Stuart Taylor

Title Project Manager Title Project Director

Contents 1 Introduction ....................................................................................................................................... 6

1.1 Background ............................................................................................................................ 6 1.2 Objective ................................................................................................................................ 6 1.3 OMP Purpose ......................................................................................................................... 7 1.4 OMP Scope ............................................................................................................................ 7 1.5 Management Area .................................................................................................................. 7 1.6 Roles and Responsibilities ..................................................................................................... 7 1.7 OMP Implementation and Review .......................................................................................... 8

2 Site Setting ........................................................................................................................................ 9 2.1 Site Characteristics ................................................................................................................ 9

2.1.1 Regional meteorology .............................................................................................. 9 2.1.2 Topography and bathymetry .................................................................................... 9 2.1.3. Ecological setting ................................................................................................... 10 2.1.4 Geology ................................................................................................................. 10 2.1.5 Soil landscape ....................................................................................................... 11 2.1.6 Hydrogeology ........................................................................................................ 11 2.1.7 Management Area Surface Water Features and Drainage .................................... 12 2.1.8 PFAS Impacts to Surface Water and Groundwater ................................................ 12

2.2 Groundwater use .................................................................................................................. 12 2.2.1 On-site ................................................................................................................... 12 2.2.2 Off-site ................................................................................................................... 12

3 Ongoing Monitoring Program ........................................................................................................ 14 3.1 Data Quality Objectives ........................................................................................................ 14 3.2 Sampling and Analysis Quality Plan ..................................................................................... 16 3.3 Sample Analysis ................................................................................................................... 17 3.4 Proposed monitoring intervals .............................................................................................. 17 3.5 Surface Water Monitoring ..................................................................................................... 18 3.6 Groundwater Monitoring ....................................................................................................... 19

3.6.1 Groundwater Monitoring Network .......................................................................... 19

4 Reporting on Monitoring ................................................................................................................ 24 4.1 PFAS Screening Levels ....................................................................................................... 24 4.2 Reporting Requirements ...................................................................................................... 24

5 Risk Profile Review ......................................................................................................................... 26 6 References ...................................................................................................................................... 27

Figures Figure 1 HMAS Cerberus – Site Location Figure 2 Management Area and Site Vicinity Figure 3 Site Details Figure 4 Surface water catchment (purple line) and topographical (black contours) map of HMAS Cerberus

where Site boundary is indicated by yellow line. Figure 5 Regional groundwater flow – Brighton Group aquifer. Figure 6 Inferred groundwater flow – Uppermost Brighton Group aquifer Figure 7 PFOS Groundwater Plumes Figure 8 Surface Water Features and Drainage Network Figure 9 Surface Water Monitoring Network

Figure 10 Groundwater Monitoring Network

Tables Table 1 Summary of Site identifying details Table 2 Regional Geology Table 3 Data quality objectives Table 4 Data quality indicators (DQIs) Table 5 PFAS Analytes Table 6 Proposed monitoring intervals Table 7 Sampling locations for surface water – inflows Table 8 Sampling locations for surface water – drains discharging into creeks or Hanns Inlet Table 9 Surface water monitoring locations – Base tidal creeks, drains, and Hanns Inlet Table 10 OMP Wells Table 11 Screening levels for PFAS in water

Acronyms Term Definition

AFFF Aqueous film forming foam

AHD Australian Height Datum

ANZECC Australian and New Zealand Environment Conservation Council

AS Australian Standard

bgl Below ground level

BOM Bureau of Meteorology

CoC Chain of Custody

CSM Conceptual Site Model

Defence Department of Defence

DQI Data quality indicators

DQO Data quality objectives

DSI Detailed Site Investigation

EPA Environment Protection Authority

EPBC Act Environment Protection and Biodiversity Conservation Act 1999 (Cwth)

FTS Fluorotelomer sulfonic acid

HDPE High-density polyethylene

HEPA Heads of EPAs Australia and New Zealand

LOR Limit of reporting

MoE Maintenance of Ecosystems

NATA National Association of Testing Authorities

NEMP 2018 PFAS National Environmental Management Plan (January 2018)

NEPM 2013 National Environment Protection (Assessment of Site Contamination) Measure 1999 (Amendment 1, 2013)

PMAP PFAS Management Area Plan

POP Persistent organic pollutant

QA Quality assurance

QC Quality control

SAQP Sampling and Analysis Quality Plan

SEPP State Environmental Protection Policy

SPFE Stored Pressure Foam Extinguishers

STP Sewage treatment plant

TDS Total dissolved solids

TOC Top of casing

UCL Upper confidence level

US EPA United States Environmental Protection Agency

VIC Victoria

Project 256337 File 0066_HMAS_Cerberus_OMP-Rev2-final.docx 12/09/2018 Revision 2 6

1 Introduction

1.1 Background Department of Defence (Defence) commissioned Aurecon Pty Ltd (Aurecon) to undertake a Detailed Site Investigation (DSI) of per- and poly-fluoroalkyl substance (PFAS) site conditions on, and near HMAS Cerberus (the Site; refer Figure 1), which have resulted from the historical use (practice ceased in 2008) of aqueous film forming foam (AFFF) for fire-fighting and fire-fighting training exercises at the Site.

PFAS are manufactured compounds that comprise a carbon background containing many carbon-fluorine bonds that impart oil and water repellent properties. PFAS were first manufactured in the 1940’s and have been widely used in many industrial applications and processes, e.g., fire-fighting foams, electroplating, paper manufacturing, and were commonplace in many domestic household products e.g., non-stick cookware, fabric, furniture and carpet stain protection and food packaging.

PFAS are widely distributed in the global environment due to their high solubility in water, low to moderate sorption to soils and sediments and resistance to biological and chemical degradation. PFAS, including perfluorooctane sulfonic acid (PFOS) and perfluorooctanoic acid (PFOA), have recently emerged as ‘potential contaminants of concern’ around the world due to their persistence in the environment and ability to bioaccumulate in biota (plants and animals) and humans. As a result, significant numbers of people are reported to have measurable levels of PFAS in their body (National Centre for Environmental Health 2017). Consequently, PFOS, its salts and precursors are now recognised as persistent organic pollutants (POPs), listed under Annex B of the Stockholm Convention. They are classified as ‘emerging contaminants’, which means there is limited information available about them and the understanding of the risks to human health and the environment are being developed.

AFFF containing PFAS was used extensively throughout Australia and the world due to its effectiveness in fighting liquid fuel fires. These products were typically used by Defence, as well as civil aviation authorities, the petroleum industry and emergency services. Since the 1970’s Defence has used AFFF to suppress liquid fuel fires, in either training or emergency response applications. At HMAS Cerberus, Defence historically used 3M Light Water AFFF, which contained PFOS and PFOA (Colville and McCarron 2003, Senate Estimates Brief SB15-000647). Since 2004, Defence has been progressively replacing 3M Light Water with Ansulite (3% and 6% AFFF concentration), which does not contain PFOS and PFOA as active ingredients. Ansulite contains other PFAS compounds such as 6:2 Fluorotelomer sulfonic acid (6:2 FTS) and 8:2 Fluorotelomer sulfonic acid (8:2 FTS) and has the issue of impurities and precursor transformation. Around 2008, usage of Ansulite at the Site ceased and was replaced with a Solberg foam that does not contain PFAS.

