CFA
Submission to the Environment and Natural Resources Committee Inquiry into the CFA Training College at Fiskville
March 2015
Contents PART A – EXECUTIVE SUMMARY ........................................................................................... 1
PART B – GLOSSARY OF TERMS ............................................................................................ 3
PART C – INTRODUCTION .................................................................................................... 4
Some critical dates ........................................................................................................... 6
PART D – ENSURING GOOD GOVERNANCE ............................................................................. 7
PART E - THE WELFARE OF CFA PEOPLE ................................................................................. 9
Short term measures ........................................................................................................ 9
Longer term measures .................................................................................................... 10
Water Testing ................................................................................................................ 16
PART F – SAFEGUARDING THE LOCAL ENVIRONMENT ........................................................... 18
Assessment work ........................................................................................................... 18
The clean up plan ........................................................................................................... 19
ATTACHMENT 1 ................................................................................................................ 22
CFA’s response to the IFI Report ...................................................................................... 22
ATTACHMENT 2 ................................................................................................................ 38
Human Health Risk Assessments ...................................................................................... 38
ATTACHMENT 3 ................................................................................................................ 44
Health studies ................................................................................................................ 44
ATTACHMENT 4 ................................................................................................................ 46
Water Quality Management Plans ..................................................................................... 46
ATTACHMENT 5 ................................................................................................................ 49
Fiskville site plan ............................................................................................................ 49
ATTACHMENT 6 ................................................................................................................ 50
Environmental assessment works ..................................................................................... 50
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PART A – EXECUTIVE SUMMARY This CFA Submission to the Environment and Natural Resources Committee’s Inquiry into the CFA
Training College at Fiskville aims to provide the Committee with up to date information about the
action taken by CFA following the commissioning of the Independent Fiskville Investigation (IFI).
The IFI was commissioned following media claims in December 2011 that fire fighters had been
exposed to harmful chemicals in practical fire fighting drills at the Fiskville Training College from the
early 1970s until 1999. The IFI was led by Professor Robert Joy, former Deputy Chairman of the
Environment Protection Authority, who undertook an independent and exhaustive investigation to
establish the facts surrounding the use of hazardous chemicals at Fiskville. His Report was published
in July 2012.
The IFI Report established that chemical contaminants that had been used in fire fighting training up
until 1999 could present a potential health risk for different groups of people at Fiskville and had
leached into the soil and surface water and that these chemicals were still present in water used for
training purposes in 2012 because the water was treated on site and re-used.
Following receipt of the IFI Report, the CFA Board adopted all the report’s recommendations and put
in place a detailed program to remediate the issues identified in the recommendations. This
Submission provides information about the actions taken by the CFA to address the contamination
identified by the IFI at Fiskville. The detail of information summarised in this Submission is available
through reports available on CFA’s website and the EPA’s website.
This Submission is structured around three themes that encapsulate CFA’s response to this
Parliamentary Committee. Those themes are as follows.
1. Good governance practices
The IFI Report highlighted a history of hot fire training at the CFA’s central training facility at
Fiskville for the period from the 1970s until 1999. Following receipt of the IFI Report, CFA’s
Board and senior executive adopted all the report’s recommendations as well as putting in
place 11 management initiatives aimed at ensuring good governance and high levels of
responsibility were taken for implementing the IFI Report’s recommendations.
These initiatives included bolstering the Board’s governance arrangements by establishing a
Board Health, Safety and Environment Committee whose membership included an independent
Member with relevant health, safety and environment expertise. CFA agreed to adopt National
and International standards for environmental management and the health and safety of its
people. An Independent Monitor was appointed to assess progress with, and the quality of, the
implementation of the IFI recommendations. CFA’s health services for its people were
expanded and a range of health studies and assessments were commissioned. Specialist staff
and senior managers were appointed.
These initiatives are described in more detail in Part D of the Submission.
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2. The welfare of CFA people is the Board’s first priority. CFA has an ongoing
commitment to the health, safety and welfare of CFA people and others affected by
past practices at Fiskville
In parallel with the commissioning of the IFI, CFA took a number of steps to meet the emerging
concerns of fire fighters, their families and the community by providing information and advice
on the IFI and steps that could be taken to address their health concerns. CFA’s CEO and the
Executive Director, Operational Training and Volunteerism, engaged with staff and major
stakeholders on a number of occasions to understand the concerns of its people and the wider
community so that it was possible to develop CFA’s approach to resolving those issues. The
strong emphasis on communications with CFA people and other interested parties continues.
As soon as the IFI Report was available, CFA established a plan of action to meet the needs of
people who had been identified as potentially exposed to hazardous chemicals at Fiskville. Five
human health risk assessments were undertaken to establish the type and level of risk faced by
CFA people (both those living at Fiskville and those who were there for short periods of time),
local community members and those who used Lake Fiskville for recreational purposes or who
lived downstream from Lake Fiskville. These studies were extensive and broke new ground in
assessing the human impact of specific chemical contamination of surface water and soil.
The outcomes of these studies are addressed in Part E.
Additionally, two major health studies into the incidence of cancer were undertaken.
Also in 2012, CFA stopped using recycled water from the various dams at Fiskville for training
purposes and has since only been using mains water.
Part E of this Submission addresses these matters.
3. The local environment is to be safeguarded and action taken to correct
environmental damage
The final Part of this Submission, Part F, outlines the works that CFA commissioned to assess
and respond to the environmental impact of the historical use of hazardous chemicals.
Following the release of the IFI Report, the EPA subsequently issued two clean up notices which
meant that CFA needed to re-scope the remedial work it had commissioned to ensure it would
satisfy the EPA’s requirements. An EPA appointed Auditor was engaged by CFA to oversee the
clean up plan and audit the assessments and remediation work.
Eleven studies have now been completed and findings are set out in Attachment 6.
The EPA requires that the clean up work be completed before June 2017 so that another audit
by the EPA appointed Auditor can determine whether the works have been sufficient to satisfy
the EPA’s requirements and remediate the issues that were the subject of the clean up notices.
The clean up plan is being managed in six stages, with two stages (initial containment and off
site works) now complete. Work is in progress on site assessments, remediation and updating
plans and procedures. Monitoring will be ongoing.
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PART B – GLOSSARY OF TERMS
Abbreviation Meaning
Auditor Mr Darryl Strudwick of AECOM
BOD Biochemical oxygen demand
Cardno Cardno Lane Piper
CFA Country Fire Authority
CHW Central Highlands Water
Committee The Environment and Natural Resources Committee of the Parliament of Victoria
EPA Environment Protection Authority Victoria
Fiskville CFA Fiskville Training College, 4549 Geelong-Ballan Road, Fiskville, Victoria
FLP Flammable Liquids PAD
FMA Fuel Mixing Area
HSEMS Health Safety and Environment Management System
HHRA Human Health Risk Assessment
HSE Health Safety and the Environment
Independent Monitor Mr Kieran Walsh (retired Deputy Commissioner, Victoria Police)
IFI Independent Fiskville Investigation into chemical use at Fiskville chaired by Robert Joy between December 2011 and June 2012
IFI Report Understanding the Past to Inform the Future, Report of the Independent Fiskville Investigation, June 2012
ITFP Informing the Future Program
OHS Occupational Health and Safety
PAD Practice Area for Drills
PFCs Perfluorinated compounds
PFOA Perfluorooctanoic acid
PFOS Perfluorooctanesulfonic acid
PPE Personal protective equipment
SAQP Sampling and Analysis Quality Plan
SEPP (WoV) State Environment Protection Policy (Waters of Victoria)
SOP Standard Operating Procedure
TPH Total petroleum hydrocarbons
VUT Victoria University of Technology
WQMP Water Quality Management Plan
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PART C – INTRODUCTION CFA purchased the property at Fiskville in 1971. It had been used by AWA Ltd as a communications
facility. The facility was opened for training in 1972. The technologies and materials used at Fiskville
changed over time, with early reliance on donated chemical materials for fire ground training. Some
of the materials used in the past, such as paint, contained chemicals that are now known to be
hazardous. As at March 2015, 79 people worked at Fiskville. Over the period of its operation, tens of
thousands of people were trained at Fiskville. Trainees came from a wide range of agencies,
including police, emergency service workers, MFB members and members of fire services from other
States and Territories. It was CFA’s primary training ground. On 26 March 2015 the CFA Board
resolved to close the Fiskville Training College.
The Environment and Natural Resources Committee of the Parliament of Victoria is conducting an
Inquiry into the CFA Training College at Fiskville. The Terms of Reference provide the following scope
for the Inquiry:
1) a comprehensive historical study of pollution, contamination and unsafe activities at Fiskville
between 1970 and the present day
2) a study of the health impacts on employees, residents and visitors between 1970 and the
present day
3) a study of the role of past and present executive management at Fiskville
4) an assessment of the feasibility of decontamination/rectification of the training site
5) recommendations as necessary to mitigate ongoing harm and to provide justice to victims
and their families.
This Submission focuses primarily on the actions CFA took in response to the Independent Fiskville
Investigation (IFI). This investigation was commissioned by CFA in response to media claims in
December 2011 that fire fighters had been exposed to harmful chemicals used in practical fire
fighting drills at the Fiskville Training College between the early 1970s and 1999. The IFI Report
focussed on the 1970s to 1990s period because the use of hazardous chemicals on the PAD was
discontinued in 1999. After this date the fuels used on the PAD were petrol, diesel and LPG.
The IFI, led by Professor Robert Joy, looked at historical use of chemicals for live fire fighting training
at Fiskville between 1971 and 1999. Professor Joy’s report, “Understanding the Past to Inform the
Future” (the IFI Report) was published in July 2012. Professor Joy had all the resources he required
to conduct the IFI and he was free to make whatever enquiries of CFA members, past and present,
that he considered necessary. He also commissioned a number of environmental studies of Fiskville.
In addition PriceWaterhouseCoopers was retained by CFA to assess the level of independence of the
IFI team and was able to confirm that independence.
The ten IFI Report recommendations were:
1. That soil and groundwater quality be assessed in areas where fuel storage tanks are
currently located or have been located in the past both above and below ground
2. That groundwater investigations be undertaken in the vicinity of: the historical FLP, the FMA,
the historical foam training pits, the prop storage area and the area used to rehabilitate
contaminated soils in 1998
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3. That further investigation be undertaken into surface water in and discharging from Lake
Fiskville to
a. better quantify the risk to downstream human health receptors, taking into account
downstream dilution and environmental fate and transport mechanisms
b. investigate potential sources of PFOA and PFOS discharges to Lake Fiskville and
identify potential means of reducing PFOA and PFOS concentrations in Lake Fiskville
and discharging off site, if the potential risk of adverse impact on downstream
human health receptors is found to be unacceptable
c. collect surface water samples at a representative location to assess whether the
reported copper and zinc concentrations are consistent with background levels and
d. assess the ecological condition of Lake Fiskville
4. That any electrical transformers located at any CFA training site be inspected by an
independent hygienist and, if not able to be certified as PCB-free under the National
Polychlorinated Biphenyls Management Plan 2003, that it be treated as a scheduled waste
and disposed of in accordance with the provisions of the Plan
5. That any subsequent study of possible linkages between exposure of persons during training
at Fiskville to materials such as flammable liquids and health effects evaluate the usefulness
of the qualitative assessment of relative risk of exposure of different groups developed in
Chapter 7
6. That procedures be put in place to protect the health of personnel potentially exposed to
water and sediments in Dams 1 and 2 of the firewater treatment system and, in particular,
to manage the risks to individuals who have the potential to come into contact with
sediments in the dams during routine maintenance
7. That soil and groundwater quality be assessed in the following areas that were not examined
during the site investigation stage of the Preliminary Site Assessment of Fiskville carried out
by Golder
a. Part of Drum Burial Area 1 (south of the Airstrip and south of Deep Creek Road)
b. Drum Burial Area 2 (north of the Administration Building)
c. Drum Burial Area 3 (east of the Administration Building)
d. Historical landfills 1 and 2
8. That historical landfill 1 which has been disturbed by the construction of a walking track
needs to have its extent clearly identified, have an appropriate impermeable and properly
drained cap constructed and be revegetated with shallow rooting species that will not
compromise the integrity of the cap. This should ensure the safety of any people using the
walking track
9. That any decision on the future management of historical landfill 2, including possible
exhumation of buried drums and further site rehabilitation, await the results of soil and
groundwater quality assessment at the site (Recommendation 7)
10. That the site specific recommendations of the Golder Associates' Preliminary Site
Assessment – CFA Regional Training Grounds be adopted including recommendations to
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a. undertake targeted soil and groundwater investigations at sites where possible
sources of contamination have been identified
b. assess fire fighting water quality for contaminants associated with flammable liquids
and extinguisher foams
c. assess water quality where discharges occur to the environment.
On receiving the IFI Report, the CFA Board adopted all its recommendations and supported the
establishment of a detailed implementation strategy and the management initiatives discussed in
Part D. CFA’s response to the IFI Report is at Attachment 1.
The central themes of this Submission are around how CFA responded to the IFI and the focus given
to both the welfare of people and safeguarding the environment. This Submission specifically
addresses:
1) CFA governance in responding to the IFI Report
2) The welfare of CFA people and others that may have been affected by Fiskville
3) Safeguarding the local environment.
Some critical dates 1971 Fiskville was acquired and the Fiskville Training College was established as an
important training facility for fire fighters. Training commenced at the site in
September 1972.
1996 Flammable liquid PAD, tank and clover leaf props deemed unsafe and closed
(Dangerous goods OH&S environmental audit).
1999 Second PAD redevelopment, sealing of PAD surface and move to LPG for approximately 70% of drills, water system treatment complete, construction
of third dam, site remediation.
2007 Fiskville stops using B Class foams with PFOS.
December 2011 Media reports raised concerns about possible health impacts arising from
training practices, dating back to the 1970s.
December 2011 CFA commissioned Professor Robert Joy, former Deputy Chairman of the
Environment Protection Authority, to undertake an independent and
exhaustive investigation to establish the facts surrounding the use of
hazardous chemicals at Fiskville.
June 2012 CFA received the IFI Report.
July 2012 CFA commenced a program of work, including its 11 management initiatives,
to implement the recommendations of the IFI Report.
December 2014 The Government announced a Parliamentary Inquiry into the CFA Training
College at Fiskville.
2 March 2015 CFA suspends training at Fiskville.
26 March 2015 CFA Board resolved to close the Fiskville Training College.
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PART D – ENSURING GOOD GOVERNANCE CFA accepted the facts, conclusions and recommendations established in the IFI Report. In June
2012 the CFA Board undertook to take action to demonstrate its ongoing commitment to the health,
safety and welfare of CFA people and others affected by past practices at Fiskville, and to care for
the environment by fully implementing the IFI Report recommendations and by improving
governance and management capabilities and processes.
The Board accepted that Professor Joy established the facts relating to the procurement, handling,
storage, and exposure of people to hazardous chemicals at Fiskville between 1971 and 1999, to the
extent that it was possible to do. There were limitations arising from the passage of time and lack of
detailed information about donated materials used at CFA fire training grounds, which means that a
full account of events at Fiskville was not possible. Nevertheless, the IFI is based on the best
available information about conditions at Fiskville over that period.
Supporting CFA’s determination to implement the recommendations effectively, CFA arranged for
the implementation of recommendations to be monitored by an Independent Monitor. Much of the
work undertaken by CFA also needed to meet the requirements of clean up notices issued by the
EPA and was therefore subject to mandatory auditing by an EPA appointed Auditor. Reports from
the Independent Monitor and mandatory audits provide for rigour and transparency. The
Independent Monitor and the EPA appointed Auditor’s mandatory audit reports are available
through the CFA’s and EPA’s websites respectively.
The IFI Report found that past poor management practices concerning the use of potential
hazardous materials reflected a culture that did not give health, safety and the environment a high
priority. To ensure that CFA people and the wider community can have confidence in CFA's ability to
respond effectively to the IFI Report and to any future issues, the CFA Board endorsed the following
11 management initiatives to:
1. establish a Board Committee for Health Safety and Environment on 1 October 2012,
including an independent Member with relevant expertise. The Committee continues to
operate in 2015.
2. implement international standard ISO14001 for Environmental Management along with
national standard AS4801 for Occupational Health and Safety in the first instance at Fiskville
and all other training grounds. The aim of adopting these recognised standards is to ensure
that CFA people and the community can have a high level of confidence in CFA training and
management practices at CFA training grounds. This work is in progress.
3. establish a standing item on Board agendas for reports from the Committee for Health
Safety and Environment on implementation of the IFI recommendations.
4. appoint an Independent Monitor (which occurred in February 2013) to monitor and assess
the implementation of the IFI recommendations. The Independent Monitor’s report is
available on CFA’s website.
5. extend CFA’s Health and Welfare Service for those who may have been affected by activities
at Fiskville, including by way of health monitoring for those identified in the high and
8
medium risk exposure groups. This program commenced in August 2012 and will continue
for a period of 5 years.
6. commission health impact studies to examine the linkages between the risk of exposure to
hazardous materials at Fiskville and health effects. A statistical analysis of the incidence of
cancer experienced by firefighters who were trained at Fiskville, by the Cancer Council
Victoria was received on 18 June 2014 and a Monash University Report was provided in
November 2014.
7. provide information packs to CFA members and families outlining available support services
available. This commenced in July 2012.
8. provide information packs to the public which incorporate details on accessing community
based services. This also commenced in July 2012.
9. acquire specialist personnel around environmental management to support personnel who
are already working on health and safety, and increase the presence across the State around
HSE. A Health and Safety Adviser – Training Campuses was appointed on 13 May 2013. CFA
currently has 10 HSE staff (HSE team leader, 5 Regional, 2 Directors and 2 general staff) who
have completed a Certificate 4 in environmental management conducted by Absob Training.
CFA also relies on a broad number of environment consultants for impartial, expert advice.
10. allocate the executive responsibility and management and control for all training grounds
with the Executive Director Operational Training and Volunteerism. The transition of
executive responsibility from the Human Resources Directorate of all Regional Training
Campus staff was completed by 1 July 2013.
11. appoint a Program Manager and Program Officer in August 2012 to provide high level
project management capability for the implementation of recommendations.
In summary, the March 2015 status of the implementation of recommendations and initiatives of
the IFI Report is as follows:
seven of the ten IFI recommendations have been completed (Recommendations 8, 9 and 10
are still in progress)
ten of eleven management initiatives have been completed (AS4801 / ISO14001 are still in
progress).
In early December 2011 CFA initiated a detailed communications plan so that CFA people and
external stakeholders were aware of the action being taken by CFA. The communications plan also
enabled CFA to be open to the concerns of its people and stakeholders. The main activities of this
plan were:
a CEO’s blog that is available through the CFA website. The blog is emailed to staff, and
Regional Directors distribute it to local brigades
face to face meetings with CFA people at Fiskville by both the CEO and the Executive
Director, Operational Training and Volunteerism
CEO Updates were provided periodically to external stakeholders.
Further discussion of the implementation of the IFI Recommendations is in Parts E and F of this
Submission.
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PART E - THE WELFARE OF CFA PEOPLE The IFI found:
for one group of staff (the PAD operators), the risks of exposure to flammable liquids were
significant and considerably greater than for other groups
instructors working full-time at Fiskville were the group most exposed to products of
combustion, foam and fire water
part-time instructors had experienced the same types of acute exposures as the full-time
instructors, but the frequency of such exposure was considerably less
trainees’ frequency of exposure was significantly less again
exposure of other Fiskville staff and residents, including children, to chemicals, products of
combustion, foam and firewater was negligible or very low and exposure of persons off-site
was negligible. The key exposure of staff, residents, the people at the primary school and
neighbours was to occasional smoke and particulate fall out.
CFA undertook short term and long term measures to understand and reduce risk to human health
following the receipt of the IFI Report. Water Testing protocols have also been reviewed and
upgraded.
Short term measures Immediately following the December 2011 allegations, CFA took steps to enhance existing health
and wellbeing services to provide targeted support to members and their families affected by the
allegations, as well as to members of the public, or other organisations, who may be affected. CFA
recognised that proactive support was critical to the appropriate management of individuals'
concerns.
CFA established a small dedicated Health & Welfare Coordination Team, comprised of members of
the Health & Safety and Wellbeing Teams within the People and Culture Directorate. The team
worked closely with other groups within the organisation to support the initial response. The
objectives were to:
a) provide a health and wellbeing information hotline service for people with concerns about
the allegations of use of and potential exposure to hazardous chemicals used in fire fighting
practices at Fiskville from 1971
b) support the process of identifying those individuals and groups at risk due to use of and
potential exposure to hazardous chemicals
c) provide coordinated health and welfare advice to those who believed they may be at risk or
have health concerns due to use of and potential exposure to hazardous chemicals
d) provide coordinated medical and welfare assessment to those identified as potentially at
risk and in conjunction with the Compensation Claims function
e) where requested, providing welfare support services to members, past members and their
families giving evidence to the IFI
f) effectively communicate and engage with internal and external stakeholders about health
and welfare factors associated with the IFI
g) provide communications and regular updates to all individuals requesting information
h) establish and maintain a complete case management system that captured all relevant
information to enable ongoing support of those identified as at potential risk
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i) establish a database utilising existing incident reporting and health monitoring protocols to
record, track and support people following the conclusion of the IFI.
The team also conducted research to inform CFA’s approach and in particular referenced “Sealing a
just outcome: Report from the Inquiry into RAAF F-111 Deseal/Reseal Workers and their families”1.
This report provided CFA with useful information in the establishment of policy and practice in its
response to the Fiskville allegations and subsequent IFI findings and recommendations.
The specific health and welfare support provided to members, past members and their families
included:
a) access to counselling services (psychologist, chaplain, peer etc.) leading up to, during and
following any meetings/interviews
b) access to medical advice or assessments as appropriate
c) transport to and from any meetings, interviews, medical assessments
d) overnight accommodation, if required
e) provision of meals where required to attend authorised meetings or appointments relating
directly to the alleged exposures at Fiskville
f) reimbursement to employers/members for any lost salaries or wages as a consequence of
involvement in the IFI process
g) any other appropriate support as is necessary.
Longer term measures The longer term measures were designed to enable judgements to be made and action to be taken
to mitigate human health impacts and risks to human health.
Based on extensive investigation of the contamination associated with Fiskville (discussed further in
Part F below) five human health risk assessments (HHRA) were undertaken. The reports on these
HHRAs were commissioned in 2012 and received in March 2014. The long lead time arose because:
the underlying data collection was time consuming
an environmental Auditor was not appointed until early 2013 when the EPA clean up notices
were issued. The Auditor needed to undertake some independent data collection and form
independent conclusions. The Auditor also needed to review and assess the data collected
by the consultants, Cardno. The audit process necessarily took time and required
deliberation between the consultants and the Auditor
there was some change in scope of the original study design that arose from the findings of
the underlying data collection
some of the HHRAs were breaking new ground and required peer review
In addition, CFA could not release the reports until the audit was completed. All reports are
available on the EPA website.
Summaries of the HHRA, related findings and CFA action are set out below. Further information
about them is at Attachment 2. The full reports are available on the EPA's website.
1 Joint Standing Committee on Foreign Affairs, Defence and Trade. (2009). The Parliament of the Commonwealth of Australia.
Canberra.
11
HHRA 1 was designed to estimate the potential for impacts upon the health of:
PAD workers and other potentially exposed individuals to water and sediments during hot
fire training
other individuals (e.g. members of the community) related to potential exposures to water
discharged offsite.
The findings were:
For workers involved in fire fighting training
The concentrations of PFCs in the blood serum of PAD instructors (those with highest
occupational exposure) were at least 2 orders of magnitude below the total PFC
concentration deduced from the literature, not to be associated with health effects in
workers.
Exposure to PFCs during fire fighting training had not resulted in an increase in serum
concentrations above those expected in the background (ie resulting from exposures in
everyday living).
Health effects from exposure to PFCs during fire fighting training were very unlikely to be
experienced by PAD instructors. By extension, less exposed workers, including recruits,
were also at low health risk.
The blood serum data confirmed the conclusions of the quantitative modelling of a very
low health risk from PFC exposure during fire fighting training. Further, the data
confirmed that the worst case scenario overestimates exposures and should not be
referred to in making conclusions on health risk.
For maintenance workers
Risks to maintenance workers from exposure to PFCs and TPHs are considered negligible,
assuming that these workers employ appropriate OHS practices in line with Fiskville
procedural requirements and use PPE that prevents or minimises exposure.
Microbial risks
The Quantitative Microbial Risk Assessment identified potential microbiological risks if
untreated water from dams was used in training drills, due to the possible presence of a
range of microbes, including endotoxins, algal toxins, opportunistic microbial pathogens
and enteric microbial pathogens. This risk is present in any dam/lake/waterway, and is
not related to contamination.
In response CFA:
revised dam maintenance activities to achieve minimal contact with dam water and
sediments
introduced protocols for workers and visitors so as to avoid contact with dam water
stopped using dam water for fire fighting training and is solely used town mains water
put plans in place for routine monitoring of algae as part of the ongoing Water
Management Plan.
HHRA 2 was designed to identify risks to any people with access to Lake Fiskville for recreational
activities, to estimate the potential for impacts upon people of the Fiskville community from
exposures to chemicals in water in Lake Fiskville.
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The report concluded that the risks estimated for people from the Fiskville community
potentially exposed to PFCs present in water or fish and rabbits caught on-site were
considered negligible.
There were no recommendations arising from this HHRA, however CFA:
banned recreational activities (e.g. fishing, swimming) in water bodies at Fiskville. Lake
Fiskville and the dams have been fenced and signposted accordingly
required management authorisation for hunting activities
investigated feasible options for remediation of water bodies at Fiskville including Lake
Fiskville
developed a water management strategy to provide clean water and treat contaminated
water generated during training
altered the training program at Fiskville to minimise the potential contaminant load into
Lake Fiskville
constructed a bypass channel to divert Beremboke Creek around Lake Fiskville, thereby
preventing its flow through Lake Fiskville and minimising discharges from the Lake.
HHRA 3 was designed to identify risks to downstream users of the creeks and the Moorabool River,
and estimate the potential for impacts upon the health of persons exposed to contaminants
discharged to the downstream creeks.
The scope was expanded during the course of the investigation to assess risks to downstream
users who are potentially exposed (directly or indirectly) to wind-blown materials such as foams
and/or spray drift and any potential resultant impacts.
The report concluded that the risks calculated for downstream users potentially exposed to
PFCs present in water, fish and/or rabbits are considered negligible. There were no
recommendations for CFA action.
HHRA 4 was a qualitative assessment of risk to human health performed for the water sources
(potable water, process water and recirculated water) at Fiskville to provide a set of criteria for a "fit
for purpose" non-potable and sustainable water quality suitable for use in fire-fighter training.
HHRA 4 also established a process for monitoring and accepting water for use in fire fighting training
or off-site discharge which CFA can incorporate into a Water Quality Management Plan adaptable
for each training ground.
The report concluded that the health risks due to exposure to potable water are negligible as
the water is treated prior to supply (assuming that potable water is used immediately and not
held in on-site storages for a length of time that would cause the chlorine levels to fall below
0.5mg/L). The report provides a proposed set of conservative water quality criteria against
which to monitor and assess fire training water for human health and for discharge to the
environment.
The criteria proposed were selected and/or derived for hot fire training and include:
Treatment Management Levels – criteria used to monitor the performance of the water
treatment system. They were designed to meet water quality objectives for industrial
use of reclaimed waters (EPA Victoria, 2003).
OHS Risk Based Targets – criteria derived to protect the health of CFA Training Personnel
for select compounds (organic and inorganic chemicals) and microbial pathogens.
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Environmental Discharge Criteria – used for the protection of the ecology of the surface
water bodies to which water can be discharged. These are primarily based on established
guidelines in Australia (ANZECC 2000) and SEPP WoV.
HHRA 5 assessed the PFOS concentration in sheep resident on a farm adjacent to Fiskville to become
better informed about the ratio of PFOS in serum, muscle, liver and kidney of sheep and assess the
risk to public health and food safety related to the consumption of meat from those animals. As one
of the largest field studies undertaken anywhere in the world that investigated PFC levels in
domestic animals raised for human consumption, this study broke new scientific ground and was a
peer reviewed.
The report2 found:
minimal impact to soil and grass. The exception is the creek, and its flood plain between
Lake Fiskville and the twin dam on the farm at the north-western boundary. The upper
portion of this farm dam has high concentrations of PFCs within it and is considered to be
the primary source of PFCs in sheep on the property
areas around the farm homestead and the water supply for the homestead are not
impacted
soil PFC concentrations and concentrations in the farm dam are safe for persons working
on the farm providing there is not frequent direct contact with farm dam water or high
degree of immersion in it. Although the dams are unlikely to sustainably support
frequent collection of large yabbies, these animals can potentially accumulate high
concentrations of PFCs. It is therefore suggested that advice be provided to the
landowner that consumption of yabbies from the dam not occur
for a range of consumption scenarios it is concluded there is negligible risk to public
health. There is also low health risk associated with assumed high meat intake by a
subsistence farmer
The ewes on the farm have low amounts of PFOS in their serum, which are similar to
background concentrations in human serum. These levels do not appear to have affected
either the welfare or productivity of the animals. By analogy with the lamb HHRA it is
concluded that culling ewes for human consumption is associated with negligible health
risk.
On 18 October 2013 Victoria's Acting Chief Health Officer advised that "based on the
evidence, this incident [the detection of PFOS in sheep] poses no public health or food safety
risk”.3 HHRA 5 notes that, on 15 November 2013, Dr Drew provided an update on the
outcomes of the tests of the farm soil, grass, water, sheep and lambs at an interagency
meeting held by Department of Health that reinforced the earlier findings.
The Summary Report4 found:
The concentrations of PFCs in the blood serum of PAD instructors (those with highest
occupational exposure) are at least 2 orders of magnitude below the total PFC
concentration deduced from the literature, not to be associated with health effects in
workers.
2 Health impact assessment from consumption of lamb produced near CFA Fiskville training ground. ToxConsult. 15 May 2014. 3 Email to CFA dated 18 October 2013 4 Summary Report – Human Health risk Assessment – CFA Training Personnel 4549 Geelong-Ballan Rd, Fiskville Victoria.
Cardno, March 2014
14
Exposure to PFCs during fire fighting training has not resulted in an increase in serum
concentrations above those expected in the background (ie resulting from exposures in
everyday living).
Health effects from exposure to PFCs during fire fighting training are very unlikely to be
experienced by PAD instructors. By extension, less exposed workers including recruits
are also at low health risk.
The blood serum data has confirmed the conclusions of the quantitative modelling of a
very low health risk from PFC exposure during fire fighting training. Further, the data
confirms (as expected) that the worst case scenario overestimates exposures and should
not be referred to in making conclusions on health risk.
In addition to the five HHRAs two major pieces of research were commissioned by CFA. Further
details of these studies can be found in Attachment 3.
I. A statistical analysis of cancer risk experienced by firefighters who were trained at Fiskville
The objective was to perform an analysis of cancer risk for CFA fire fighters that may have
arisen from past practices undertaken at Fiskville.
Overall, this cohort of 599 fire fighters, control matched with the Victorian Cancer Registry,
were assessed against two reference populations. The report found that “overall, this cohort
of fire fighters did not have an increased incidence of cancer”5.
Limitations of this study are further discussed in Attachment 3.
II. Fiskville Firefighters' Health Study, Department of Epidemiology and Preventative Medicine,
Monash University, November 2014. The objectives of this study was to investigate the risk of
cancer and mortality for individuals grouped according to the IFI Report as being likely to have
had a high, medium or low risk of chronic exposure to a variety of materials (Recommendation
5).
The cohort examined comprised 606 people, including three women, and had 95 men in the
high group, 256 men in the medium group (105 career firefighters and 151 volunteer
firefighters) and 252 men in the low group. The cohort was linked to the National Death Index
and Australian Cancer Database (both held by the Australian Institute for Health and Welfare)
and to the Victorian Cancer Registry.
The findings were:
no deaths or cancers were identified for the three women in the cohort
there were 28 deaths and 69 cancers identified among the men in the cohort
when compared to the Victorian population, higher than expected cancer rates were
observed for:
o melanoma and cancer of the testis in the high risk group
o brain cancer in the medium risk group
when compared to the Victorian population and to the Australian-born Victorian
population, the overall cancer risk was:
o significantly raised for the high risk group
5 An analysis of cancer risk experienced by firefighters who were trained at Fiskville. Cancer Council of Victoria. 18 June 2014
15
o similar for the medium group
o significantly reduced for the low group
When compared to the low risk group, there was a statistically significantly increased
cancer risk for the medium and high groups, but the number of cancers in the low group
was very small, resulting in a lot of imprecision in the results and this is likely to impact on
the robustness of these findings
When compared to the general Australian population, the overall mortality was
statistically significantly decreased for the whole cohort and for the low and medium
groups. This reduction in mortality may be due, at least in part, to the healthy worker
effect. For the low risk group and the volunteer firefighters in the medium risk group in
particular, the low mortality may also be a result of an ascertainment bias, that is, some
individuals who had died may have been less likely to have been identified and included
in the cohort. It is also possible however, that those individuals who died of cancer were
more likely to be recalled than other individuals who had died of other diseases. The
mortality for the career medium group and the high group was also reduced but not
statistically significantly so.