A PFAS Management Area Plan (PMAP) has been prepared to provide a roadmap for response management by Defence of potential risks arising from PFAS impact associated with HMAS Cerberus and surrounding areas. The PMAP includes a Management Area ongoing monitoring plan (OMP) that sets out the process that will be used to monitor changes in groundwater and surface-water PFAS characteristics. The OMP is set out in this document.

1.2 Objective The objective of the OMP entails describing a program to monitor groundwater and surface water conditions at the Site. The findings from the monitoring will be used to assess any changes to the nature and extent of PFAS impact where there is an identified potentially elevated risk to a receptor or a potential future risk to a receptor.


1.3 OMP Purpose The purpose of the monitoring set out in the OMP is to evaluate whether any changes had occurred in the nature and extent of PFAS impact in groundwater and surface water pathways associated with Site sources of PFAS derived from AFFF.

Findings from implementing the program will provide information on changes in PFAS contamination originating from a Defence Base to inform risk management decisions by Defence and State/Territory agencies to protect human health and the environment.

1.4 OMP Scope The scope of the OMP comprises the following elements:

Roles and responsibilities for implementing the OMP (refer Section 1.6)

Site setting to provide context to the monitoring program (refer Section 2)

Sampling locations, level and flow measurements, analytes and sampling frequency (refer Section 3)

As recommended in the PMAP, fulfilment of these scope elements provides information that will inform the on-going requirements for Site management of PFAS-impacted media that contributes to a potentially elevated risk to receptors.

Note that the monitoring proposed is primarily to evaluate changes in the nature and extent of PFAS impacts in groundwater and surface water. Where relevant, the data collected will also be used to support the ongoing evaluation of management responses outlined in the PMAP, although this is not the specific purpose of the monitoring detailed in this OMP. Specific further investigation or monitoring to assess the feasibility of a management option, or monitoring to assess the efficacy of the implementation of a management response, will be outlined in separate documentation.

1.5 Management Area The management area (MA) coincides with the investigation area (IA) for the intrusive component of the DSI works (refer to the blue polygon shown on Figure 2).

1.6 Roles and Responsibilities Defence is the occupier of the Site and undertook activities that resulted in the identified PFAS impact across the Site. As such, Defence is responsible for implementing this OMP, which includes the following roles and responsibilities.

Role Responsibilities

Defence (Base managers, Regional environmental and sustainability officers, and the PFAS investigations management branch)

Ensure that the OMP is implemented;

Respond to exceedances of adopted trigger levels and enact contingency measures where required.

Ensure future access rights to the Site to allow ongoing monitoring and maintenance activities.

Liaise with EPA Victoria as required.

Contractor / consultant to undertake monitoring of groundwater and surface water

Execute monitoring activities per this OMP and relevant reference guidelines, including the SAQP (as amended) for the DSI.

Report findings from the monitoring to Defence as set out in the OMP.


Contractor (laboratory NATA-accredited for PFAS analyses)

Using current analytical methods, undertake PFAS (and non-PFAS, as required) analyses of water samples provided by the contractor / consultant.

Provide NATA-certified laboratory reports of analytical results (including ESDAT-compatible electronic format) to the monitoring contractor and Defence.

1.7 OMP Implementation and Review Initially, the OMP will be implemented for a one-year period, which will allow evaluation of seasonal and spatial changes in PFAS concentrations across the MA. Upon completion of this initial year of implementation, the findings from the monitoring will be assessed with regards to:

Frequency of monitoring and sampling events to allow timely detection of any changes in the nature and extent of PFAS impact across the MA.

Screening levels may have changed since adoption of the values used in the DSI and this OMP. Therefore, this will include a review of the currency of screening levels to reflect the on-going research on PFAS risks.

Appropriateness of trigger points and mitigation/response measures to manage risk posed by increasing PFAS concentrations.

Appropriate monitoring frequency for subsequent events to assess concentration trends at a specified level of statistical confidence.

This OMP is a living document that will be reviewed at least on an annual basis. In particular, this OMP will be reviewed with consideration of:

Changes in the nature and extent of PFAS concentrations over time and across the MA would be reviewed to evaluate whether the monitoring frequency should be changed.

− For example, if PFAS concentrations in a well is increasing based on a statistical trend analysis, then more frequent sampling may be required and additional wells may need to be added to the monitoring plan.

− Conversely, if PFAS concentrations reported for wells along a groundwater pathway reduce below respective screening levels on a consistent basis, then those wells could be removed from the monitoring program.

Changes in the monitoring network (such as destruction of monitoring locations due to construction activities).

Undertaking management response activities (such as source removal by excavation).

Changes in legislation, regulations or guidelines.

Changes to Defence policy pertaining to PFAS.


2 Site Setting

2.1 Site Characteristics HMAS Cerberus is located between Somers and Bittern / Crib Point, on Western Port Bay, approximately 70 km south of Melbourne, Victoria (refer to Figure 1). The Site surrounds Hanns Inlet, which is located off the north arm of Westernport Bay, the latter being an internationally significant wetland listed under the Ramsar Convention on Wetlands (refer Figure 2). Site identifying details are summarised in Table 1. Table 1 Summary of Site identifying details

Item Relevant Site Information Site address HMAS Cerberus, VIC, 3920

Site area 1,517 ha (15.17 km2) Current Site owner Department of Defence

Municipality Mornington Peninsula Shire Council Property Number 80160 Current Land Use Zoning Commonwealth Land (CA)

Current Site Occupier Department of Defence (RAN) Lot and Plan Number 45 parcels of land

2.1.1 Regional meteorology Climate data for the site available from the Site weather station (Bureau of Meteorology station number 086361) between 1986 and 2017 indicates the following:

• Annual rainfall is approximately 723 mm, which occurs over approximately 178 days of rain.

• Highest average monthly rainfall is approximately 75 mm, which occurs in August

• Lowest average monthly rainfall is approximately 38 mm, which occurs in January and February

• Average maximum temperatures range between 14ºC in the winter and 25ºC in the summer. Average minimum temperatures range between 6ºC and 14ºC. Average annual wind speed is approximately 15 km/hr in the morning and 20 km/hr in the afternoon.

Migration of PFAS in surface water is more likely to occur in the wetter months as stormwater captures PFAS from across the site and there is an increased risk of overflow of the former sewage treatment plant. Any effluent overflowing from the former STP would discharge into the creek flowing between the STP lagoons, which discharges into Hanns Inlet.

2.1.2 Topography and bathymetry Topographically, the Site is located within a broad valley that slopes to the southeast towards Hanns Inlet and the North Arm of Westernport Bay. The highest portion of the broad valley ranges in elevation between 50 mAHD and 90 mAHD (refer to Figure 4). The main operational area of the Site is between sea level and approximately 10 mAHD on a low ridge flanked by two drainages that flow to the southeast towards Hanns Inlet. On-site, higher ridges with remnant vegetation (up to approximately 20 mAHD) are located north and south of the two main drainages.