Limitations of this study are further discussed in Attachment 3.
CFA has also worked closely with WorkSafe, which has visited Fiskville more than 60 times in the
period 28 July 1999 to 10 February 2015. The type of Worksafe visits in this period included:
a) undertaking investigations into reported injuries
b) undertaking inspections in relation to OHS protections and systems on site, and compliance
with applicable standards and laws
c) provision of advice regarding content and method of provision of training courses provided
by CFA
d) assessing compliance with Provisional Improvement Notices (PIN’s) issued by health and
safety representatives
e) for the purposes of industry based prevention programs involving general inspections across
multiple sites.
Following identification of historical practices at Fiskville in 2012, numerous onsite inspections and
meetings occurred and significant documentation was provided to Worksafe. WorkSafe monitored a
range of remediation works at Fiskville, including those related to two independent hygienist
assessments that occurred. CFA agreed to a range of improvements over the period of WorkSafe’s
involvement and worked cooperatively to resolve these. Some of the measures implemented
included:
a switch to mains water for fire fighting training water
fencing of PAD and dams 1-4
installation of signs along perimeter fence for PAD and dams 1-4
bunding in area of 2,200 litre diesel tank to prevent contaminants entering the pit pending
permanent solution for relocation of tank (relocation no longer required given installation of
above ground tanks for storage of mains water)
updating of PAD Safety Briefing to address access to dams
updating of, and training in respect of, Incident Notification/Summary reports
development of job safety analysis reports for taking of water samples by CHW
16
updating of water sampling procedures and Water Criteria and Management Plan
risk assessments for dams 1-4 looking at emergency response rescue procedures, installation
of landing site for dams 1 and 2 and further induction training development
ALS Water Reuse Investigation Report (February 2012).
A WorkSafe entry in 2013 followed a request for an inspector to deal with an alleged health and
safety issue associated with the impact of foams on cattle drinking troughs and on the collection of
drinking water on an adjoining private property. The inspector was advised of CFA's precautions for
handling foams (PPE and relevant policies); email notifications to various people, including
neighbours, of CFA's training schedule (with opportunities for concerns to be raised with the
Training Centre which CFA noted at the time had not been utilised); and monitoring of
environmental conditions and changes to program if necessary as a result of those prevailing
conditions. CFA agreed that foam on Dam 1 was to be tested for contaminants and Worksafe was to
be made aware of the results. Cardno undertook this testing and provided a report to CFA in January
2014 which concluded that it is “highly unlikely that wind-blown foams would cause any harm to the
residents on adjoining properties as a result of potentially contaminating rain fed drinking water
supplies in water tanks”6.
In 2013-14 WorkSafe conducted an investigation under section 131 of the Occupational Health and
Safety Act 2004 (Vic) following a formal request from an external party to investigate and prosecute
CFA regarding historical practices associated with alleged exposure of employees to chemicals and
organisms. WorkSafe undertook detailed investigations into alleged offences at Fiskville and
determined that there was insufficient evidence to prosecute.
WorkSafe is currently involved in reviewing water quality as a result of the identification of PFOS in
the hydrants on the PAD.
Water Testing CFA implemented a formal Water Management Plan in March 2008, which was most recently
amended in 2012. A Draft Water Quality Management Plan was produced by Cardno for CFA in
March 2014. Further discussion of the 2008 plan and testing outcomes between the implementation
of that plan and 2014 is at Attachment 4.
The purpose of the Draft WQMP was to provide a guideline for the management of water quality
used in fire training at Fiskville, to ensure that water quality was suitable and protected the health
and safety of CFA personnel and the environment. The WQMP was not implemented at Fiskville
because mains water was being used for training activities. Cardno prepared the Draft WQMP with
the intent of CFA customising and implementing it once the remediation works were complete and
the new water treatment plant was installed and water was being re-circulated for use in training.
The draft WQMP was intended to:
identify the roles and responsibilities of personnel involved in hot fire training water supply
and treatment at Fiskville
describe the water system at Fiskville including water supply and treatment facilities
6 Wind Blown Foam Assessment – CFA Fiskville. WorkSafe Entry Report – Reference No V01011101740L. Cardno. 24 January
2014.
17
summarise water quality criteria (WQC) appropriate for fire training water, and presented this
in a manner that allowed a progressive implementation of management responses in the
event that water quality indicators started to move outside the ideal ranges for use in fire-
fighting training or discharge to the environment (a "traffic light system"). This approach
organised the WQC into groups relative to two levels of Water Quality Triggers (WQT).
Generally, the WQT are the recommended maximum values which should not be exceeded
set out key water monitoring (continuous or quarterly depending on parameter in question)
and relevant control actions if the WQT are exceeded, including water sampling and testing
requirements, switch to potable water only with no recirculation and no reuse or cessation of
fire-fighting training and discharges to the environment
set out documentation, reviews (at least every 2 years) and record keeping requirements
relevant to the draft WQMP.
The draft WQMP was written and based on the understanding that:
the water for fire fighting training at Fiskville is initially sourced from potable water (namely,
town water mains)
water collected from the PAD area is to be treated onsite (via a new water treatment plant),
stored, reused as recirculated water or process water, and potentially disposed of to the
environment, all subject to appropriate approvals
recirculated water is stored in appropriate holding tanks, but do not incorporate the water
treatment Dams 1 to 4 formerly used to store and treat effluent from the PAD
water recirculation does not include any water from the Dams nor Lake Fiskville that
potentially contain contaminants including PFCs.
The Draft WQMP also set out the materials approved for use on the PAD.
During site assessments carried out by BlueSphere in January 2015 (to determine the scope of
remediation works around the PAD), an unexpected test result from two of the hydrants on the PAD
was obtained.
Further water testing in March 2015 revealed PFOS at additional sites that were not associated with
the domestic water supply. On 26 March 2015 the Board determined to close Fiskville permanently.
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PART F – SAFEGUARDING THE LOCAL ENVIRONMENT In July 2012 CFA engaged environmental engineering firm Cardno to undertake assessments and
prepare formal reports to respond to the IFI Report recommendations. Cardno engaged the services
of eminent Australian toxicologist, Dr Roger Drew, to provide extensive expertise and assistance. As
much of Dr Drew's work on these assessments is leading science, a second eminent Australian
toxicologist, Professor Brian Priestley, was also engaged by CFA to peer-review Dr Drew's work.
Following the engagement of Cardno, in January 2013 the EPA issued two clean up notices under
Sections 53V and 53X of the Environment Protection Act 1970 (Vic) to the CFA in relation to Fiskville.
These clean up notices were updated in December 2013. As a result of the clean up notices the
planned assessment and remediation work was adapted to meet the requirements of the clean up
notices and to provide a clean up plan. Both the clean up notices are subject to mandatory auditing.
The section 53V audit has been completed. The section 53X audit will be done following the
completion of remediation works.
As with the HHRA work outlined in Part E there was a long lead time between the original
commissioning of this work and making the study outcomes public because:
the underlying data collection was time consuming
an environmental Auditor was not appointed until early 2013 when the EPA clean up notices
were issued. The Auditor needed to review and assess the data collected by the consultants,
Cardno. The Auditor also needed to undertake some independent data collection and form
independent conclusions. The audit process necessarily took some time and required
deliberation between the consultants and the Auditor
there was some change in scope of the original study design that arose from the findings of
the underlying data collection
some of the studies were breaking new ground and required peer review.
In additional CFA could not release the reports until the audit was completed. All reports are
available on the EPA website.
Assessment work The environmental assessments are listed below. A copy of a plan of Fiskville showing the location of
the features referred to in the Cardno reports is provided in Attachment 5. The EPA appointed
Auditor replicated some of the Cardno studies, independently collecting some data and using his
own audit team. The Auditor reached the same conclusions as Cardno. Further detail of the
assessments and findings is available at Attachment 6 and the EPA’s website.
Study 1: Review of Standard Operating Procedures for Fire Fighting Training, CFA Fiskville and
Regional Training Grounds, Victoria, Cardno, 18 April 2013
Study 2: Feasibility Study of Water System Upgrade, Diversion Work and Remediation, CFA
Fiskville Training College, Cardno, December 2013
Study 3: Environment - Site History Review, Cardno, March 2014
Study 4: Environment – Soil Assessments, Cardno, March 2014
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Study 5: Environment - Buried Drums Assessment, Cardno, March 2014
Study 6: Environment – Groundwater Contamination Assessment, Cardno, March 2014
Study 7: Environment – Surface Water and Sediment Contamination Assessment, Cardno,
March 2014
Study 8: Environment – Investigation of Risks at Former Landfills, Cardno, March 2014
Study 9: Environment – Environmental Sampling and PFC Analysis Program, Adjacent Land,
Fiskville, Cardno, March 2014
Study 10: Environment - Aquatic Ecology Assessment, Cardno, March 2014
Study 11: Ecological Risk Assessment, Fiskville Training Grounds, Senversa, 28 January 2015
The clean up plan The outcomes of these studies and the Auditor’s recommendations have been developed into a
program of work, namely the clean up plan, which is designed to meet the requirements for
implementing the IFI recommendations and the EPA in relation to the clean up notices. The clean up
plan is a living document and will be updated as required. The clean up plan has been endorsed by
the Auditor.
The clean up plan has been arranged in six stages. The following provides a brief description and
status of each stage. Under the terms of the clean up notices, all work is to be completed prior to 30
June 2017 to allow a second audit to be completed by that date.
Stage 1 – Containment. Status – Completed May 2014
The purpose of this stage of work was to contain CFA's training waste water on-site and reduce the
risk of it flowing off-site. This is a necessary prerequisite before further remediation works can
commence to remove the source of contaminants.
Work commenced in early 2013 and formed part of CFA's Interim clean up plan. The scope of work
and methodology is set out in Cardno's report, "Feasibility Study of Water System Upgrade,
Diversion Work and Remediation".
Stage 2 – Site Assessments. Status – In progress
The purpose of this stage of work is to:
assess areas of Fiskville that are yet to be sampled
undertake further assessment of areas as recommended by the EPA appointed Auditor
meet the requirements of the EPA’s clean up notice, including delineation of previously
identified contamination. This includes assessment or further assessment of soil, groundwater,
sediment, perched water and PAD infrastructure (concrete, pipes and hoses) to arrive at a
detailed remediation scope and once remediated the completion of the Audit.
SAQPs will be developed to meet all of the above assessment objectives for Stage 2, and will be
approved by the EPA appointed Auditor prior to further assessment works.
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Stage 3 – Off site works. Status – Completed October 2014
The purpose of this stage of work was to advise potential downstream users of water from
Beremboke Creek and Lake Fiskville that the water should not be used for human consumption.
Stage 4 – Remediation. Status – In progress
The purpose of this stage of works is to:
upgrade water treatment infrastructure
remediate the surface waters and sediments in Dams 1-4 and Lake Fiskville
remediate perched groundwater in the scoria between the dams and also at the southern end of
Lake Fiskville (following further assessments to delineate their extent)
remediate former landfill areas at Fiskville.
Recent market assessments have identified a range of emerging technologies potentially capable of
treating PFCs, which are the primary residues requiring remediation at Fiskville. Accordingly, a multi
stage procurement process was designed to identify and assess potential technologies and suppliers’
capacity, capability and experience to undertake the required works and provide the necessary
competitive pressure to achieve the best possible value for money in any final solution selected.
The tender process is currently underway and involves three procurement stages as outlined below:
Open Market Expression of Interest (EOI)
Selective Early Tenderer Involvement (ETI phase) - where Prospective Tenderers run
performance trials for proof of concept
Selective Request For Tender (RFT)
Stage 5 – Plans and Procedures. Status – In progress
The purpose of this stage of work is to develop and implement plans and procedures as required to
meet the Auditor's recommendations. This will include the development of the plans and
procedures, the assignment of specific responsibilities to individuals to implement them, and the
ongoing review and maintenance of those plans and procedures.
A summary of the methodology for Stage 5 is provided in the clean up plan, and include measures
relating to:
ensuring there is no water extractions from Lake Fiskville or further stocking of fish
independent chemical validation of foam products
procedures in the event that any buried drums are found on site in the future
implement landfill environment management plan
store chemicals on sealed and bunded surfaces
procedure for managing leaks/ruptures of fuel pipelines.
The Activities / Tasks set out in Stage 5: Plans & Procedures are underway primarily through the
development of the HSE system, however more time is needed than originally planned. Corrective
action has been taken.
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Stage 6 – Monitoring. Status - Ongoing
The purpose of stage 6 is to monitor the effectiveness of clean up measures undertaken to
remediate residual surface water contamination and adequately treat fire training water prior to
discharge to the environment. Secondary to this is to establish an ongoing monitoring program.
Given Fiskville is now closed, the clean up plan will need to be updated.
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ATTACHMENT 1
CFA’s response to the IFI Report The following is the text of CFA’s response to the IFI Report.
Foreword
After being made aware of health concerns related to historic practices for live fire fighting training at Fiskville from 1971 – 1999, CFA commissioned an Independent Investigation.
Professor Robert Joy, former Deputy Chairman of the Environment Protection Authority, has undertaken an exhaustive investigation over the past six months to establish the facts surrounding this complex setting that reaches back over three decades.
CFA has considered Professor Joy’s report “Understanding the Past to Inform the Future” and provides this response.
CFA accepts the facts, conclusions and recommendations established in the report and will work to ensure the recommendations are addressed as a matter of priority.
CFA’s response will be monitored and audited externally to ensure that the approach taken is consistent, thorough and transparent.
What took place at Fiskville, and to a lesser extent at our other RTGs, was not good
enough and we regret what happened. While we cannot change what happened in
the past, we can clearly demonstrate that we can learn from past mistakes and
we are committed to making changes to assure the ongoing health and safety of
our people, along with our care for the environment.
Kerry Murphy PSM AFSM Mick Bourke Chairman Chief Executive Officer
23
Part 1 – Informing Our Future Fiskville is CFA’s primary training facility and has been in operation since 1971. It is where most of
our people have been trained and where the majority of our operational staff commenced their
careers. Other service agencies also regularly send their people to train there. CFA uses the facility
for graduation ceremonies, to celebrate the achievements of our people and to honour those who
have lost their lives in the course of duty. Over time Fiskville has come to play a symbolic role in CFA,
reflecting the ethos and commitment of CFA members to emergency service. In early December 2011 newspaper reports suggested there was a link between the materials used at
Fiskville for hot fire training during the 1970s, 80s and 90s and some incidences of serious illness and
death in CFA members. We took these reports seriously and by mid December 2011 Professor
Robert Joy was tasked with establishing the facts surrounding the use of chemicals in hot fire training
at Fiskville. A fully resourced, independent team began its investigations in January 2012.
Professor Joy was provided with the resources he needed to conduct the investigation and had
unfettered access to information held by CFA. He was free to make whatever enquiries of our
members past and present that he considered necessary. He also commissioned a number of
environmental and pollution studies of the Fiskville property and other Regional Training Grounds
(RTGs). In addition PriceWaterhouseCoopers (PwC) was retained to assess the level of independence
of the investigation team and found evidence confirming CFA’s commitment to protecting the
independence of the investigation.
CFA Welcomes the Independent Investigation Report
The CFA Board and Management welcome the Report of the Independent Investigation into the CFA
Facility at Fiskville between 1971 and 1999 (the Report). The Report by Professor Robert Joy was
provided to CFA on 28 June 2012. It is titled “Understanding the Past to Inform the Future”, which is a
challenge that we accept.
The work of Professor Joy and his team is greatly appreciated and we thank them for their committed
work over a six-month period to produce this Report. The Board particularly wants to put on record its
appreciation of all those who contributed to the Report. Interviews were held with 324 people,
including past and present CFA members, management and Board members as well as CFA
customers, suppliers and our neighbours at Fiskville, all of whom gave their time willingly to assist the
investigation. We also acknowledge the extent of the technical and support work that needed to be done to ensure
the Investigation was robust and independent. Four million documents were searched and a targeted
review was undertaken of 30,000 documents with 8,000 documents deemed relevant to the task. A
range of environmental studies were undertaken and individual interviews needed to be structured so
that they were thorough and could be relied upon to clarify the issues presented to Professor Joy and
his team.
24
Conclusions
We feel that it is important to include in our response the conclusions that Professor Joy came to in
the Report. We accept Professor Joy’s conclusions and they have helped to shape our governance
and further management initiatives.
The conclusions of Professor Joy (pages 140 – 142 of the Report) are reproduced below.
CONCLUSIONS
The historical risks to staff and the environment at Fiskville associated with the use of a range of
flammable materials in training will never be fully known.
Viewed from the perspective of modern day health, safety and environment standards and regulations, Fiskville’s acceptance and use of donated fuels posed substantial risks which would be unacceptable today. It can be argued that, during the 1970s and much of the 1980s, the general level of industry standards and of regulatory requirements in relation to the management of hazardous materials waste was low. However, by the early 1990s, that situation had changed and the CFA’s own staff responsible for assisting industry to comply with dangerous goods regulations could readily identify that Fiskville was not compliant with regulatory requirements.
The Investigation believes for one group of staff (the PAD operators), the risks of exposure to flammable liquids were significant and considerably greater than to other groups. Instructors working full-time at Fiskville were the group most exposed to products of combustion, foam and fire water. Part-time instructors would have experienced the same types of acute exposures as the full-time instructors, but the frequency of such exposure would have been considerably less. Trainees’ frequency of exposure would have been significantly less again. Exposure of other Fiskville staff and residents, including children, to chemicals, products of combustion, foam and firewater would have been negligible or very low and exposure of persons off-site would have been negligible. The key exposure of staff, residents, the primary school and neighbours would have been to occasional smoke and particulate fall out.
Exposure to chemicals during training needs to be seen in the context of the time and other risks firefighters would have been exposed to, particularly when responding to fires. The risks of exposure of firefighters to hazardous chemicals when responding to fires is likely to significantly outweigh any exposures as part of periodic training. Furthermore, exposures to chemicals as part of other occupational risks, particularly for volunteers, needs to be considered. For example, through the period considered by the Investigation, farmers often had significant exposures to agricultural and veterinary chemicals.
The risks associated with training need to be weighed against the benefits of hot firefighter training in saving the lives of firefighters and of community members. However, the risks inherent in training could have been recognised and managed earlier than 1996, without seriously compromising the realism of firefighter training exercises.
In view of the tens of thousands of people who trained on the flammable liquids PAD between its completion in 1974 and its closure in 1996, it is surprising that only three acute incidents involving exposure to chemicals have been identified. This is despite an exhaustive search of CFA’s OHS records and over 300 interviews. No record of acute incidents involving exposure to chemicals has been found at the six RTGs.
Sampling and analysis of soil, surface water and sediments undertaken for the IFI by Golder Associates at Fiskville has shown that levels of a small number of residual contaminants, notably PFOA and PFOS, exceed human health or ecological guideline values. While the levels of contamination found are not judged to pose a significant risk either on or off-site, further work is needed: to characterise risks to groundwater; to better quantify the potential risks to human health downstream of Lake Fiskville (taking into account dilution, environmental fate and transport mechanisms); and to investigate and potentially reduce sources of PFOA and PFOS discharges into Lake Fiskville.
25
The full facts about drum burial at Fiskville remain unclear. However, the Investigation found documentary evidence that drums and contaminated soil from two mass burials in the 1980s were removed from Fiskville in 1991 and 2002. Drums are likely to remain buried at the former on-site landfills. It is uncertain whether further drum burials remain or, where exhumations have taken place, whether all drums and contamination have been removed. Given the length of time for which any remaining drums will have been buried, it is likely that their integrity will have been breached and volatile components will have evaporated or migrated downwards. The Investigation believes that the risks associated with such drums are likely to be limited and to relate primarily to groundwater.
By 1996 the practice of Regional Training Grounds accepting undocumented, unknown fuels appears to have largely ceased with a shift to increased use of LPG. As a result, the four RTGs established in the 1990s were involved in accepting drums of donated fuel for only a relatively short period, so risks associated with exposure to chemicals, products of combustion and fire water were substantially less than at Fiskville. Unlike Fiskville, where PAD operators were mainly full-time employees, at the RTGs they were employed on a part-time basis. Even in the early days at Wangaratta and Gippsland, training numbers were much lower than at Fiskville, so the demand for large volumes of material, particularly drummed material, to be stored on site did not arise. Nevertheless the majority of each site’s fire training area is unsealed and there is potential for contamination of soil and ground water.
In 1980 concerns over potential PCB contamination in donated fuels were transmitted from Fiskville to CFA senior management. However, the general approach of Fiskville management appears to have been that events that occurred at Fiskville (such as the 1982 drum fire and chemicals exposure incident) were dealt with at Fiskville without reference to head office.
In 1987, the Officer involved in the 1982 exposure incident sought information from the CFA Chairman about the nature of the chemicals in the buried drums. After some delay while head office staff inquired into the incident, CFA employed a consultant to temporarily exhume the drums and identify the chemicals. After a delay of more than two years, CFA provided the Officer with information about the chemicals identified in the consultant’s report on the basis that the information would be treated as confidential.
The Investigation is aware of the problems in applying retrospectively current standards and community expectations in relation to corporate duty of care for health, safety and environment. Nevertheless, in the Investigation’s view CFA managements’ handling of concerns raised by the Officer is open to criticism on the following grounds. Firstly, the consultant’s report clearly stated that the consultant was not qualified to comment on the possible health implications of exposure to the contents of the drums and advised that medical and/or legal advice should be sought. The Investigation saw no evidence that this was done and views this as a significant oversight. Secondly, the report included information on the acute and chronic toxicity of benzene, toluene and xylene that may have been present in the resins and solvents in the drums. In the case of benzene, the report noted that it was a recognised carcinogen of blood forming tissue.
Despite being made aware of the range of potentially serious impacts on health of exposure to these compounds, and despite the Officer expressing concern that there were others apart for himself that should be advised of the results, there is no documentary evidence that this was ever done. Nor do interviews with the other officers indicate they were ever informed of the results of the consultancy. In the Investigation’s view CFA should, as requested, have contacted all those involved in that incident and have made them aware of the findings.
Further, the Investigation concludes that, on the basis of the information available to the CFA Chairman and senior management by the second half of 1988, a thorough audit of Fiskville focusing on the nature and management of fuels should have been undertaken. This should have comprehensively assessed hazards to health and the environment associated with the acquisition, storage, handling, use and disposal of flammable liquids in training. A plan should have been developed to mitigate such hazards. A similar audit and plan should have been undertaken at the two RTGs in use at the time, West Sale and Wangaratta.
26
In addition, inquiries should have been made with past and then present staff at Fiskville with a view to determining whether other incidents involving significant exposure to chemicals had occurred.
Where such incidents were identified, all potentially exposed staff should have been provided with timely and relevant information on potential risks.
Against a background tightening regulatory requirements and increasing industry focus on environmental practice and health and safety, by the mid–1990s, there is evidence of concern amongst some CFA personnel about dangerous goods storage and handling practices at Fiskville. Prior to this, Fiskville staff did not appear to get substantial advice or support on health, safety and environment matters from head office. It is significant that staff pushing for change felt impelled to use regulatory requirements to ensure CFA management’s attention to these matters.
Following CFA dangerous goods auditing in 1996, a CFA Instructor was asked to take a more holistic look at these issues, and the redevelopment of Fiskville in the late 1990s did take into account some health, safety and environment issues. However, even after the extensive studies and plans of 1996 and 1997, the response from Fiskville and corporate management appears limited, with no evidence of systematic follow up, review or auditing of recommendations. Only some of a large number of recommended actions appear to have been implemented. The Investigation did not identify a fundamental shift in focus on health, safety and environment in the period of the Investigation.
The Board through most of the period considered by the Investigation was a representative board and it is understandable that it did not adopt modern governance practice. However, it is notable that CFA did not adopt a more systematic approach to health, safety and environmental issues as other sectors did through the 1980s and 1990s. The fact that CFA hired its first occupational health and safety manager in 1994 is indicative of a late awakening by senior management and the Board.
The Investigation’s Terms of Reference do not include considering current materials used in training or training practices. Rather they focus on legacy issues such as possible site contamination that may pose an on-going risk to human health or the environment. Consequently, these are the areas which the Investigation’s recommendations address.
The Facts
Professor Joy has established the facts relating to the procurement, handling, storage, and exposure
of people to hazardous chemicals at Fiskville, up until 1999, to the extent that it has been possible to
so do. There are limitations arising from the passage of time and lack of detailed information about
donated materials used at CFA fire training grounds, which means that a full account of events at
Fiskville is not likely to be ever known. Nevertheless, the investigation was extensive and is based on
the best available information we are likely to have about conditions at Fiskville over that period. We
therefore accept this information and are taking action based upon it. In the Report, Professor Joy has set out a chronology of events that describes the materials used at
Fiskville for hot fire training. The materials of major concern were flammable materials and
combustion products (such as solvents and paint thinners), extinguishing foams and waste firewater.
These materials are considered to have contained chemicals that carry health risks. Liquid materials
were stored in drums and the investigation shows that some drums were buried on the property. Most
of these drums would have contained residual amounts of solidified materials. The use of these
materials and extinguishing foams has resulted in contaminated firewater that was fed into dams on
the property. A safe working standard is required to ensure personnel are not exposed to hazardous
substances while working with Dams 1 and 2. Professor Joy recommends that further work be done to minimise any risks from areas where buried
drums possibly remain; to investigate possible contamination of dams on the property with a view to
remediation if necessary; and to thoroughly investigate the quality of groundwater at Fiskville.
27
The series of four firewater retention dams eventually drain into Lake Fiskville, which is not a source
of drinking water. Analysis completed for the investigation concluded that the risk posed to human
health was considered to be low. Nevertheless, the Report recommends that further investigation is
required to confirm that the waters and the discharge from Lake Fiskville pose no on-going threat to
human health or to the environment. Professor Joy also considered, in detail, three incidents related to acute exposures to chemicals by
workers which have been documented. While noting that there may be other undocumented
incidents, no additional incidents came to attention during the investigation period. He also comes to
the conclusion that the “historical risks to staff and the environment at Fiskville, associated with the
use of a range of flammable materials in training, will never be fully known”.
Exposure Levels
Professor Joy concludes that there were different levels of risk of chronic exposures for different
groups of people to various sources of contamination while working at and using Fiskville.
Supervisors and operators on the practice area for drills (PAD workers) are regarded as having high
risk of exposure to flammable chemicals with other groups having low to negligible exposure to these
chemicals. Full-time instructors were found to have much lower exposure to flammable chemicals
than the PAD operators although they had high risk of exposure to combustion products and recycled
firewater. PAD workers together with full-time instructors have been identified as having a high overall
risk of exposure. Part-time instructors are regarded as being at medium risk with all other groups
having low to negligible risk. Professor Joy recommends that any further investigation of possible linkages between the risk of
exposure and health effects evaluates the usefulness of the relative risk of exposure of different
groups identified in his Investigation.
The Welfare of our People
CFA accepts the facts, conclusions and recommendations established in the Report. We will take the
necessary action to demonstrate our ongoing commitment to the health, safety and welfare of our
people and others affected by past practices at Fiskville; and our care for the environment, by fully
implementing the recommendations and by improving governance and management capabilities and
processes.
What took place at Fiskville, and to a lesser extent at our other RTG’s, was not good enough and we
regret what happened. While we cannot change what happened in the past, we can clearly
demonstrate that we can learn from past mistakes and we are committed to making changes to
assure the ongoing health and safety of our people, along with our care for the environment.
The welfare of our people remains our first priority. CFA has an existing Health and Welfare Service
that provides access to health services and to a peer support program, chaplains, psychologists and
counsellors. This Service has been expanded and now also includes the following support services
that were developed especially for those who may be affected by the Fiskville matter:
a Health and Welfare Hotline providing 24-hour access for up-to-date information on services
available as well as on-the-spot telephone counselling;
medical reviews for members and their families who have registered with CFA because they
believe they may be affected by Fiskville;
case management based communication for identified past and current members (and their
families) so that they will have a direct relationship with CFA including face-to-face meetings,
telephone contact and written communication.
These services will be strengthened in the coming weeks as:
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CFA will offer health monitoring for those identified as being in a high or medium risk of
exposure group;
CFA will commission an independent health impact study to examine the linkages between
the risk of exposure to hazardous materials at Fiskville and health effects;
Information Packs will be available to CFA members and families outlining the support
services available.
In addition, Information Packs will also be made available to the public and will incorporate details on
accessing community based services. These packs are intended to target those in the community
who feel they could be affected by their involvement with Fiskville or because they live or work close
to the Fiskville training facility now or have done so in the past.
CFA’s Response to the Recommendations
A detailed response to each of the ten recommendations is contained in Part 2 of this response. In
summary:
In response to Recommendations 1, 2, 3, 6, 7 and 10 about the nature, extent and significance
of contamination of soils, sediments, groundwater and surface water, CFA will commission an
independent examination of Lake Fiskville and the dams at Fiskville and any like
arrangements at RTG’s to assess these aspects of the contamination. Alternative firewater
management systems and training water arrangements will be put in place at training grounds
as required. Procedures to protect the health and safety of people working on Dams 1 and 2 at
Fiskville will be put in place. As well, a site ground water monitoring system and appropriate
soils testing will be implemented using an expert provider.
Recommendation 4 that requires an inspection of electrical transformers at Fiskville has been
implemented. All transformers either used as props or retained for that particular purpose
have already been removed from CFA properties to an EPA approved disposal site.
In March 2012 CFA undertook to proceed with a health impact study once the Professor Joy
Report was available. This study will look at the possible linkages between the risk of
exposure of persons during training at Fiskville to the hazardous materials identified in the
Report and health impacts in accordance with Recommendation 5.
Recommendations 8 and 9 require assessment of the need for rehabilitation of landfill areas
at Fiskville after groundwater issues have been dealt with. Following geophysical examination
of these areas and environmental assessments, management plans will be developed with a
view to ensuring that any risks are mitigated and those areas are safe for use. This includes
an appropriate cap for Landfill 1.
We accept accountability for the required implementation and the CFA Board will actively monitor the
progress. We will ensure an independent and transparent scrutiny over this activity.
Governance and Further Management Initiatives
CFA is confident that the events and practices discovered by Professor Joy in respect to the use of
hazardous substances in hot fire training are events and practices of another era. Attitudes,
understandings and work practices have changed markedly for the better since 1999; but we do not
underestimate how much further we have to go. Commencing after the Linton fires in 1998 CFA’s
focus became safety first for fire ground operations and equipment. Further advances are now
required in the way we undertake our hot fire training so as to achieve the same emphasis on safety
and environmental care. One of the themes of the Report is past poor management practices concerning the use of potential
hazardous materials that reflected a culture that did not give health, safety and the environment a
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high priority. To ensure that our people and the community can have confidence in CFA’s ability to respond effectively to this Report and to any future issues, the CFA Board is:
establishing a Board Committee for OHS&E that will also have independent membership
with relevant expertise;
implementing ISO 14001 Environmental Management and along with AS4801
Occupational Health and Safety strive to gain accreditation in these business processes;
including a Standing Item on Board agenda’s relating to progress reports on
implementation of the Report;
arranging for external independent audit of our actions to implement the Professor Joy
Report and making the audit results publically available;
acquiring specialist personnel around environmental management to support personnel
who are already working on health and safety, and increase the presence across the State
around OHS&E;
allocating the executive responsibility and management and control for all Training
Grounds with the Executive Director Operational Training and Volunteerism. The Regional
Site Review issues and recommendations will be considered, assessed and implemented
by OT&V in a manner that is complimentary to the Professor Joy Report and
recommendations;
providing project management capability for the implementation of recommendations;
extending our Health and Welfare Services for those who may be affected by the
Fiskville matter, including:
o health monitoring for those identified as being in a high or medium risk of exposure group.
o commissioning a health impact study to examine the linkages between the risk of exposure to hazardous materials at Fiskville and health effects.
o providing Information Packs to CFA members and families outlining the support services available.
o making Information Packs available for the public which will incorporate details on accessing community based services. These packs are intended to target those in the community who feel they could be affected by their involvement with Fiskville or because they live or work close to Fiskville training facility.
While training in realistic conditions helps save firefighters lives, CFA acknowledges that hot fire
training carries inherent risks, especially to workers at fire training grounds, but also to trainees. To
better manage these risks, CFA will take steps to ensure that its training facilities are accredited as
meeting recognised International and Australian Standards including AS4801 in relation to health
and safety and ISO14001 for environmental management. Together, these standards should
ensure that our people and the community can have a high level of confidence in our training
management practices. CFA will also arrange for external audit of our response to the Professor Joy Report. An
independent audit will maximise the confidence of the CFA Board and Management that the
identified issues have been addressed effectively. More importantly, such an audit will give our
people, stakeholders, local land owners and the community information and assurance about the
steps we have taken to rectify the problems found by Professor Joy.
30
Part 2 – Recommendations The Report’s conclusions relate largely to the activities, practices, exposures and management
at Fiskville and in Headquarters prior to 1999 but some conclusions have implications for the
future. The Recommendations of the Report focus on work that needs to be done to ensure
that the Fiskville training facility and RTGs are safe facilities for our members, trainees, nearby
residents and the local community. The following discussion sets out the recommendations of
the Report, some background to those recommendations and how the CFA will respond to them.