Hanns Inlet, which is a tidally influenced estuary, connects to the North Arm of Western Port Bay. Water depths in Hanns Inlet varies with tide level. The tidal flats are often exposed during low tides; while at high tides water depths can be up to 2 m. Within the access channel to the Site marina water depths range between 2 m and 4 m over tide cycles.

With a tidal range of approximately 2 m, most of Hanns Inlet consists of a broad tidal flat with a main tidal channel extending out from the two main natural drainages (South Creek and East Creek) located south and


east of the main operational area of the Site. Typically, the tidal flat is inundated twice a day with high tides rising to approximately 1 mAHD and low tides falling to around -1 mAHD. To provide ship access to the Site, a man-made channel between 2 m and 3 m deep is maintained. This access channel was last dredged (to remove weed and marine vegetation) in 2006 with the spoil placed in a sullage pit located on the north shore of Hanns Inlet (refer Figure 3).

2.1.3. Ecological setting HMAS Cerberus borders the Western Port Bay Ramsar wetlands, which encompasses Hanns Inlet. Using the on-line search tool for matters of national environmental significance, Aurecon (2018) indicated that there were 63 threatened species of birds, frogs, mammals, sharks and plants. Two ecological communities (Subtropical / Temperate Coastal Saltmarsh and Natural Damp Grassland of the Victorian Coastal Plains) were listed as threatened.

The sensitive ecological receptors identified in the investigation area, include but are not limited to;

Mammals, such as rabbits, kangaroos and possums

Birds, migratory and local

Reptiles and insects

Semi-aquatic biota, including crabs and worms

Fish, including flathead, whiting, mullet, Australian salmon, toad fish and trevally

Fiddler rays (banjo sharks) and gummy sharks

Pipis, oysters and crustaceans

Benthic detritivores

Grass, trees and other vegetation

Cows are maintained off-Site to the west and south of the Site for agricultural business (grazing and dairy). Horses are also maintained in this agricultural area off-Site to the west and south.

2.1.4 Geology Interrogation of the GeoVic1 and Visualising Victoria Groundwater (VVG)2 websites indicated that geology at and near the Site comprised the following strata (refer Table 2).

Table 2 Regional Geology

Strata Characteristics Thickness (m)

Recent dune, river, swamp and alluvial deposits Dune sands (Sandy Point), predominantly silts and clays with some interbedded sands 0 - 15

Tertiary Brighton Group (river and near-shore marine deposits) (lateral equivalent to Baxter Sands)

Sandy clays to clayey sands with localised iron staining and cement 1 - 20

Tertiary Yallock Formation and Sherwood Marl (marine) (lateral equivalent to the Fyansford Formation)

Sand and clays with some limestone layers 50 - 60

Tertiary Childers Formation (coastal/near-shore marine) (lateral equivalent to the Werribee Formation)

Lignite and clay with some sand 10 - 15

Interbedded with the Werribee Tertiary Older Volcanics (terrestrial deposits)

Variably weathered and fractured basalt lava flows 10 - 20

Silurian Bedrock (marine deposits) Siltstones and sandstones >100

1 http://earthresources.vic.gov.au/earth-resources/maps-reports-and-data/geovic 2 http://www.vvg.org.au/

http://earthresources.vic.gov.au/earth-resources/maps-reports-and-data/geovic


2.1.5 Soil landscape Regionally, the State soils database indicates that the Site comprises the Bittern soil complex comprising brown and yellow Chromosols with some Sodosols. Surface soils comprise dark brown, slightly acidic loamy sands to fine sandy clay loams. Subsoils comprise moderately acidic, yellow-brown heavy clay.

The regional soil characteristics were evident in the surface soils sampled during the DSI (Aurecon, 2018), which typically comprised silty sands to clayey sands, coloured grey to brown with moist to wet moisture conditions. Acid sulphate soils are likely to be present in the wetlands soils (hydrosols) deposited along the tidally influenced portions of the Site creeks. In the tidal flats swamp deposits occur, which are wet for most of the year and are dark grey clays or silty clays, which become bluish grey with depth. These soils can be described as Extratidal Hydrosols.

Fill soils comprising Brighton Group sediments excavated from the northern portion of the Site were used to reclaim tideland along the marina area. Logs for boreholes in this area indicate approximately 4 m of clayey fill material was placed in this area.

2.1.6 Hydrogeology Regionally, groundwater generally flows towards the southeast from the head of the local groundwater basin located northwest of the Site. These shallow aquifers are predominantly recharged directly by rainfall within the local catchment; and to a lesser degree by irrigation of sports fields or agricultural land. Groundwater discharges via either evapotranspiration, surface-water features, such as the local drainages and Hanns Inlet, or off-Site extraction wells. As shown by the purple arrows on Figure 5, groundwater flows generally to the southeast where discharge occurs through the seafloor of Western Port Bay (including Hanns Inlet).

Shallow aquifers at the Site fall within a groundwater basin coincident with the local surface-water catchment shown on Figure 4. Shallow groundwater (less than 20 m in depth) occurs in the Recent alluvial sediments (Quaternary Aquifer under the Victorian Aquifer Framework, SKM, 2009) and the Tertiary Brighton Group sands and clays (Upper Tertiary Aquifer (fluvial), and Upper Mid-Tertiary Aquifer).

At the Site, a water-table aquifer is developed in the Recent alluvial soils (mainly silts and clays) deposited in the drainages south and east of the operational portion of the Site (south of the Fire Ground and east of the Fire Station) and in fill soils in the marina area. A semi-confined aquifer is developed in the Tertiary Brighton Group sediments.

As shown on Figure 6, shallow groundwater in the Brighton Group aquifer is inferred to flow generally to the southeast with localised flow towards the Site tidal creeks. Note that the inferred directions are from private extraction bores onto the operational area of Site. This means that the private extraction bores are inferred to be located hydraulically up- or cross-gradient (east, north and west) of the Site.

Interrogation of the VVG3 website indicates groundwater salinity at and near the Site falls within Segment B (that is, between 1,000 mg/L and 3,500 mg/L of total dissolved salts (TDS). Salinities of groundwater (as electrical conductivity (EC)) reported for the Site monitoring wells (Golder, 2017) ranged between approximately 1,000 µS/cm and 30,000 µS/cm, which indicate that fresh (potable) to saline groundwater is present beneath the Site. Golder measurements indicate that potable groundwater (Segment A) is locally present in the western portion of the Fire Ground, which may reflect local recharge and / or leakage from the storage pond at the Fire Ground.

In addition, seawater intrusion occurs near the tidal channels south and east of the operational area and along the shoreline of Hanns Inlet. In these area, a wedge of saline groundwater extends landward (to the west) from Hanns Inlet. In addition, the wide tidal range of approximately 2 m results in typically a twice-daily inundation of the tidal flats of Hanns Inlet. This seawater recharges the surface soils of the tidal flats and mixes with shallow groundwater in a mixing (hyporheic) zone. Hence, along the shoreline shallow groundwater is generally brackish and not used for potable supply.