Recommendation 1
That soil and groundwater quality be assessed in areas where fuel storage tanks are currently located or have been located in the past both above and below ground.
What the Professor Joy Report says
Contamination at Fiskville is likely to have arisen from a number of activities including fire
training, storage of fuels and materials used in training, capture and disposal of waste water from
training, burial of used drums and potential leakage from underground fuel tanks. While targeted
sampling has been done for the Report, groundwater was not found in any of the bores used for
sampling. While it was considered unlikely that there was an adverse risk to human health o r the
ecosystem, specific testing of groundwater is recommended.
What will be done
A soil and ground water quality assessment will be undertaken in the areas where fuel
storage tanks are currently located or were located in the past both above and below g
round. The assessment will test for a wide range of organic chemicals and metals associated
with materials that have been identified in the Report.
The work will be part of a property-wide investigation of groundwater occurrence, flow
and chemistry. Soil will be assessed at each storage area. The property-wide groundwater
investigation will commence following consultation with EPA and will be done by specialist
environmental practitioners with capability in investigation of similar situations.
Recommendation 2
That groundwater investigations be undertaken in the vicinity of: the historical flammable
liquids PAD, the fuel mixing area, the historical foam training pits, the prop storage area and the
area used to rehabilitate contaminated soils in 1998
What the Professor Joy Report says
In 1998 a two-stage remediation plan was implemented at Fiskville to address possible
contamination of the PAD. Soil was excavated from the flammable liquids PAD and old fire
training pits (i.e. foam pits) and remediated by soil composting. Six months after the completion
of bioremediation, the quality of the soil met the Victorian EPA clean fill criteria. Groundwater
quality in the vicinity of these historic areas needs to be checked.
31
A groundwater study will be undertaken for the whole property to delineate the groundwater
movements beneath the property and whether or not the groundwater has been affected
by activities carried on at the property. It will include the areas specifically addressed in the
recommendations. A strategy will be adopted whereby the groundwater environment will be investigated initially
in areas with no contamination sources to confirm the occurrence, chemistry and flow of
groundwater in its regional setting. Following the confirmation of the hydrogeology of the
property, bores will be installed down-gradient of each key suspected source of contamination to
test the water and enable ongoing monitoring for potential contamination. The work will ensure CFA has an understanding of the contamination status of the groundwater
and any current or future risks to groundwater. CFA will then be able to take action to protect
groundwater quality.
The work will be undertaken by specialist environmental practitioners with expertise in
investigation of similar situations.
Recommendation 3
That further investigation be undertaken into surface waters in and discharging from Lake Fiskville to:
better quantify the risk to downstream human health receptors, taking into
account downstream dilution and environmental fate and transport mechanisms;
investigate potential sources of PFOA and PFOS [flurosurfactants perflurooctanic acid and perfluorooctanesulfonic acid] discharges to Lake Fiskville and discharging offsite, if the potential risk of adverse impact on downstream human health receptors is found to be unacceptable;
collect surface water samples at a representative location to assess whether the reported copper and zinc concentrations are consistent with background levels; and
assess the ecological condition of Lake Fiskville.
What the Professor Joy Report says
Fiskville Lake is not used as a source of drinking water. Rather, it is part of the system for treating
water used on the fire training ground. Water used for fire fighting at Fiskville circulates through a
treatment system of four dams to remove contaminants and finally flows into Lake Fiskville, an
artificial lake (dam) built on the adjacent Beremboke Creek. Lake Fiskville overflows to the
creek environment away from the Fiskville property. The Professor Joy Report identifies that water and/or sediment in the dams (and to a minor
degree Lake Fiskville) are contaminated with PFOA and PFOS, copper and zinc, petroleum
hydrocarbons and bacteria but also concludes that these concentrations may not be of
significance for worker health and safety and public health. The Report is less definitive about
ecological impacts on the lake and creek and recommends further assessment of these risks
including downstream water users. The Report also considered it necessary to further
investigate the sources of PFOA and PFOS in Lake Fiskville.
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Lake Fiskville surface waters and discharge will be investigated to assess the distribution of
dissolved and sediment-adsorbed PFOA and PFOS in the water system. The potential sources
of any contaminants will be investigated, including dams 1 -4, to understand the distribution and
persistence of any chemicals found in the lake. The presence of copper and zinc in Lake Fiskville will be assessed in comparison with the quality
of uncontaminated water in the local catchment to assess whether the Lake Fiskville levels of
copper and zinc are a reflection of the background levels in the local environment or if they are
indicative of contamination. Following the assessment of Lake Fiskville waters, and if those results suggest it, we will
undertake an assessment of the health risk to downstream users of water from creeks and
dams fed by surface waters receiving discharge from Lake Fiskville. Finally, the ecology of Lake Fiskville will be assessed in accordance with the State
Environment Protection Policy (Waters of Victoria) to arrive at a measure of the health of the
water body. An Ecological Risk Assessment report will be prepared in consultation with EPA. See also information related to Recommendation 6.
Recommendation 4
That any electrical transformers located at any CFA training site be inspected by an
independent hygienist and, if not able to be certified and PCB-free under the National
Polychlorinated Biphenyls Management Plan 2003, that it be treated as a scheduled
waste and disposed of in accordance with the provisions of the Plan inspected
What the Professor Joy Report says
At Fiskville two disused electrical transformers were being used as props for training purposes
at the beginning of the Investigation but they were not certified as PCB-free (polychlorinated
biphenyls (PCBs)) are known to produce a range of adverse health and environmental effects.)
Similar props were stored at Bangholme training centre. It appears unlikely that any action was
taken to ensure that these props were PCB-free.
What has been done
In March of 2012 both transformers at Fiskville were tested for PCBs by ALS Global, an
environmental auditing company. Testing revealed d that both electrical transformers
contained traces of PCBs above the acceptable safe levels as per the relevant EPA guidelines.
Arrangements were subsequently made with MRI Pty Ltd, an accredited and EPA approved
transporter of contaminated materials, to remove both electrical transformers to an approved
disposal site at Campbellfield. The removal occurred on 30 May 2012. The appropriate EPA
Waste Transport Certificate was provided at the time of disposal. At Bangholme there were five electrical transformers that have not been used for many years.
The transformers were used as static props, not incorporating hot fire , for a two-year period
following their arrival and then remained unused. In June 2012 the five transformers were tested
for PCBs by MRI Pty Ltd. The testing found no oil samples were present or obtainable, with all
units identified as having been previously drained and stripped leaving the metal casings only.
This was the condition in which the electrical transformers were when they arrived at Bangholme
some 15 years previously. Given these transformers were no longer required , arrangements
were made with MRI Pty. Ltd. to remove the electrical transformers, which occurred on 4 July.
The appropriate EPA Waste Transport Certificate was provided at the time of disposal.
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No dormant electrical transformers now exist on any CFA property.
Recommendation 5
That any subsequent study of possible linkages between exposure of persons during training
at Fiskville to materials such as flammable liquids and health effects evaluate the usefulness of
the qualitative assessment of relative risk of exposure of different groups developed in Chapter 7 What the Professor Joy Report
The Report concluded that the risk of exposure of PAD workers to flammable liquids was high
and considerably greater than other groups. Full-time instructors had high levels of
exposure to products of combustion, foam and firewater but low exposure to flammable
materials. Part -time instructors would have experienced the same types of exposures as the full -
time instructors, but the frequency of exposure would have been considerably less. Exposure of
trainees would have been significantly less again. Other Fiskville staff, visitors and residents
would have experienced considerably lower levels of exposure than trainees. The key
exposure to staff, residents, the primary school in the grounds of Fiskville and neighbours
would have been to occasional smoke and particulate fall-out.
What will be done
CFA has previously committed to undertake a study of possible linkages between exposures
of persons during training at Fiskville to materials such as flammable liquids and health effects.
Discussions have been held with the Head of the Monash University Department of
Epidemiology and Preventative Medicine with a view to conducting a study to determine
possible linkages between exposure to hazardous materials and any possible health effects
taking into account that some groups of people as identified in the Professor Joy Report had
higher levels of risk of exposure than others. This approach will ensure that the usefulness of
the qualitative assessment of relative risk referred to in the Report is assessed. Preliminary steps have been taken so that the feasibility of a retrospective cohort study can
be assessed. The feasibility of the study will determine if records exist that can identify the
individuals who comprise each of the exposed groups, determine their level of exposure and take
account of other demographic information such as age. Monash University Ethics Committee
approval will be required and will ensure the validity and reliability of the research methodology.
The results of the feasibility study and the health study will be made publicly available.
Recommendation 6
That procedures be put in place to protect the health of personnel potentially exposed to waters
and sediments in Dams 1 and 2 of the firewater treatment system and, in particular, to manage
the risks to individuals who have the potential to come into contact with sediments in the dams
during routine maintenance
What the Professor Joy Report says
Golder Associates undertook a series of technical investigations at the Fiskville property on
behalf of the Investigation. Sampling and analysis of soil, surface water and sediments included
34
testing of the water and sediment in the four dams at Fiskville. As indicated above, this testing
indicated contamination in the water and sediment in the dams by a number of chemicals
including hydrocarbons, PFOS and PFOA (derived from discontinued fire -fighting foams). While
there are no specific criteria for these contaminants for firefighting training water, they exceeded
drinking water criteria. The level of contaminants was judged to pose an insignificant risk to
workers at Fiskville or in surrounding or downstream areas. The Report recommends
implementation of procedures to protect workers who are potentially exposed to water and
sediment in Dams 1 and 2.
What will be done
While the fire fighting water system at Fiskville is supplied by potable town mains water source, it
is apparent that chemicals such as PFOA and PFOS and bacteria are circulating in the
water recycling system dissolved in the water and adhering to the fine sediment particles.
The risks arising from current operational exposure of PAD workers to water and sediment in
Dams 1 and 2 will be assessed. Similarly, the risks arising from current operational exposure
of instructors and trainees to fire fighting water recirculated from Dam 2 will be assessed. Standard Operating Procedures (SOPs) for fire fighting water system operation and
maintenance will be reviewed and revised to assure the safety of personnel exposed to this
water. The SOP will include an updated water quality monitoring program and an audit process.
OHS procedures and compliance systems will be revised. OHS will be managed in
conformance with AS4801 and accreditation will be pursued. Once these procedures are in place
normal OHS precautions will provide adequate protection.
In addition to resolving issues related to the presence of hazardous materials in Dams 1 and 2
we will also develop a set of criteria for water quality to assure suitability for current fire fighting
training purposes. This water quality does not need to be of a potable standard. A specific
risk -based criterion for PFOS and PFOA may need to be derived.
A comprehensive study into the options for re-engineering the firewater supply, treatment and
recirculation system at Fiskville will be undertaken to achieve fit-for-purpose water quality
at Fiskville. Options with and without recirculation of firewater will be developed for upgrading
and refurbishing the fire water supply system at Fiskville with a view to eliminating PFOA and
PFOS to the greatest extent practicable and to meet the risk -based criterion. Options will be explored that could include provision of large storage tanks to contain the
additional town water needed to allow the majority of training exercises to be conducted. Other
options such as upgraded treatment systems or using groundwater supply will also be
investigated as the local groundwater may be a suitable non-potable quality for fire fighting
purposes. No water from Dam 1 or 2 will be used in training until the assessment of OHS risk is completed.
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Recommendation 7
That soil and groundwater quality be assessed in the following areas that were not examined
during the site investigation stage of the Preliminary Site Assessment of Fiskville: (Figure 8.1)
Part of Drum Burial Area 1 (south of the airstrip and south of Deep Creek Road)
Drum Burial Area 2 (north of Administration Building);
Drum Burial Area 3 (east of the Administration Building)
Historical landfills 1 and 2.
What the Professor Joy Report says
Up until 1996 drums that had contained flammable materials were frequently buried at Fiskville
in landfill areas or by way of mass burials. The Investigation leading to the Professor Joy
Report included a search for prospective drum burial areas using ground penetrating radar,
however no drums were found. The Report concludes that should any drums remain , their
integrity would have been breached by now and any volatile components will have evaporated
or migrated downwards and any remaining risk will relate to possible groundwater
contamination.
What will be done
The five areas where buried drums have been found or have been suspected will be
investigated in more detail using geophysical methods including but not limited to
electromagnetic and magnetic methods to identify the location of any remaining drums .
A soil and ground water quality assessment will be undertaken in the areas where drums are
believed to have been buried. The testing program will include a wide range of organic
chemicals and metals associated with materials that were known to have been stored in drums.
In the event that drums are found, they will be removed if it is assessed that that is the best
way of addressing any risks associated with the drums. Otherwise the area will be capped.
This work will be undertaken in association with work to address Recommendations 1 and 2
(Soil and groundwater investigation).
Recommendation 8 That historical landfill 1 which has been disturbed by the construction of a walking track needs to
have its extent clearly identified, have an appropriate impermeable and properly drained cap
constructed and be revegetated with shallow rooting species that will not compromise the integrity
of the cap. This should ensure the safety of any people using the walking track
Recommendation 9 That any decision on the future management of historical landfill 2, including possible exhumation
of buried drums and further site rehabilitation, await the results of soil and groundwater quality
assessment at the site (Recommendation 7)
36
What the Professor Joy Report says
Drums, sludge and other material were routinely buried at Fiskville in one of two areas near
the south-western corner of the property. One of those landfills (Landfill 1) dates back to and
was used by previous owners of the property, AWA, as well as by CFA. While the drums were
reported to be empty, in practice any are likely to have contained solidified residues. The
AWA landfill also contains other materials, such as old ceramic insulators that were brought
to the surface during construction of a public walking track. Further work is needed both to
determine if there is any residual contamination of these areas and to ensure that the
areas are properly drained and covered.
What will be done
The environmental condition of both landfills will be investigated. The type, thickness and
condition of landfill capping will be determined by geotechnical drilling and inspection.
A qualitative risk assessment based on the landfill history, soil and groundwater assessment,
geophysical investigation and current property usage will be completed. In particular, the risks to
people using the walking track traversing Landfill 1 will be assessed.
Any decision to remove drums from either landfill will depend on the outcomes of the risk
assessment, including the risks associated with removal of the drums.
Upon completion of the assessment and works required to be done under Recommendation 7,
a management plan will be developed and implemented to ensure that all environmental and
health
and safety risks are adequately managed at the two former landfills.
Recommendation 10
That the site specific recommendations of the Golder Associates’ Preliminary Site Assessment –
CFA Regional Training Grounds (RTGs) be adopted including recommendations to:
undertake targeted soil and groundwater investigation at sites where possible sources of
contamination have been identified;
assess fire fighting water quality for contaminants associated with flammable liquids
and extinguisher foams;
assess water quality where discharges occur to the environment.
What the Professor Joy Report says
Golder Associates completed a Preliminary Site Assessment of RTGs for the Investigation.
Four RTGs have unsealed fire training areas and visual inspection shows evidence of
hydrocarbon staining, probably arising from poor fuel storage and management practices. The
Professor Joy Report found that the types of exposure on the RTGs would be similar to those at
Fiskville, but the levels of exposure would be significantly less. Further examination of these
grounds is warranted to assure health and safety.
What will be done
CFA has commissioned a range of work that is informed by and will achieve the outcomes sought
in the report of assessments completed by Golder and Associates (see below). This
recommendation is complex and covers six properties where we have RTGs. The work will include targeted soil assessments in the vicinity of:
37
flammable liquids pads;
current and former above ground and underground storage tanks ;
extinguisher pads;
fuel mixing areas;
prop storage areas including former transformer prop areas ;
soil remediation areas;
water recirculation dams.
A laboratory testing program will test for a wide range of organic chemicals and metals
associated with materials that have been used on the RTGs. The results of these assessments
will inform the investigation of groundwater quality.
In accordance with the approach taken at Fiskville , the hydrogeology of each property will
be examined in its regional setting. At least three monitoring bores will be installed at each
training ground, including down-gradient from the potential source area of contamination.
Procedures will be put in place to protect groundwater quality. We will sample and test water in the fire-fighting systems at key points at each training ground
plus the point of water discharge from each property. Testing would be for the same chemical and
biological parameters evaluated at Fiskville in order to assess the potential for adverse
human health or environmental impact. Supporting technical assessments
In the course of the Independent Fiskville Investigation, Professor Joy commissioned a number
of technical assessments from Golder and Associates. CFA has used these reports to ensure that
the response to the recommendations of the Professor Joy Report is comprehensive. The reports
include:
a Health Hazard Report, which provided factual information on substances
potentially present at Fiskville;
a Preliminary Site Assessment of Fiskville designed to identify the location of
buried contaminants and make recommendations about clean-up or remediation. Three
recommendations are included in the Assessment Report which are reflected in
Recommendations 1, 2, 3, 6 and 7 of the Professor Joy Report;
a Preliminary Site Assessment of Regional Training Grounds to assess potential sources
of contamination and undertake a preliminary assessment of the risks of potential
contamination. Thirteen recommendations (being between one and three
recommendations for each of the RTGs) are included in the report which is reflected in
Recommendation 10 of the Professor Joy Report.