3 http://www.vvg.org.au/ accessed 1 August 2017.

http://vro.agriculture.vic.gov.au/dpi/vro/vrosite.nsf/pages/gloss_HR#hydrosols

http://www.vvg.org.au/


2.1.7 Management Area Surface Water Features and Drainage The storm-water network for the operational areas of the Site consists of a combination of open drains and an engineered concrete pit-and-pipe network (refer Figure 7).

Surface-water features comprise the Ornamental Lake located south of the Fire Station, the storage lagoon at the Fire Ground, three lagoons at the former sewage treatment plant, and tidal creeks and drains (refer Figure 3). The Ornamental Lake drains via a pipe to Hanns Inlet. Until 2017, the storage lagoon at the Fire Ground drained via a pipe to the wetlands south of the Fire Ground.

2.1.8 PFAS Impacts to Surface Water and Groundwater Residual PFAS in soils were identified and generally delineated, with respect to the adopted screening criteria, within and surrounding the key areas where known AFFF use, storage and waste management has occurred; including the Fire Ground (and neighbouring wetlands) and Fire Station (and nearby Ornamental Lake). These soil (and minor concrete) impacts have in turn caused PFAS impact to surface waters and groundwater within the Site. These surface waters and groundwater provide the transport pathways for ultimate discharge into Hanns Inlet.

The major source areas (i.e., areas of more significant residual PFAS impact) were identified as:

The Fire Training Ground (Fire Ground)

South Creek and receiving wetlands (which both received stormwater runoff from the Fire Training Ground)

Residual PFAS in soils were identified and generally delineated, with respect to the adopted screening criteria, within and surrounding the other potential source areas; including the Former Sewage Treatment Plant (STP), the Sports Fields that were irrigated with recycled water, a region of a bushfire, the closed landfill sites, the former dry cleaning facility, the former coal loading area, some of the areas with underground fuel storage tanks and the Sullage Pit (which contains vegetation and sediment from channel maintenance in Hanns Inlet). Likewise, these soil impacts have in turn caused PFAS impact to surface waters and groundwater within the Site. These surface waters and groundwater provide the transport pathways for ultimate discharge into Hanns Inlet.

Groundwater impacted by Site-derived PFAS is present across the operational portion of the Base. The plumes associated with Site sources are generally migrating in a southerly to easterly direction and discharges into Hanns Inlet or interacts with surface water within the tidal creeks within the low lying tidal sections of the Site, which ultimately discharge to Hanns Inlet

Surface water within the Site is primarily impacted with Site-derived PFAS however PFAS impacted surface water was reported entering the Site via drains that received PFAS-impacted water from unknown off-Site source(s) at two locations along the northern and western Site boundaries.

2.2 Groundwater use

2.2.1 On-site Groundwater is not abstracted or used at the Site.

2.2.2 Off-site A water use survey was issued to properties within 1 km of the Site boundary between 28 July and 7 August 2017 to determine water use and land use activities on properties adjacent to HMAS Cerberus. The format of the water use survey was provided by Defence to ensure consistency with other Defence Sites where DSI works were being conducted.

A total of 280 surveys were completed using hard copy or online (Survey Monkey) format, between 1 August 2017 and 27 November 2017.


To summarise the results of those returned surveys:

• 243 identified as private residential properties

• 28 identified as rental properties

• 12 identified as hobby farms

• 1 identified as industrial

• 1 identified as horticultural

• identified as food production

• 1 identified as aquaculture

• 1 identified as other

Water supply and use on those properties comprised:

• 239 used mains water

• 145 used rain water

• 33 used bore water (exact locations cannot be shown due to privacy laws)

• used recycled water

• 195 had rain water tanks

• 6 users currently mixed bore water with rain water in tanks for mixed use (see below) and 9 users have previously mixed bore water with rain water

Water use surveys identified bore water was used directly or via tank top up for:

• 1 for domestic use

• 5 for household purposes

• 2 for drinking

• 1 for washing

• 2 for watering animals

• 3 for livestock

• 1 for vines

• 5 for gardens

• 1 for vegetables

• 3 for swimming pools

• 1 for toilets

• 1 for firefighting

• 1 for wetlands

• 1 for contingency livestock watering

It was determined that sampling of these off-Site bores was not required as previous sampling of such off-site bores reported PFAS concentrations below drinking water guidelines (GHD, 2016). This was further supported by sampling and analysis of groundwater undertaken for this investigation at locations along the Site boundary, which likewise reported PFAS concentrations in groundwater below NEMP (2018) drinking water screening criteria.


3 Ongoing Monitoring Program

3.1 Data Quality Objectives Data quality objectives (DQOs) are qualitative and quantitative statements derived from the outputs of the first six steps of the seven steps DQO process that:

• Clarify the study objective

• Define the most appropriate type of data to collect

• Determine the most appropriate conditions from which to collect data

• Specify tolerable limits on decision errors which will be used as the basis for establishing the quantity and quality of data needed to support the decision

The DQOs for this investigation have been prepared in line with the DQO process outlined in US Environmental Protection Agency (EPA) (2006) and NEPM 2013 (Schedule B2), and are presented in the seven-step DQO approach presented in Table 3. Data quality indicators (DQIs) relevant to the DQOs are presented in Table 4.


Table 3 Data quality objectives

Process Response Step 1: State the Problem

The PMAP recommended ongoing surface water and groundwater monitoring be undertaken to assess variation in PFAS concentrations over time and across the MA.

Step 2: Identify the Decision

The principle objective of the OMP is to monitor and assess variations in PFAS concentrations in groundwater and surface water over time and across the MA. In particular, to evaluate:

Migration of PFAS in groundwater from the Site, particularly in groundwater discharging to Site tidal creeks or directly into Hanns Inlet

Conduct surface water sampling during a range of flow conditions, including worst-case scenario (e.g., extreme rainfall events)

Step 3: Identify the Inputs to the Decision

Objectives and scope of works of this plan

Findings from the DSI

CSM, including potential sources, pathways and receptors

Contaminants of concern (PFAS)

Field methods, such as sampling, sample storage and preservation, laboratory methods, quality control (QC) and quality assurance (QA)

Media to be sampled (surface water and groundwater samples), and location of samples

Adopted assessment criteria for surface water and groundwater

Field data (including water quality parameters and visual/olfactory observations) and laboratory analysis

Step 4: Define the Boundaries of the Study

The OMP comprises sampling locations within the MA to assess variation in PFAS concentrations over time and to measure the success of the remediation and management methods. The surface water and groundwater sampling locations are detailed on Figure 9 and Figure 11, respectively. The sampling unit for surface water and groundwater will be an assessed, collected and field screened water sample in a laboratory supplied HDPE bottle.