A Review of CFA Regional Training Grounds was undertaken for Professor Joy by Brian
Lawrence which addressed governance, systems, training, best practice and asset management
of the RTGs. Eighteen recommendations are included in the re view. These recommendations
require a new focus on the management and operation of the RTGs in order to achieve
consistency of practice, common systems, standards and processes, clear responsibilities and
accountabilities and a strong and focussed management. Responsibility for assessing and
implementing these recommendations rests with the Executive Director Operational Training and
Volunteerism .
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ATTACHMENT 2
Human Health Risk Assessments Five human health risk assessments have been undertaken. Summaries of these assessments are
set out below. The full reports are available on the EPA’s website.
1. Summary Report - HHRA – CFA Training Personnel, Cardno, March 2014
This HHRA will be used in conjunction with the findings from the other investigations to
inform the decision process for upgrading the water systems and water management
practices at Fiskville. The HHRA will also be used to derive a set of non-potable, "fit for
purpose", fire training water quality criteria to be presented in a separate report.
Objectives
(i) Conduct a HHRA to estimate the potential for impacts upon the health of
PAD workers and other potentially exposed individuals to water and
sediments from Dams 1 and 2 during hot fire training.
(ii) Estimate the potential for impacts upon the health of other individuals (e.g.
members of the community) related to potential exposures to water
discharged offsite.
(iii) Provide recommendations regarding actions required to eliminate or
effectively manage identified risks.
Findings
Workers involved in fire fighting training
The concentrations of PFCs in the blood serum of PAD instructors (those with
highest occupational exposure) are at least 2 orders of magnitude below the
total PFC concentration deduced from the literature, not to be associated with
health effects in workers.
Exposure to PFCs during fire fighting training has not resulted in an increase in
serum concentrations above those expected in the background (ie resulting
from exposures in everyday living).
Health effects from exposure to PFCs during fire fighting training are very
unlikely to be experienced by PAD instructors. By extension, less exposed
workers including recruits are also at low health risk.
The blood serum data has confirmed the conclusions of the quantitative
modelling of a very low health risk from PFC exposure during fire fighting
training. Further, the data confirms (as expected) that the worst case scenario
overestimates exposures and should not be referred to in making conclusions
on health risk.
Maintenance Workers
Risks to maintenance workers from exposure to PFCs and TPHs are considered
negligible, assuming that these workers employ appropriate OHS practices in
line with Fiskville procedural requirements and use PPE that prevents or
minimises exposure.
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Microbial risks
The Quantitative Microbial Risk Assessment identified potential microbiological
risks if untreated water from dams was used in training drills, due to the possible
presence of a range of microbes, including endotoxins, algal toxins, opportunistic
microbial pathogens and enteric microbial pathogens.
This risk is present in any dam/lake/waterway, and has nothing to do with
contamination.
Recommendations
Recommendation Corresponding
section 53V audit
recommendation
Action* Status
Maintenance activities on Dam 1 and
2 should be designed to involve
minimal contact with water and wet
sediments. Where maintenance of
the dams is required with high
potential exposure to sediments,
such as clearing vegetation, specific
OHS measures should be
implemented that minimise contact
with sediments, consistent with
existing Fiskville procedural
requirements
7 Project 12
(HSEMS) of
ITFP
Completed
OHS protocols be implemented for
workers and visitors accessing the
dams for maintenance or monitoring
purposes. The minimum procedure
would involve the use of waterproof
gloves, safety glasses, rubber boots
and waders in place of or in addition
to normal PPE used by workers
accessing the PAD area. This is
consistent with Fiskville procedural
requirements
7 Completed
All water used for fire-fighting
training must be disinfected prior to
use to prevent risk of exposure to
microbial pathogens that are likely to
be present. This includes the current
temporary storage tank system as
well as any new system involving
other water treatment with or
without recirculation of treated water
for use in training drills
Stage 4 Current water
is town mains
only and
tested
regularly
Routine monitoring of algae should
be added to the Water Management
Plan for the Site.
Stage 6 Not started
formally, but
such
inspections
are part of
current
informal
maintenance
40
Recommendation Corresponding
section 53V audit
recommendation
Action* Status
practice
* Stages in this and following tables refers to stages of the clean up plan.
2. HHRA – Fiskville Community, Cardno, March 2014
Objectives
The purpose of this HHRA is to identify risks to individuals considered to be a part
of the Fiskville Community. The Investigation Report made a recommendation
regarding assessments of risk to CFA personnel on site as well as "downstream
users of water" potentially exposed to contamination associated with fire fighting
activities. This HHRA was prepared in addition to these studies to address risks to
any people with access to Lake Fiskville for recreational activities.
The ‘Fiskville Community’ is defined for the purpose of this report as:
(i) any staff member who works on the site and may casually access Lake
Fiskville in their spare time for recreational purposes (e.g. swimming, fishing
etc);
(ii) family members of staff who reside on-site and may casually access Lake
Fiskville in their spare time for recreational purposes; and
(iii) people from the local community who may have accessed the site (in
particular Lake Fiskville) in the past for recreational purposes.
The specific objectives of the HHRA are to:
(i) conduct a HHRA to estimate the potential for impacts upon people of the
Fiskville Community from exposures to chemicals in water in Lake Fiskville;
and
(ii) provide recommendations regarding actions required to eliminate or
effectively manage risks identified.
The scope was expanded during the course of the investigation to assess risks to
people from the Fiskville community who are potentially exposed to wind-blown
foams and/or spray drift from training areas (other than occupational exposures).
Findings
The report concludes that the risks estimated for people from the Fiskville
Community potentially exposed to PFCs present in water or fish and rabbits caught
on-site are considered negligible.
Recommendations
There are no recommended actions given the conclusions of this HHRA.
CFA have already implemented relevant management initiatives:
(i) banning of recreational activities (e.g. fishing, swimming) in water bodies at
Fiskville. Lake Fiskville and the dams have been signposted accordingly;
41
(ii) management authorisation required prior to hunting activities being conducted
at Fiskville;
(iii) investigation into the feasible options for remediation of water bodies at the
site including Lake Fiskville;
(iv) development of a water management strategy to provide clean water and
treat contaminated water generated during training;
(v) altering the training program at Fiskville to minimise the potential
contaminant load in to Lake Fiskville; and
(vi) construction of a bypass channel to divert Beremboke Creek around Lake
Fiskville. This will prevent its flow through Lake Fiskville so as to minimise
discharges from the Lake.
3. HHRA – Downstream Users, Cardno, March 2014
Objectives
The purpose of this HHRA is to identify risks to downstream users of the creeks and
the Moorabool River. The specific objectives of the HHRA are to:
(i) Conduct a HHRA to estimate the potential for impacts upon the health of
persons exposed to contaminants discharged to the downstream creeks from
the Site as a result of fire fighter training activities.
(ii) Provide recommendations regarding actions required to eliminate or effectively
manage identified risks.
The scope was expanded during the course of the investigation to assess risks to
downstream users who are potentially exposed (directly or indirectly) to wind-
blown materials such as foams and/or spray drift and any potential resultant
impacts (eg soil, grass, rainwater in tanks).
Findings
The report concludes that the risks calculated for downstream users potentially
exposed to PFCs present in water, fish and/or rabbits are considered negligible.
Recommendations
Nil.
4. Fire Training Water Quality Criteria – CFA Training Grounds, Victoria, Cardno,
March 2014
A qualitative assessment of risk to human health performed for the water sources
(potable water, process water and recirculated water) at Fiskville.
Objectives
(i) Propose a set of criteria for a "fit for purpose" non-potable and sustainable water
quality suitable for use in fire-fighter training; and
(ii) establish a process for monitoring and accepting water for use in fire fighting training
or off-site discharge which CFA can incorporate into a WQMP adaptable for each
training ground.
42
Findings
Concluded that the health risks due to exposure to potable water are negligible as
this water is treated prior to supply (assuming that potable water is used
immediately and not held in on-site storages for a length of time that would cause
the chlorine levels to fall below 0.5mg/L).
The report provides a proposed set of conservative water quality criteria against
which to monitor and assess fire training water for human health and for discharge
to the environment.
The criteria proposed are selected and/or derived for hot fire training and include:
(i) Treatment Management Levels – criteria used to monitor the performance of
the water treatment system. They were designed to meet water quality
objectives for industrial use of reclaimed waters (EPA Victoria, 2003);
(ii) OHS Risk Based Targets – criteria derived to protect the health of CFA Training
Personnel for select compounds (organic and inorganic chemicals) and
microbial pathogens based on the Cardno HHRA; and
(iii) Environmental Discharge Criteria – used for the protection of the ecology of the
surface water bodies to which water is discharged. These are primarily based
on established guidelines in Australia (ANZECC 2000a) and SEPP WoV (Gov
2003).
5. Health Impact Assessment from consumption of lamb produced near CFA
Fiskville training ground, ToxConsult Pty Ltd (Dr Drew), 15 May 2014
While this report was not prepared in time for inclusion in the 53V audit report, the
outcomes of the investigation were documented in letters, presentations and other
documents which were provided to the Auditor for consideration as part of the 53V audit.
Objectives
Following a methodology developed and agreed in partnership between
Department of Health, Department of Primary Industries, PrimeSafe and
ToxConsult, assess the PFOS concentration in sheep resident on a farm adjacent to
Fiskville to become better informed about the ratio of PFOS in serum, muscle, liver
and kidney of sheep and assess the risk to public health and food safety related to
the consumption of meat from those animals. This study is the largest field study
undertaken anywhere in the world that investigates PFC levels in domestic animals
raised for human consumption.
Findings
(i) The environmental investigation of the neighbouring farm for possible impact
by PFCs from Fiskville fire fighting activity has shown minimal impact to soil
and grass (just above the analytical limit of reporting, and 2-4 orders of
magnitude below the concentrations the US EPA considers safe for families to
live on). While some areas close to the boundary with CFA have low amounts
of PFCs, they are unlikely to materially contribute to the PFC body burden of
sheep on the farm. The exception is the creek, and its flood plain between
Lake Fiskville and the twin dam on the farm at the Western boundary. The
upper portion of this farm dams has high concentrations of PFCs within it and
is considered to be the primary source of PFCs in sheep on the property.
(ii) Areas around the farm homestead and the water supply for the homestead are
not impacted. Cardno determined soil PFC concentrations, and concentrations
in the farm dam are safe for persons working on the farm providing there is
not frequent direct contact with farm dam water or high degree of immersion
43
in it. Although the dams are unlikely to sustainably support frequent
collection of large yabbies, these animals can potentially accumulate high
levels of PFCs. It is therefore suggested that advice be provided to the
landowner that consumption of yabbies from the dam not occur.
(iii) The extended ewe and lamb study investigating PFC concentrations has
provided a large and robust data set for assessing the risk to the general
public that may be associated with eating meat or offal from lambs raised on
the farm. For a range of consumption scenarios it is concluded there is
negligible risk to public health. There is also very low health risk associated
with assumed high lamb meat intake by a subsistence farmer.
(iv) The ewes on the farm have low amounts of PFOS in their serum, similar to
what is measured as background concentrations in human serum. These
levels do not appear to have affected either the welfare or productivity of the
animals. By analogy with the lamb HHRA it is concluded that culling ewes for
human consumption is associated with negligible health risk.
(v) As with any HHRA of this nature there are a number of uncertainties with the
quantitation of risk. These are addressed by embedded conservatism in the
assessment that errs on the side of safety. Overall the HHRA tends to
overstate rather than understate the health risks, even so the risks are
considered to be negligible and are underpinned by a data set of high quality.
(vi) Based on the above findings, Victoria's Acting Chief Health Officer advises that
based on the evidence, this incident poses no public health or food safety risk.
44
ATTACHMENT 3
Health studies Two major health studies were undertaken.
1. A statistical analysis of cancer risk experienced by firefighters who were trained
at Fiskville, Cancer Council Victoria, 18 June 2014
Objectives
CFA commissioned the Cancer Council Victoria to perform an analysis of cancer risk
for CFA fire fighters that may have arisen from past practices undertaken at
Fiskville.
The cohort of 599 men was linked with the Victorian Cancer Registry to identify
those who were diagnosed with invasive primary malignancies in the years 1982-
2012. Two reference populations were used for analysis:
(i) the population of Victoria; and
(ii) the population of Victoria that was born in Australia.
The latter was used, as the composition of our workforce is predominantly
Australian-born and is under represented by immigrant groups.
Findings
Overall, this cohort of fire fighters did not have an increased incidence of cancer.
The excess risks obtained using the principal analysis based on using the entire
population of Victoria as the reference population were attenuated and became
statistically non-significant when the reference population used was restricted to
the Australian-born component of the Victorian population. This underlines the
importance of using reference populations appropriate to the demographic
composition of industrial cohorts.
Limitations
Complete data from the cancer registry was available for the years 1982 to 2012
(inclusive) and so risk of cancer was considered during this period only. This follow-
up time may be too short to have detected all cancers that might occur in this
cohort above and beyond that which is normally expected as a result of ageing.
Information about grade (low, medium or high) and duration of exposure to
hazardous material was limited and so was not considered.
Standardised Incident Ratios (SIR) estimates, particularly those for specific
cancers for which a small number of cases was observed, should be interpreted
with caution as they are highly imprecise. The 95% confidence interval for each
SIR estimate can be interpreted as the range of possible values of the “true” SIR.
2. Fiskville Firefighters' Health Study, Department of Epidemiology and Preventative
Medicine, Monash University, November 2014
Objectives
CFA commissioned Monash University to investigate the risk of cancer and
mortality for individuals grouped according to the Investigation Report as being
likely to have had a high, medium or low risk of chronic exposure to a variety of
materials (Recommendation 5).
45
The cohort examined comprised 606 people, including three women, and had 95
men in the high group, 256 men in the medium group (105 career firefighters and
151 volunteer firefighters) and 252 men in the low group. The cohort was linked to
the National Death Index and Australian Cancer Database (both held by the
Australian Institute for Health and Welfare) and to the Victorian Cancer Registry.
Findings
No deaths or cancers were identified for the three women in the cohort.
There were 28 deaths and 69 cancers identified among the men in the cohort.
When compared to the Victorian population, higher than expected cancer rates
were observed for:
melanoma and cancer of the testis in the high group; and
brain cancer in the medium group.
When compared to the Victorian population and to the Australian-born Victorian
population, the overall cancer risk was:
significantly raised for the high group;
similar for the medium group; and
significantly reduced for the low group.
When compared to the low group, there was a statistically significantly increased
cancer risk for the medium and high groups, but the number of cancers in the low
group was very small, resulting in a lot of imprecision in the results and this is
likely to impact on the robustness of these findings.
When compared to the general Australian population, the overall mortality was
statistically significantly decreased for the whole cohort and for the low and
medium groups. This reduction in mortality may be due, at least in part, to the
healthy worker effect. For the low group and the volunteer firefighters in the
medium group in particular, the low mortality may also be a result of an
ascertainment bias, that is some individuals who had died may have been less
likely to have been identified and included in the cohort. It is also possible
however, that those individuals who died of cancer were more likely to be recalled
than other individuals who had died of other diseases. The mortality for the career
medium group and the high group was also reduced but not statistically
significantly so.
Limitations
Imprecision in the findings given the small numbers in the cohort of firefighters
and even smaller numbers when the low, medium and high groups examined
separately.
Concerns about the completeness of the cohort, especially for the low group
and volunteer medium subgroup and for those who have already died.
Lack of information on other lifestyle factors which are known to be related to
cancer risk.
Limitations in probabilistic matching with cancer and mortality registries.
Difficulty in assigning a start date for work at Fiskville from the variety of data
sources provided.
However, several uncertainty analyses were undertaken, and most did not result in
major differences in the pattern of the findings, which suggests that the study
limitations may not have greatly affected the validity of the findings.
46
ATTACHMENT 4
Water Quality Management Plans CFA originally introduced a formal Water Management Plan for RTGs in March 2008. This plan was
last amended in 2012. The recommended criteria for water quality parameters, supported by EPA
and the Department of Human Services, were set at:
(b) E coli – < 10 orgs per 100 mls
(c) BOD - < 10 mg/l
(d) pH – 6.0-9.0
(e) Suspended solids - < 5 mg/l
(f) Pseudomonas aeruginosa - < 10 orgs per 100ml
The first 4 criteria complied with the Class A recycled water criteria as set out in the "Class A
Recycled Water Management Plan" agreed between CFA, MFESB and relevant water authorities in
September 2007, and adopted by CFA in SOP 9.36 – "Recycled Water – Use and Management
of". The level of Pseudomonas aeruginosa was based on advice from Ecowise Environmental (6
March 2008) as being an appropriate standard for firefighting water.
It became apparent that the E.coli level of 10 orgs per 100 mL was difficult to maintain at some
CFA training grounds that source training water from on-site dams. A review of this criterion was
therefore requested to determine whether the E. coli criterion could be amended to 150 orgs per
100 mL which had also been recommended by Ecowise Environmental (6 March 2008). As the
water used at RTGs was rainwater stored in on-site dams, the criteria set out in the Class A
Recycled Water Management Plan do not apply.
The Department of Human Services had no objection to the proposed amendment. The EPA
confirmed that the use of rainwater/stormwater is not regulated, and advised CFA to discuss
appropriate E. coli levels and management practices with the Department of Human Services and
Worksafe.
As a result of this consultation, the level for E. coli was amended to < 150 orgs per 100 mls in
August 2009. A revised version of the Water Management Plans was issued in June 2010, also
informed by the Wynsafe report on PFCs, with a further revised version being issued May 2012.
In June 2012, due to heightened concerns, CFA ceased using recycled dam water for training at
Fiskville and switched to town mains water. At this time CFA also reduced the criteria for E coli
back to < 10 orgs per 100 mls as a precautionary measure as documented in a revised Water
Management Plan prepared by Cardno in October 2012.
In March 2014, Cardno provided CFA with a draft WQMP, based on their work undertaken in
respect of Fiskville. This WQMP was developed in anticipation of a return to the use of recycled
water on the hot fire training PAD (pending the completion of all remediation works and the
implementation of a water treatment plant). CFA planned to implement this new WQMP once all
remediation was complete and the new water treatment plant was procured and installed at
Fiskville (the first two stages of a three part tender process have been completed).
All water test results undertaken by CHW since July 2012 (ie since potable water has been the sole
source of firefighting training water) are on CFA's website
http://www.cfa.vic.gov.au/about/fiskville-water-test-results/. Those results show that the water
tested pursuant to the Water Management Plans was suitable for use for firefighting. All results
were within set criterion, with the exception of:
47
a) Week of 20 August 2012 – a water sample collected on 14 August 2012 exceeded the
criterion for suspended solids (not a critical parameter for OHS). However, a sample
collected on 20 August 2012 did not exceed the criterion. The suspended solids were
thought to arise from runoff from the unsealed ground adjacent to the Water Supply
Pit. Water from the Water Supply Pit filled with mains water can continue to be used for
firefighting training purposes (Cardno letter report, 28 August 2012).
b) September 2012 – water samples collected on 11 and 20 September 2012 exceeded the
criterion for suspended solids (not a critical parameter for OHS). The control actions
outlined in the Water Management Plan for Fiskville should be implemented – clean out of
Water Supply Pit, and filling with town water within a month of the letter (CFA immediately
actioned this). The water in the Water Supply Pit remains suitable for use (Cardno letter
report, 27 September 2012).
c) 28 June 2013 – water sample from the Red Pipe – PG Tank collected on 20 June 2013
exceeded the criterion for pH slightly (9.1). Criteria for pH are typically provided to
minimise corrosion to infrastructure and prevent scaly build up in pipes or for aesthetic
reasons. However, alkaline water with a pH greater than 10 may lead to gastrointestinal
irritation in sensitive individuals and irritation of the eye, skin and mucous members at pH
above 11. Therefore a pH of 9.1 is not considered a human health problem (Cardno letter
report, 2 July 2013).
d) 31 October 2013 – water sample from the beige pipe BU Tank exceeded the criterion for
pH slightly (9.1). See discussion at paragraph above regarding the effect of this pH result.
e) February 2014 - water sample from the beige pipe BU Tank exceeded the criterion for pH
slightly (9.5). See discussion at paragraph above regarding the effect of this pH result.
Draft Water Quality Management Plan – March 2014
The purpose of the Draft WQMP is to provide a guideline for the management of water quality used
in fire training at Fiskville, to ensure that water quality is suitable and protects the health and
safety of our personnel and the environment. The WQMP has not yet been implemented at
Fiskville, given potable water is currently used for training activities. Cardno prepared the Draft
WQMP with the intent of CFA customising and implementing it once the remediation works are
complete and the new water treatment plant is installed and water is being re-circulated for use in
training (see Stage 4 CUP (Remediation), Part F, section 3.4).
The draft WQMP, which is based on the Cardno reports is intended to:
identify the roles and responsibilities of personnel involved in hot fire training water
supply and treatment at Fiskville;
describe the water system at Fiskville including water supply and treatment facilities;
summarise water quality criteria (WQC) appropriate for fire training water, and
presents this in a manner that allows a progressive implementation of management
responses in the event that water quality indicators start to move outside the ideal
ranges for use in fire-fighting training or discharge to the environment (a "traffic light
system"). This approach organises the WQC into groups relative to two levels of
Water Quality Triggers (WQT). Generally, the WQT are the recommended maximum
values which should not be exceeded;
sets out key water monitoring (continuous or quarterly depending on parameter in
question) and relevant control actions if the WQT are exceeded, including water
sampling and testing requirements, switch to potable water only with no recirculation
and no reuse or cessation of fire-fighting training and discharges to the environment;
and
set out documentation, reviews (at least every 2 years) and record keeping
requirements relevant to the draft WQMP.
48
The draft WQMP is written and based on the understanding that:
the water for fire fighting training at Fiskville is initially sourced from potable water
(i.e. town water mains);
water collected from the PAD area is proposed to be treated onsite (via a new water
treatment plant), stored, reused, (i.e. recirculated water or process water) and
potentially disposed of to the environment, all subject to appropriate approvals;
recirculated water is stored in appropriate holding tanks (the current and future water
systems do not incorporate the water treatment Dams 1 to 4 formerly used to store
and treat effluent from the PAD); and
water recirculation does not include any water from the Dams nor Lake Fiskville that
potentially contain contaminants including PFCs.
Cardno prepared the Draft WQMP under the assumption that a new Water Treatment Plant for
Fiskville will be installed to provide water suitable for fire-fighting training and will include:
pre-sedimentation: removal of large debris and heavy particles (surge basin);
oil separation, coagulation, flocculation and sedimentation: removal of separate phase
petroleum hydrocarbons, dirt from the water column and the floc (water treatment
plant);
filtration: removal of smaller particles using filtration;
disinfection: use of chlorination and/or UV light to disinfect water;
storage: water is stored in enclosed tanks and residual chlorine levels monitored; and
proposed wetland system as part of the site drainage improvement works prior to any
discharge off site.
The Draft WQMP also sets out the materials approved for use on the PAD. All other materials
require approval prior to use on the PAD, to ensure that the treatment system is capable of
reducing associated contaminants as appropriate.
49
ATTACHMENT 5
Fiskville site plan
50
ATTACHMENT 6
Environmental assessment works The following studies form the package of environmental assessment work. Full reports are
available on the EPA website.
Study 1: Review of Standard Operating Procedures for Fire Fighting Training, CFA Fiskville and
Regional Training Grounds, Victoria, Cardno, 18 April 2013
Study 2: Feasibility Study of Water System Upgrade, Diversion Work and Remediation, CFA
Fiskville Training College, Cardno, December 2013
Study 3: Environment - Site History Review, Cardno, March 2014
Study 4: Environment – Soil Assessments, Cardno, March 2014
Study 5: Environment - Buried Drums Assessment, Cardno, March 2014
Study 6: Environment – Groundwater Contamination Assessment, Cardno, March 2014
Study 7: Environment – Surface Water and Sediment Contamination Assessment, Cardno,
March 2014
Study 8: Environment – Investigation of Risks at Former Landfills, Cardno, March 2014
Study 9: Environment – Environmental Sampling and PFC Analysis Program, Adjacent Land,
Fiskville, Cardno, March 2014
Study 10: Environment - Aquatic Ecology Assessment, Cardno, March 2014
Study 11: Ecological Risk Assessment, Fiskville Training Grounds, Senversa, 28 January 2015
1. Review of Standard Operating Procedures for Fire Fighting Training, CFA
Fiskville and Regional Training Grounds, Victoria, Cardno, 18 April 2013
The specific objectives of Cardno's review of the Standard Operating Procedures (SOPs)
were to:
a) identify the potential risks to worker health and safety from occupational exposure
during current training practices using supplied water, and the risks of exposure to
sediments in dams;
b) assess the adequacy of occupational health and safety SOPs to protect workers from
excessive exposure to water used in training; and
c) provide specific and detailed comments to improve current SOPs or introduce new
SOPs considered necessary.
Cardno provided advice regarding recommended upgrades to SOPs following its review,
along with a set of minimum example SOPs for the critical activities and tasks.
As a result of the review, the SOPs have been developed within the context that CFA has
taken all practicable measures to prevent personnel from becoming exposed to water and
sediments in the dams and Lake Fiskville. This includes the following:
a) Fiskville staff members have been briefed (in face to face sessions with the CEO) not
to access the dams or Lake Fiskville and not to fish or eat fish from those water
bodies;
b) trainees attending Fiskville are advised not to access dams or Lake Fiskville through
site induction procedures;
c) the dams are no longer used as a water supply for hot fire training, and regular water
testing of these water bodies has ceased;
d) hazards associated with fire water prior to its use in fire fighting training activities have
been removed as a result of CFA's reliance on town mains water since 26 June 2012 as
its sole water supply;
51
e) CFA staff and visitors to the site are not permitted to enter Lake Fiskville or the dams;
f) signs have been posted around all of the dams and Lake Fiskville advising "No
Fishing", "No Drinking" and "No Swimming";
g) Dams 1 and 2 have been fenced to prevent access; and
h) advertisements have been posted in the local newspapers advising the community not
to fish or eat fish from Lake Fiskville, and advising them to contact CFA if they have
eaten fish in the past.
The following procedures have been documented and implemented to ensure all staff and
visitors to Fiskville are advised of the location of the water bodies, the potential hazards,
instructions not to access them, and safety procedures in the event a person must access
them for maintenance:
(i) Contractor management - all external contractors are provided an induction to warn
them of the hazards on site (including water hazards), and are expected to provide a
Job Safety Analysis, provide evidence of appropriate occupational health and safety
procedures and follow these procedures when carrying out their work. The relevant
procedures are SOP 1.08 (Induction and Supervision) and SOP 1.08.S1 (Induction
Checklist).
(ii) Grounds maintenance workers – limited maintenance work is undertaken around the
dams or Lake Fiskville. Any maintenance workers who may have occasion to work
around the Lake or dams are provided an induction SOP 1.08 (Induction and
Supervision) and SOP 1.08.S1 (Induction Checklist) (where appropriate) and Appendix
4 (Grounds Maintenance Work Practices Induction of the CFA State Training College –
Fiskville Induction Package 2013).
(iii) Trainees – all trainees are provided an induction. These procedures form part of the
PAD Operations Manual. The specific PAD Operations Guidelines (POG) that are
relevant are: POG 4.08 re Water Supplies, POG 2.07.S1 re Pre Training Safety
Briefing; and PAD Instructor Induction Checklist.
(iv) Dam rescue – if any staff or visitors accidentally fall into the Lake or dams the Dam
Water Rescue procedure (POG 2.12.S1) and Dam Water Exposure Guideline (POG
2.12) are followed. These procedures form part of the PAD Operations Manual.
On 28 November 2013, CFA provided the Auditor with evidence regarding the status of
the development and implementation of these SOPs (as requested by the Auditor in a
letter dated 24 October 2013).
2. Feasibility Study of Water System Upgrade, Diversion Work and Remediation,
CFA Fiskville Training College, Cardno, December 2013
This report was not completed to directly address any recommendations in the IFI Report,
however has come about from the recommendations in assessment works that have been
completed at Fiskville.
This report provides Cardno's opinions regarding remediation, and it should be noted that
Cardno are not PFC remediation experts. However, this provided us with an early
indication of the scope and indicative cost of work required. However, due to the
emergence of new technologies in the area of PFC remediation and the level of investment
required, CFA has put this work out to a three part open market tender:
1. Expression of Interest (completed in November 2014);
2. Early Tender Involvement (Proof of Concept / Bench Top Trials) Completed January
2015; and
3. RFT – not yet commenced and subject to approvals.
52
As a result of the above process, the feasibility of different remediation technologies and
options has been further assessed and actual technical solutions may differ from Cardno's
recommendations.
Objectives
(i) To identify, assess and recommend detailed options (including concept
designs and cost estimates) for:
(A) preventing the discharge of contaminated water currently stored in
the surface water bodies on site to surface waters downstream;
(B) water supply upgrades to service the PAD;
(C) the treatment of fire training water/effluent discharged from the PAD
to a standard that meets water quality criteria for discharge to the
waters protected by SEPP WoV; and
(D) the remediation of contaminated surface waters and sediments (in
dams and Lake Fiskville).
(ii) Identify and arrange for the necessary approvals from EPA and other
authorities.
Recommendations
(i) Creek Diversion: Design and Install a Channel and Bund from Resident Drive to Lake
Road and then channel to the outlet of Lake Fiskville to Beremboke Creek. The
design has commenced for this component of the work. Completed.
(ii) Stormwater Diversion: Upgrade the stormwater management infrastructure by
diverting surface water catchment away from the dams to minimise the cascading
effect and the potential off-site migration of contaminated water from overflowing
dams during periods of high rainfall. Divert the stormwater that leaves the FLP into
the spoon drain for off-site discharge. Construct a wetland to have stormwater flow
through to allow for capture of contaminants. Bund Dam 4 to increase storage
capacity by 1.4 megalitres. Additional works were also proposed to contain the
runoff from the PAD to Lake Fiskville prior to the installation of the water treatment
plant. It is proposed to build a 750mm high bund across the outfall of Lake Fiskville,
providing 18 megalitres of additional capacity. Completed.
(iii) Water Supply: To improve security of supply, water availability for training, and long
term sustainability, it is recommended that an alternative water source and supply
also be provided to the current potable supply from CHW. Based on this
assessment, treated recirculated water is recommended. Longer term, consideration
is given to providing a connection from the proposed new waste water treatment
plant for the accommodation and administration buildings subject to appropriate
treatment to further enhance security of supply. That approval and volumes be
sought and confirmed to extract raw water from Lake Fiskville as an alternate supply
long term post remediation subject to appropriate treatment. Water recycling is a
key component of remediation works planned for Fiskville.
(iv) Water Storage: The 250 kilolitre tank at the FLP be relocated to the secondary pump
to reduce the current impact on the parade ground as requested by CFA. This tank
is replaced with sufficient storage (i.e. preferably a minimum nominal or net capacity
of approximately 250 kilolitre and currently proposed by CFA as 2 x 150 kilolitre
gross capacity tanks) such that the tank configuration does not impact on the ability
to continue to supply the primary pump station. That further additional storage is
either incorporated in any new proposed Treatment Plant providing treated water
and currently nominated to be located near the existing safety pump station for the
FLP or provided at the primary pump station. Storage in excess of 500 kilolitre each
53
at the primary and secondary pump station is ultimately recommended. It is
recommended the design allow for additional tanks or storage to be progressively
added at each of the pump stations as the need arises and current and future
training demands are confirmed. Dam 1 is retained as a potential emergency or
buffering storage facility.
(v) Upgrade Water Mains: The reported 1” main to the tank at the secondary/safety
pump. CFA has proposed a 2” main parallel to the existing main as immediate
works. The 4” main can be a long term measure if a proposed treatment plant and
water recycling proceeds.
(vi) Water Treatment – No Foams: The existing system is recommended to be
augmented whether treating to discharge or recycle. A modular treatment system
involving coagulation, flocculation and sedimentation followed by lamella plate
settlers and activated carbon or other system to control pH and reduce BOD and
chemical oxygen demand, suspended solids, oils and TPH that may not be treated
effectively by the existing oil - water separator / triple interceptor trap is proposed.
Additional treatment and infrastructure post the treatment plant is required including
as a minimum disinfection (chlorine and ultraviolet treatment) to be able to recycle
the water. In progress
(vii) Water Treatment – With Foams: in this case the ‘No Foams’ system is recommended
to be augmented whether treating to discharge or recycle. The initial
recommendation is to design the same system as no foams as this will form the pre-
treatment with the addition of a modular Ultrafiltration plus Reverse Osmosis with
disinfection treatment system to allow recirculation of treated water “with foams”.
In progress.