Step 5: Develop a Decision Rule

The statistical parameter of interest is the true mean of the contaminant concentrations, as evaluated by calculating the 95% upper confidence interval (95% UCL) based on the concentrations reported in each media at each sampling location. Typically, calculation of the 95% UCL requires at least four results to be statistically valid. The OMP will: Compare PFAS concentrations in surface water and groundwater against the interim

ecological screening levels for fresh and marine waters, drinking water and recreational water health based guidance values, developed by Food Standards Australian and New Zealand (2017)

Compare PFAS concentrations in surface water and groundwater against previous results to determine any trends or variations in concentrations. In particular, trends that suggest exceedance of any relevant screening level prior to the next sampling event would trigger more frequent sampling to confirm any identified increasing trends

Step 6: Specify Tolerable Limits on Decision Errors

Acceptance limits on field and laboratory data collected for this investigation will be in accordance with NEPM 2013 and the 2018 NEMP. The acceptable limits on decision errors to be applied in the investigation and the manner of addressing possible decision errors have been developed based on the data quality indicators (DQIs) of precision, accuracy, representativeness, comparability and completeness, and are presented in this Section. The potential for significant decision errors will be minimised by completing a robust QA/QC program and by completing an investigation that has an appropriate sampling and analytical density for the purposes of the investigation.

Step 7: Optimise the Design for Obtaining Data

The OMP has been developed in accordance with relevant guidelines through targeted monitoring of source-pathway-receptors. Samples are to be analysed by a National Association of Testing Authorities (NATA) accredited laboratory within approved sample holding times. The recommended holding time for PFAS is 14 days.


Table 4 Data quality indicators (DQIs)

DQI Field Laboratory Acceptability

limits Completeness Water identified to be potentially

impacted by contamination pose a potential risk to health, safety and the environment and may require remediation to remove the risk to human health and the environment.

Appropriate sampling procedures to be used

Experienced field team to undertake monitoring

Correct documentation to be completed

All required samples analysed

Appropriate methods Appropriate limits of

reporting (LORs) Sample documentation

correct Sample holding times in

compliance

As per NEPM 2013

Comparability Correct sample procedures used at each location

Experienced field team Same type (medium, volume and

sampling technique) of samples collected

Same analytical methods used

Appropriate LORs Samples submitted to the

same NATA accredited laboratory

Analytical data is presented in the same unit

As per NEPM 2013

Representativeness Appropriate media sampled All media identified (ie surface

water, groundwater)

All required samples analysed

As per NEPM 2013

Precision Correct sample procedures used at each location

Collection of appropriate QA/QC samples

Analysis of: Intra- and inter-laboratory

samples (1 per 10 samples collected)

Laboratory duplicate samples

Relative percent deviation (RPD) of 30-50%

Accuracy Sampling procedures appropriate and complied with

Collection of appropriate QA/QC samples

Analysis of: Method blanks Laboratory surrogate spikes Laboratory control samples Reference material Matrix spikes Matrix spike duplicates Surrogate spikes

Non-detect for contaminants of concern

70-130%

3.2 Sampling and Analysis Quality Plan A sampling and analysis quality plan (SAQP) should be prepared for undertaking the monitoring set out in this OMP. The SAQP developed for the DSI should be used as the basis for preparing a SAQP for this OMP. This approach would provide consistency in sampling methods and analyses. The OMP SAQP should comply with the guidelines set out in the following guidelines:

NEPC, 2013, National Environment Protection (Assessment of Site Contamination) Amendment Measure 2013 (No. 1), Canberra, National Environment Protection Council (NEPM).

EPA Victoria, 2009, Industrial Waste Resource Guidelines, Sampling and Analysis of Waters, Wastewaters, Soils and Wastes, Publication 701.

EPA Victoria, 2018, Interim Position Statement on PFAS, Publication 1669.2, August 2018.

Heads of EPAs, 2018, PFAS National Environmental Management Plan.


3.3 Sample Analysis The primary and secondary laboratories should be NATA accredited for all analyses. Laboratory analysis of PFAS presented in Table 3 should be undertaken for samples of groundwater, surface water, and QA/QC samples, such as rinse blanks. In addition, groundwater samples should be analysed annually for total organic carbon and major anions and cations.

Table 5 PFAS Analytes

Functional group Parameter

Perfluoro carboxylates (PFCAs) Perfluorobutanoic acid (PFBA)

Perfluoropentanoic acid (PFPeA)

Perfluorohexanoic acid (PFHxA)

Perfluoroheptanoic acid (PFHpA)

Perfluorooctanoic acid (PFOA)

Perfluorooctane sulfonamide (PFOSA)

Perfluorononanoic acid (PFNA)

Perfluorodecanoic acid (PFDA)

Perfluoroundecanoic acid (PFUnDA)

Perfluorododecanoic acid (PFDoA)

Perfluorotridecanoic acid (PFTrDA)

Perfluorotetradecanoic acid (PFTeDA)

Fluorotelomer sulfonates (FTSs) 4:2 Fluorotelomer sulfonic acid (4:2 FTS)

6:2 Fluorotelomer sulfonic acid (6:2 FTS)



Perfluroalkyl sulfonates (PFSAs) Perfluorobutane sulfonic acid (PFBS)

Perfluoropentane sulfonic acid (PFPeS)

Perfluorohexane sulfonic acid (PFHxS)

Perfluoroheptane sulfonic acid (PFHpS)

Perfluorooctane sulfonic acid (PFOS)

Perfluorodecane sulfonic acid (PFDS)

Perfluorooctane sulfonamidoethonals and perfluorooctane sulfonamidoacetic acids

N-methylperfluoro-1-octane sulfonamide (N-MeFOSA)

N-ethylperfluoro-1-octane sulphonamide (N-EtFOSA)

2-(N-methylperfluoro-1-octane sulfonamido)-ethanol (N-MeFOSE)

N-methyl-perfluorooctanesulfonamidoacetic acid (N-MeFOSAA)

2-(N-ethylperfluoro-1-octane sulfonamido)-ethanol (N-EtFOSE)

N-ethyl-perfluorooctane sulfonamidoacetic acid (N-EtFOSAA)

3.4 Proposed monitoring intervals Ongoing monitoring of surface and groundwater requirements will vary through the implementation period of the PMAP as detailed in Table 6 below.


Table 6 Proposed monitoring intervals

Matrix Location Interval* Parameters

Surface Water Drain discharge points and at locations indicated along the Site creek and drains, and at the floating docks in Hanns Inlet

Twice yearly for tidal creeks and Hanns Inlet; Ephemeral drains during wet season and post-extreme event

Level (including levels in South Creek bridge and Hanns Inlet at the marina), flow (except at Hanns Inlet locations), physical-chemical parameters PFAS

Groundwater Groundwater on Site from select wells

Twice yearly: August/September & February/March

Groundwater levels, physical-chemical parameters PFAS

Table note: * Individual Remediation Action Plans may alter the frequency of monitoring

3.5 Surface Water Monitoring Surface water monitoring will be conducted in the long term to provide ongoing measurement of PFAS concentration within surface-water pathways that are considered the primary pathway for PFAS resulting in exposure to on- and off-Site receptors (Aurecon 2018). In addition, the flow rate and quality (physical-chemical parameters) of surface water will be measured at each sampling location.

Proposed monitoring of surface water located in and surrounding the management area are detailed on Figure 9 and details presented in Table 7 through Table 9.

Table 7 summarises sampling locations for drains that discharge onto the Base. Results for samples collected from these locations will be used to evaluate whether PFAS-impacted stormwater is coming into the MA.

Table 7 Sampling locations for surface water – inflows

Drain Feature Surface water body

Aurecon Sample

ID

Indicative flow rate

(L/s) Longitude Latitude Easting Northing Inflow 3 (top of East Creek catchment)

SW021 1 145.178894 -38.353713 340877 5753369

Inflow 4 (top of East Creek catchment)

SW022 10 145.1712 -38.353714 340204 5753356

Inflow 5 (South Creek upstream of Fire Ground)

SW024 1 145.171238 -38.365082 340233 5752094

Inflow 6 (upstream of former STP) SW023 1 145.177082 -38.377417 340770 5750736

Table 8 summarises locations at stormwater drains discharging from Base into either Base tidal creeks or directly into Hanns Inlet. Results from these samples will be used to evaluate whether the flux of PFAS discharging ultimately into Hanns Inlet is changing during implementation of the PMAP. Note that some of these drain outlets may be decommissioned as part of the Base redevelopment works. Replacement drain lines would be installed and the sampling locations will need to be updated.


Table 8 Sampling locations for surface water – drains discharging into creeks or Hanns Inlet

Drain Feature Surface water

body Aurecon

Sample ID


(L/s) Longitude Latitude Easting Northing Outflow 8 (HC945) SW001 10 145.1893 -38.3727 341827 5751280 HC886 SW002 0.5 145.1894 -38.3727 341834 5751278 Outflow 6 (HC665) SW003 2 145.1927 -38.3709 342117 5751488 Outflow 9 (HC164) SW004 10 145.188 -38.3726 341715 5751294 HC955 SW005 1 145.1905 -38.3727 341931 5751282 Outflow 7 (HC911) SW006 1 145.1911 -38.3728 341986 5751272 Outflow 5 (HC786) SW007 1 145.1927 -38.3699 342121 5751595 Outflow 4 (HC787) SW008 0.1 145.1927 -38.3695 342116 5751641 HC679 SW009 1 145.1925 -38.3642 342086 5752225 HC1003 SW010 1 145.1911 -38.3636 341962 5752298 HC980 SW011 20 145.1896 -38.3627 341832 5752394 HC1014 SW012 1 145.183 -38.3626 341252 5752393 HC628 SW013 1 145.1856 -38.3624 341479 5752413 HC978 SW017 20 145.1784 -38.3762 340883 5750868 HC772 SW018 0.01 145.1923 -38.366 342079 5752027 HC544 SW029 1 145.1839 -38.3693 341351 5751651 HC420 SW030 1 145.1839 -38.3693 341351 5751651

Table 9 summarises locations at Base tidal creeks discharging into Hanns Inlet. Results from these samples will be used to evaluate whether the flux of PFAS discharging via the tidal creeks into Hanns Inlet is changing during implementation of the PMAP. These samples should be collected as the tide in Hanns Inlet is falling; ideally, as slack tide occurs to maximise the contribution of baseflow into each creek. In addition, samples of surface water should be collected.

Table 9 Surface water monitoring locations – Base tidal creeks, drains, and Hanns Inlet

Drain Feature Surface water body Aurecon

Sample ID


(L/s) Longitude Latitude Easting Northing South Creek (near Fire Ground) SW024 0 to 10 145.171238 -38.365082 340233 5752094 South Creek (near closed Rifle Range Road landfill)

SW028 0 to ~50 145.181491 -38.369991 341139 5751567

South Creek (bridge across creek) SW027 0 to ~50 145.182899 -38.370987 341264 5751459 East Creek (upstream of road causeway)

SW020 0 to ~50 145.193142 -38.364651 342145 5752180

West Creek (former STP) SW017 0 to 10 145.178406 -38.376244 340883 5750868 Hanns Inlet Dock NA

3.6 Groundwater Monitoring

3.6.1 Groundwater Monitoring Network The groundwater bore network will be monitored to provide ongoing measurement of PFAS concentration within groundwater, in addition to the quality (physical-chemical parameters) of groundwater.

The HMAS Cerberus groundwater bore network was expanded as part of the Aurecon (2018) DSI. Groundwater wells that are proposed to be gauged prior to sampling are presented in Table 10 and on Figure 10. This data will be used to evaluate whether any significant changes had occurred in the flow direction of groundwater. Table 10 also indicates wells to be sampled under this OMP.


Table 10 OMP Wells

Location Sample

ID Source Area Monitored Sampled?

Zone 55

Easting Zone 55 Northing Monitored Aquifer

E Boundary MW207 Off-site to east Yes 342279 5752784 Brighton Group

E boundary MW208 Off-site to east Yes 342053 5753004 Brighton Group

East of Sports Fields

MW111 Sports Fields Yes 342002 5751955 Brighton Group

Fire Station MW110 Fire Station Yes 342066 5752094 Alluvial/Estuarine/Brighton Group

Marina MW216 Sports Field Yes 342057 5751446 Brighton Group

N Boundary MW205 Off-site to north No 340198 5753349 Brighton Group

N Boundary MW206 Off-site to north Yes 340868 5753365 Brighton Group

N Boundary MW209 Off-site to north Yes 341589 5753229 Brighton Group

N of Operations MW200 Up-gradient from sources

No 341015 5752559 Brighton Group

NW boundary corner

MW204 Off-site to west and northwest

Yes 339777 5753343 Brighton Group

NW Building 116 MW201 Cross-gradient from main sources


South of Fire Station

MW111 Sports Field Yes 342002 5751955 Brighton Group

VT0067 GW05-VT0067

Fire Ground No 341097 5751993 Brighton Group

VT0067 GW06-VT0067

Fire Ground Yes 341166 5751963 Brighton Group

VT0067 GW07-VT0067


VT0067 GW08-VT0067


VT0067 GW09-VT0067


VT0067 MW103 Fire Ground No 341177 5751999 Brighton Group

VT0067 MW117 Fire Ground Yes 340961 5752068 Brighton Group

VT0067 MW214D Fire Ground Yes 341178 5751865 Brighton Group

VT0067 MW214S Fire Ground No 341177 5751865 Brighton Group

VT0067 MW215D Fire Ground Yes 341123 5751920 Brighton Group

VT0067 MW215S Fire Ground Yes 341122 5751920 Brighton Group

VT0067 MWSSS Fire Ground Yes 341142 5752034 Brighton Group

VT0067 wetlands

MW121 Fire Ground Yes 341074 5751797 Brighton Group

VT0067 wetlands

MW122D Fire Ground Yes 341111 5751691 Brighton Group

VT0067 wetlands

MW122S Fire Ground Yes 341111 5751690 Alluvial/Estuarine

VT0067 wetlands

MW212 Fire Ground Yes 341024 5751716 Alluvial/Estuarine

VT0067 wetlands

MW213 Fire Ground Yes 341054 5751701 Alluvial/Estuarine

VT0191 GW01-VT0191

West of Building 192 - UST CER2


VT0191 GW02-VT0191

West of Building 192 - UST CER2


VT0192 GW01-VT0192

Former washdown area of WTP filters at Fire Ground


VT0192 GW02-VT0192




Location Sample


Zone 55


VT0192 GW03-VT0192



VT0192 MW100 Former washdown area of WTP filters at Fire Ground


VT0192 MW101 Former washdown area of WTP filters at Fire Ground


VT0365 GW01-VT0365

Rifle Range Road Landfill

Yes 341370 5751555 Alluvial/Estuarine

VT0365 GW02-VT0365



VT0365 GW03-VT0365



VT0365 GW04-VT0365



VT0366 GW01-VT0366

Former Outdoor Swimming Pool Landfill

No 341829 5751299 Fill

VT0366 GW02-VT0366

Former Outdoor Swimming Pool Landfill

Yes 341777 5751318 Fill (Waste)

VT0367 GW01-VT0367

Reclaimed Land, Former Coal/Fuel Storage


VT0367 GW02-VT0367



VT0367 GW03-VT0367



VT0367 MW102 Reclaimed Land, Former Coal/Fuel Storage


VT0368 GW02-VT0368

Former Dry Cleaning Yes 341584 5751784 Brighton Group

VT0368 GW03-VT0368

Former Dry Cleaning No 341614 5751816 Brighton Group

VT0368 MW109 Former Dry Cleaning Yes 341535 5751847 Brighton Group

VT0368 MW116 Former Dry Cleaning Yes 341619 5751805 Brighton Group

VT0368: southwest

MW112 VT0368 Yes 341456 5751682 Brighton Group

VT0369 GW01-VT0369

Between Nelson Rd & Building 25 - UST CER03

No 342017 5751691 Fill

VT0369 GW02-VT0369

Sports Fields Yes 341950 5751689 Brighton Group

VT0369 / VT0367 MW104 Sports Fields No 341983 5751664 Brighton Group

VT0370 GW01-VT0370

Corner Cook & Bass Rd - Former Petrol Station USTs


VT0370 GW02-VT0370



VT0370 GW03-VT0370



VT0371 GW01-VT0371

South of Building 55 - Filling Station USTs


VT0371 GW02-VT0371



VT0371 GW03-VT0371




Location Sample


Zone 55


VT0371: to southeast

MW114 South of Building 55 - Filling Station USTs

Yes 342022 5751322 Fill

VT0372 GW01-VT0372

Building 49 - Demonstration Building - AST


VT0372 GW02-VT0372



VT0372 GW03-VT0372



VT0373 GW01-VT0373

Ward Room Store 102 - AST


VT0373 GW03-VT0373

East of Building 28 - Reclaimed Land, Former Coal/Fuel Storage


VT0375 GW01-VT0375

former STP treatment tanks


VT0375 GW02-VT0375

former STP treatment tanks


VT0375 MW001 former STP No 340958 5751023 Brighton Group

VT0375 MW002 former STP No 340957 5751021 Brighton Group

VT0375 MW003 Up-gradient of former STP


VT0375 MW217D former STP Yes 340888 5750873 Brighton Group

VT0375 MW217S former STP No 340888 5750874 Alluvial/Estuarine

VT0375 MW218 former STP Yes 340949 5750947 Brighton Group

VT0380 MW113 Former indoor swimming pool - buried landfill


W boundary MW203 Off-site to west No 339999 5752725 Brighton Group

W boundary MW210 Off-site to west Yes 340289 5752003 Brighton Group

W boundary MW211 Off-site to west No 340547 5751337 Brighton Group

W boundary: nearby

MW119 Up-gradient from on-Site sources


W boundary: nearby

MW202 Off-site to west & up-gradient from on-Site sources


Bores were selected for sampling in order to evaluate any changes in the nature and extent of PFAS plumes associated with the main Site sources of PFAS:

• Fire Ground and nearby wetlands along South Creek

• Fire Station / Ornamental Lake

• Marina area

• Closed Rifle Range Road landfill

• Former STP

• Sullage pit

Additional bores along the Base boundary were selected to provide ongoing data to evaluate whether PFAS-impacted groundwater was coming onto the Base or at locations hydraulically up-gradient from Site sources of PFAS. It is anticipated that the monitoring network may be augmented based on future developments and revisions of the PMAP.


The groundwater bores proposed to be omitted from on-going sampling were selected because the bores nominated for sampling would monitor the same groundwater pathway. Note that wells located at the closed Stony Point landfill (VT0001 wells) were dry during the DSI fieldwork. These wells should be gauged to evaluate whether these is sufficient groundwater is present that could be sampled.


4 Reporting on Monitoring

4.1 PFAS Screening Levels Screening levels for PFAS in water are presented in Table 7. These screening levels will be reviewed and updated (if necessary) as part of the OMP review process. Note that the DSI found that the only risk posed by Site PFAS was to ecological receptors with the MA. Screening levels for drinking water and recreation are included for reference.

Table 11 Screening levels for PFAS in water

Exposure Scenario PFOS PFOA 6:2FTS Guidance Original references GROUNDWATER (µg/L)

Human Health - Drinking Water Quality Guideline 4 0.07b 0.56 - HEPA (2018) Department of

Health (2017) Ecological Refer to surface water ecological guidelines

SURFACE WATER (µg/L)

Human Health - Surface Water Recreational 0.7b 5.6 50 HEPA (2018)

Dept. of Health (2017)

Jarman et al (2014) Human Health - Drinking Water Quality

Guideline 0.07b 0.56 - HEPA (2018) Department of Health (2017)

Fresh Water/ Marine (99% species protection) 0.00023c 19 - HEPA (2018)

ANZECC technical draft guidelines for fresh and marine

water quality a Defence Contamination Directive #8 Version 2 aligns with NEMP (HEPA, 2018), b Combined PFOS/PFHxS, c practical screening guideline of 0.001 µg/L based on typical current laboratory limit of reporting.

4.2 Reporting Requirements After each monitoring event, information collected during field activities and laboratory results should be documented in a report. The report will document the objectives, completed scope of work, results and findings from the monitoring event. Each monitoring report should include the following information:

Field activities undertaken

Compliance with OMP SAQP requirements

Findings from the gauging and sampling activities, including any changes to the monitoring network, such as access to sampling locations or damage to well heads

Figure showing the groundwater elevations and inferred groundwater contours for the uppermost Brighton Group aquifer and a posting of groundwater elevations for each gauged well

Comprehensive laboratory results presented in a table that includes the screening levels used to evaluate the PFAS results

Commentary on the field and laboratory QA/QC findings and results

Appendices with backing information including:

− Field sampling forms

− Chain-of-custody documentation

− Calibration certificates for field equipment

4 Drinking Water screening guidelines have been adopted for screening purposes for Industrial water use, Stock Water use and Agriculture/Parks/Gardens water use.


− Laboratory certificates

Interpretation of:

− Trends in groundwater levels, gradients and flow directions

− Nature and extent of PFAS concentrations across the MA including discussion where:

Detection of PFAS at sampling locations that had not previously had reported detectable PFAS, such as the boundary wells or some boundary drains with flows coming into the MA

− Trends in PFAS concentrations in groundwater and surface water with regards to:

Statistically based trends:

For example, for each monitoring location a Mann-Kendall statistic of trend could be calculated using the cumulative set of data (including results presented in the DSI report) once at least four consecutive results are obtained.

Interpretation of the statistical tests could then be used to justify cessation of monitoring at some locations or further assessment would be warranted (such as if an increasing trend is identified)

Completeness of pathways between Site sources of PFAS and receptors

If results reported for locations along a pathway, such as a creek or groundwater flowpath, reduce to below respective screening levels, then this finding could be used to justify removal or reduction in sampling frequency of those sampling locations from the monitoring program

Note that the current PFAS screening levels for water for 99% species protection are effectively set to the laboratory limits of detection

Hence, warning and action levels would not be relevant until the detection limits are reduced or the screening levels increased


5 Risk Profile Review Findings from the ongoing monitoring will be used to review the source-pathway-receptor linkages identified in the Site CSM and evaluate whether changes have occurred to the risk posed by PFAS-impacted groundwater and surface water across the MA. The evaluation will include the following:

Comparison of the nature and extent of PFAS plumes reported in the DSI report to the plumes inferred from the OMP sampling results

− In particular, if the plume is inferred to be expanding (based on PFAS being detected in wells outside the plumes shown on Figure 7 that had not previously had detectable PFAS), then further evaluation of those results should be undertaken

− This may include re-analysis by the laboratory, and / or collection of additional samples to confirm the results

Need to alter the monitoring program in light of implementation of management measures, such as remediation of Site sources of PFAS, which may include coordination of sampling events or changes to sampling locations in light of damage to the network or establishment of new sampling locations

Development of trigger levels for sampled groundwater and surface water with respect to PFAS concentrations reported in Hanns Inlet

− Current PFAS (as PFOS) concentrations in the western and central portions of Hanns Inlet are detected but at less than 0.1 µg/L, which reflects the current flux of PFAS entering Hanns Inlet via groundwater and surface water, which mixes with surface waters in Hanns Inlet

− Under the current flux of PFAS entering Hanns Inlet no risk to human health from eating fish caught in Hanns Inlet (although not allowed) was identified

− Hence, assuming similar discharge rates, if PFAS concentrations in groundwater and / or surface water decrease such that PFAS is no longer detected in Hanns Inlet, then there is justification for removing sampling locations along pathways that discharge directly into Hanns Inlet (such as wells in the marina area near the docks)

− Conversely, if PFAS concentrations in groundwater and / or surface water increase such that PFAS concentrations in the surface waters of Hanns Inlet increase significantly (that is, above 0.1 µg/L), sampling of fish may be warranted to evaluate whether PFAS concentrations in fish flesh or liver exceed respective screening levels


6 References Aurecon (2018) Investigation of per-and poly-fluoroalkyl substances at HMAS Cerberus, Detailed Site Investigation, prepared for Department of Defence.

Bureau of Meteorology (BOM) (2018), Monthly climate statistics – (#068361), viewed 17 April 2018, available at http://www.bom.gov.au/climate/averages/tables/cw_086361.shtml.

GHD (2016) Defence per- and poly-fluoroalkyl substances (PFAS) Environmental Management Preliminary Sampling Program Final Report, September 2016.

Golder Associates (2017) Further Groundwater Assessment RAN SSSS, May 2017.

Heads of EPAs Australia and New Zealand (HEPA) (2018) PFAS National Environmental Management Plan January 2018.

Lakey, R (1980) Hydrogeological Map of Western Port Basin.

NEPM ASC (2013), National Environment Protection (Assessment of Site Contamination) Measure 1999, (amendment 1, 2013), National Environment Protection Council, Canberra.

SKM (2009) The Victorian Aquifer Framework, Summary Report prepared for the Victorian Department of Sustainability and Environment, 1 December 2009.

http://www.bom.gov.au/climate/averages/tables/cw_086361.shtml


Figures

Figure 1 HMAS Cerberus – Site Location Figure 2 Management Area and Site Vicinity Figure 3 Site Details Figure 4 Surface water catchment (purple line) and topographical (black contours) map of HMAS Cerberus

where Site boundary is indicated by yellow line. Figure 5 Regional groundwater flow – Brighton Group aquifer. Figure 6 Inferred groundwater flow – Uppermost Brighton Group aquifer Figure 7 PFOS Groundwater Plumes Figure 8 Surface Water Features and Drainage Network Figure 9 Surface Water Monitoring Network Figure 10 Groundwater Monitoring Network


Figure 1 HMAS Cerberus – Site Location

Figure 2 Management Area and Site Vicinity


Figure 3 Site Details

Figure 4 Surface water catchment (purple line) and topographical (black contours) map of HMAS Cerberus where Site boundary is indicated by yellow line.

Figure 5 Regional groundwater flow – Brighton Group aquifer.


Figure 6 Inferred groundwater flow – Uppermost Brighton Group aquifer


Figure 7 PFOS Groundwater Plumes


Figure 8 Surface Water Features and Drainage Network


Figure 9 Surface Water Monitoring Network


Figure 10 Groundwater Monitoring Network

Aurecon offices are located in: Angola, Australia, Botswana, China, Ghana, Hong Kong, Indonesia, Kenya, Lesotho, Mozambique, Namibia, New Zealand, Nigeria, Philippines, Qatar, Singapore, South Africa, Swaziland, Tanzania, Thailand, Uganda, United Arab Emirates, Vietnam, Zambia,

Document prepared by Aurecon Australasia Pty Ltd ABN 54 005 139 873 Aurecon Centre Level 8, 850 Collins Street Docklands, Melbourne VIC 3008 PO Box 23061 Docklands VIC 8012 Australia T F E W

+61 3 9975 3000 +61 3 9975 3444 [email protected] aurecongroup.com

121 2 October 2018

122 2 October 2018

APPENDIX G References

Aurecon Australasia Pty Ltd (2018) Investigation of per- and poly-fluoroalkyl substances at HMAS Cerberus – Preliminary Site Investigation, Revision 2, Prepared for Department of Defence, July 2018.

Department of Defence (2018) Defence Per- and Poly-Fluoroalkyl Substances (PFAS) Framework – Construction and Maintenance Projects, version 1, 5 March 2018.

Heads of EPAs Australia and New Zealand (HEPA) (2018) PFAS National Environmental Management Plan January 2018

NEPM ASC (2013), National Environment Protection (Assessment of Site Contamination) Measure 1999, (amendment 1, 2013), National Environment Protection Council, Canberra.

Victoria Environment Protection Authority (2016), Incoming water standards for aquatic ecosystem protection: PFOS and PFOA, Publication 1633, State Government of Victoria, Melbourne.

Western Australia Department of Environment Regulation (2017), Interim Guideline on the Assessment and Management of Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS), Government of Western Australia, Perth.

Documents

HMAS Cerberus PFAS MANAGEMENT AREA PLAN · 2018-10-11 · PFAS Management Area Plan - HMAS Cerberus ... 2. Working to protect the community from exposure while management actions