(viii) Dam and Lake Water Remediation: To remediate water in Dams and Lake Fiskville it
is recommended to use the augmented treatment system described in the foams
scenario (pre-treatment before Ultrafiltration plus Reverse Osmosis). It is noted that
multiple passes may be required to allow for environmental criteria to be met for
discharge. In progress.
(ix) Sediment Remediation: On-site containment under a clay cap or Type 2 landfill cell
of sediment (subject to auditor approval) is recommended following removal from
the lake and dams using a floating dredge. GeotubeTM containers are recommended
to dewater sediments as they can handle gravelly sediment (expected to be
encountered during dredging), which can cause problems for centrifuge units. The
proposed remediation techniques will require further sediment analysis and
preparation of a remedial plan and Auditor approval prior to final determination. In
progress.
(x) VUT Premises Effluent: In addition to the above it is recommended that that the
Victorian University of Technology building cease discharging into Dam 1 and that
water used in the building is captured and treated/disposed of separately to the
water used in fire training. It is also recommended that a management plan be put
in place to address this issue. In progress. As part of Stage 1 of the clean up plan,
physical barriers were implemented to prevent water generated within the VUT
building from discharging into Dam 1, and agreements were reached with VUT for it
to capture and appropriately dispose of their industrial waste water (off-site)
independently of CFA. Despite repeated requests, VUT have still not provided a
management plan for the building.
3. Environment - Site History Review, Cardno, March 2014
Objectives
Identify the past or current activities and facilities at Fiskville with potential to
cause contamination of the land or water and to identify those already investigated
and potentially requiring investigation.
Findings
54
The review confirmed the features identified in the IFI Report as potential
contamination sources and several additional features as well as clarifying some
ambiguities around the identity of site features.
Nine areas already assessed were identified.
The areas with potential for contamination not yet assessed and which might
require assessment, subject to the requirements of the Auditor are:
A sewage treatment plant (feature 5) including septic tank and sewerage
discharge area (feature 40) located to the west of the administration building;
Drum fire area (feature 49) to the east of the learning centre (feature 3);
Maintenance workshop (feature 6) near the learning centre (feature 3), the
garden and maintenance workshop (feature 52) near the residential area and
amenities building 2 (feature 16b) where equipment and/or machinery are
stored and/or maintained, and small volumes of fuels and chemicals may be
stored;
Areas of fill including the driver education training PAD (feature 21a), fill
platform in the operational area and beneath the FLP (feature 27) which was
backfilled as part of soil remediation;
Airstrip (feature 14) and associated hangar (feature 13). CFA has advised that
the hangar is not used for fuel or chemical storage;
Drainage channels and pipes for PAD effluent located between Dams 1 to 4,
including a crushed concrete pipe between Dams 1 and 2 which is likely to be
leaking;
Above ground storage tank 3 (feature 23c) adjacent to Dam 2;
VUT Building (feature 31) where research is conducted on the flammability of
materials used in buildings and effluent including foam waste is discharged into
Dam 1;
Other PADs around Fiskville used for fire training including wildfire PAD
(feature 15), explosives PAD (feature 21a), liquefied petroleum gas PADS
(features 32 and 32b) and structural fire attack PADs (features 33a and 33b);
Three former diesel powered generators associated with Amalgamated
Wireless (Australasia)/Overseas Telecommunications (Australia) Commission
site use which were probably located in the learning centre (feature 3) and
ceased operating in 1941;
Offsite land use for farming which may include use of pesticides, although
impacts to Fiskville are considered unlikely; and
The area of stockpiles of unidentified soil/material (feature 60) located off
Deep Creek Road west of Beremboke Creek.
Recommendations, corresponding 53V audit recommendation and action
55
Recommendation Corresponding
section 53V audit
recommendation
Action* Status
Investigation of the potentially
contaminated areas identified in Table
3-4 of this report, if they have not
already been assessed in other Cardno
reports and subject to the
requirements of the Auditor.
20 Stage 2** Not started
The scope of this further investigation
and assessment should be confirmed
with the Auditor and recorded in a
SAQP prior to commencement and
should be undertaken at the same
time as other assessment works to
assist with the completion of a section
53X audit.
N/A Stage 2 Commenced
The volumetric balance of the soil
windrows in the soil compositing area
should be assessed by a surveyor to
confirm if it is all accounted for on-site
(e.g. by comparing initial volume in
windrows and current mounds in the
driver education training PAD, also
known as the 4WD area).
21 Stage 2 Not started
It is recommended in relation to the
VUT facility that they should
discontinue any effluent discharge to
CFA property (including Dam 1) and
be required to plan for management of
their liquid effluent independently of
CFA in the future.
25 Stage 1
Stage 5
Complete
An Environmental Management Plan
should be prepared and implemented
by VUT to control and minimise all
impacts on the environment including
land and water on and off-site from
their facility and for management of
solid and liquid wastes.
26 Stage 5 CFA has
requested
VUT to
provide this
but it has not
yet complied.
(moratorium
on all VUT
activities
pending
completion)
* Stages in this and following tables refer to clean up plan stages.
**Will be considered as the scope of further site assessments is set during Stage 2.
4. Environment – Soil Assessments, Cardno, March 2014
The purpose of the assessment was to provide advice on the soil contamination status of
targeted areas identified for investigation in the IFI Report included in this assessment,
and the consequent implications for the suitability of the site for its continued use as a fire
fighter training college. The targeted areas included:
56
Current and former aboveground (AST 1 and 2) (features 23a and 23b) and
underground storage tanks (UST 1 and 2) (feature 8a and 8b) for diesel and petrol;
FLP (feature 27);
FMA (feature 22);
Former foam training pits (feature 45);
Prop storage area (feature 17); and
Soil composting area (feature 44).
Objectives
(i) Assess whether the beneficial uses of land appropriate for the current land use are
impacted by contamination in the targeted areas.
(ii) In the event that significant contamination or potential for significant contamination is
found, provide recommendations for further work necessary to define the need for
remediation to make the site suitable for its current use.
Findings
The results of soil testing in the targeted areas indicate that there are isolated
areas of soil impacts, none of which presents an impediment to the continued use
of the site for fire fighting training. Soil contamination is unlikely to pose any risks
to human health based on the current land use.
Recommendations
Targeted Soil Assessment –
Recommendation Corresponding
section 53V audit
recommendation
Action Status
The soil at the FLP and former foam
training pits should be further
investigated to delineate the PFOS and
potentially 6:2 fluorotelomer sulfonate
contamination on the periphery of the
area remediated in 1998. This includes
lateral and vertical delineation at the
base of the previously remediated
area.
20 Stage 2* Not started
While risks to the health of the few
persons potentially exposed to soil
contaminated with PFOS in the FLP
and former foam training pits area is
assessed to be low, exposures should
be minimised through the use of
appropriate OHS procedures where
direct contact with soil is likely, such
as when cutting grass around Dam 1
or excavating soil near the adjacent
oil-water separator.
Project 12
(HSEMS)
of ITFP
Completed
The potential risk to ecosystems
outside the FLP, former foam training
pits and soil compositing areas due to
PFOS contaminated soils, as a result of
migration of contaminants to
stormwater drains, requires further
assessment and management by
5, 20 Stage 1
Stage 2*
Stage 4
Drainage
systems have
been
improved
during Stage
1, but further
assessment
57
Recommendation Corresponding
section 53V audit
recommendation
Action Status
improving the drainage system in the
vicinity of Dams 1 and 2.
Stage 6 and
remediation
work is
required to
fully address
this
The impacted soil at underground
storage tank 1 and FMA should be
further investigated to delineate the
TPH contamination. The contamination
in these areas does not present a
health risk, however it is odorous
when exposed to air and should be
managed by applying OHS and
environmental procedures (to be
contained in the proposed Site
Contamination Management Plan) if
excavation occurs in these limited
areas.
20 Stage 2*
and Project
12
(HSEMS)
Not started
The soil beneath this aboveground
storage tank 2 should be assessed as
aboveground storage tank has now
been removed.
20 Stage 2* Not started
All features listed in “Areas Not Yet
Investigated” (refer to Section 4.1.2 of
the Cardno Site History Review report)
which are not included in this
investigation, are also recommended
for further assessment.
20 Stage 2* Not started
* Will be considered as the scope of further site assessments is set during Stage 2.
Surface Soil Assessment - 4WD High Mound –
Cardno undertook an inspection and limited surface sampling of an earthen mound
in the driver education training PAD (feature 21a) also known as the 4WD training
area. This work arose from anecdotal information stating that the highest mound
in the 4WD training mound ("high mound") includes soil derived from sediments
excavated from the bed of Lake Fiskville. This testing was also recommended in
the Cardno Site History Review.
Purpose
The purpose of the investigation was to assess the high mound for surface soil
contamination and/or visible asbestos originating from previous site activities and
make recommendations for managing potential health and safety risks for users of
the soil mound.
Findings
The results indicate that the soil texture on the northern side of the high mound is
consistent with Lake sediments. Contaminant levels do not exceed the assessment
58
criteria for commercial or industrial land use and does not pose any significant risk
for the continued use of the high mound for 4WD training.
Recommendations
Recommendation Corresponding
section 53V audit
recommendation
Action Status
Exposure of trainees to soil (dirt and
mud) and any potential
contaminants contained within
should always be minimised by the
use of standard OHS practices
including the use of PPE.
Communicate
d to campus
management
HSEMS
(Project 12 of
ITFP)
Completed
The entire area of the driver
education training PAD (Feature 21a)
or four wheel drive training facility at
Fiskville should be assessed for
contamination in accordance with the
recommendations of the Cardno Site
History Review.
20 Stage 2* Not started
* Will be considered as the scope of further site assessments is set during Stage 2.
5. Environment - Buried Drums Assessment, Cardno, March 2014
The IFI Report did not contain a specific recommendation to investigate Fiskville for the
presence of buried drums. It did however contain a recommendation to investigate for
contamination in specific areas (Recommendation 7). CFA considered it prudent to also
investigate each of these areas for the potential presence of buried drums.
Note that this assessment does not investigate the presence of buried drums in the landfill
area as this is dealt with the Cardno report, "Investigation of Risks at Former Landfills".
Due to the uncertainty with the information regarding drum burial areas coming out of the
IFI Report, Cardno undertook detailed electromagnetic geophysical and intrusive
investigations of any geophysical anomalies found to try and locate any buried drums.
Objectives
(iii) Identify the presence of drums in the drum burial areas identified in the IFI
Report and in one additional area from anecdotal information provided
subsequently (following fieldworks, two further areas were identified as
requiring further investigation, which was also done as part of this
assessment).
(iv) If drums are found, assess the presence of contamination and the potential
for protected beneficial uses to be impacted.
(v) Provide recommendations for further work as needed.
(vi) Conduct the work to a standard which will enable it to be used as part of the
assessment required by the Auditor.
Findings
59
No buried drums were found in any of the areas identified in the IFI. No elevated
contaminants indicative of leaking flammable liquids from buried drums were
reported.
Cardno advise that if there are drums still buried anywhere on site, there is only a
minor potential for them to be a source of impact to groundwater as groundwater
occurs at a considerable depth (greater than 60 metres) at the site and is overlain
by low permeability soils.
Recommendations
Recommendation Corresponding
section 53V audit
recommendation
Action Status
In the event that further information
becomes available regarding possible
drum burial or any discoveries of
buried drums are made, the proposed
Site Contamination Management Plan
and its protocols should be
implemented to investigate and
manage the issue.
15 Stage 5 Procedures
for
excavations
have been
developed
and
implemented.
These
procedures
specifically
address what
to do in the
event anyone
encounters
buried
drums.
Should additional drums be uncovered
in the future outside of areas already
assessed, further investigation of
groundwater is required including the
perched water areas if identified.
Stage 5 To date no
buried drums
have been
uncovered.
Perched water identified in drum burial
area 1 and drum burial area 2 should
also be further investigated as per the
recommendation discussed in the
Groundwater Contamination
Assessment Report, to further
investigate the presence and quality of
the perched water areas at the site.
Stage 2* Not started
* Will be considered as the scope of further site assessments is set during Stage 2.
CFA notes that the Emergency Management System has procedures in place for
any excavations on site to be both aware of the possibility of drums and a course
of action in the event that such drums are subsequently found.
6. Environment – Groundwater Contamination Assessment, Cardno, March 2014
The purpose of the report is to provide preliminary advice on the groundwater
contamination status of Fiskville.
Objectives
60
(vii) Assess the hydrogeological conditions at Fiskville as a basis for
understanding the occurrence and flow of groundwater and its vulnerability
to contamination.
(viii) Identify the past or current activities at Fiskville with potential to cause
contamination of groundwater at Fiskville.
(ix) Assess the groundwater for contaminants at Fiskville in the areas defined in
the IFI Report.
(x) Provide a preliminary assessment of the feasibility for obtaining a supply of
water from groundwater sources for fire fighter training at Fiskville.
(xi) Conduct the work to a standard which will enable it to be used as part of the
assessment required by the Auditor.
Findings
The results of groundwater testing indicate that there is a low risk of groundwater
contamination by sources at the site surface, or the subsequent contamination of
surface water by discharging groundwater. This is due to the considerable depth of
the regional water table (more than 60 metres) and its protection by overlying low
permeability soils and small number of groundwater bore users near Fiskville.
A small area of saturated soil (about 1-3 meters deep around Dam 2 and the FLP)
was identified, and which contained concentrations of PFCs. The contaminated
perched water is of no significance as "groundwater contamination" as the water is
limited to this area and would not be extracted for any use. However, the water
requires management because it has the potential to seep towards the stormwater
drain and it is in hydraulic connection with Dams 1 and 2, which are contaminated
and discharge to Lake Fiskville and then potentially off-site (CFA notes that this is
no longer the case). The perched water is proposed to be remediated together
with the contents of the dams, and the proposed further investigations will
contribute to the design of this remedial response.
Recommendations
Recommendation Corresponding
section 53V audit
recommendation
Action Status
Further work is recommended to
investigate the extent of PFC
contamination in the shallow, perched
water in the fill near Dams 1 and 2
and the FLP, and its potential to seep
to the stormwater drainage system.
5, 14 Stage 6
Stage 2
Commenced
1/15
An assessment of the feasibility of
remediating PFC contamination in the
perched water should be completed
after the further investigation of the
area, including hydraulic testing of the
fill.
3, 4 Stage 4 Three stage
procurement
process is in
progress
It is possible that some of the new
bores installed during 2012 may ‘gain’
groundwater over time. During the
next monitoring round, it is
12 Stage 2 Bores gauged
1/15
61
Recommendation Corresponding
section 53V audit
recommendation
Action Status
recommended that all bores should be
gauged for water level and, if sufficient
water is present, the bores should be
developed and sampled to establish a
scope for the investigation of regional
groundwater.
While further investigation of the
regional aquifers is not required at this
time, the Auditor should be consulted
to ascertain his requirements for any
further investigations.
N/A Stage 2* The Auditor's
recommendat
ions were
actioned in
1/15. The
Auditor will
be consulted
to determine
any further
requirements
.
In the event that a Reverse Osmosis
water treatment plant is installed at
the site, the feasibility of using the
plant to treat the deep saline
groundwater as a water supply for fire
fighter training should be considered.
Stage 4 Is being
considered as
part of the
water
treatment
options for
the site
* Will be considered as the scope of further site assessments is set during Stage 2.
7. Environment – Surface Water and Sediment Contamination Assessment, Cardno,
March 2014
Objectives
(i) Investigate potential sources of PFOS and PFOA and other key contaminants
discharging into Lake Fiskville and discharging off-site;
(ii) assess the quality of surface waters and sediments on-site at Fiskville and off-site
both downstream and upstream from Lake Fiskville;
(iii) assess the background concentrations of key contaminants including PFOS, PFOA,
zinc and copper; and
(iv) assess water quality of surface water discharge to the receiving water bodies
protected by the SEPP WoV.
Findings
The water management system at Fiskville has been a source of PFC entering Lake
Fiskville and the downstream surface water environment since the use of PFC-
containing foams commenced (discontinued in 2007).
The concentrations of copper and zinc in water and sediment on-site, and in water
discharging from the site, is elevated above background levels.
The off-site water bodies are protected by the SEPP WoV and Lake Fiskville is
deemed to be protected due to its evident environmental values.
62
The sediments in water bodies on-site have been impacted by PFC, hydrocarbons
and metals. The sediments in water bodies off-site are contaminated with PFCs
exceeding the criterion for a distance of not more than 2 kilometres downstream
(and the concentration rapidly decreases between the site and that distance).
The assessment of PFOA and PFOS in the off-site water samples showed detectable
levels of PFC downstream at a distance of up to 18 kilometres. The next sample
downstream was 28 kilometres from Fiskville and reported no detectable level of
PFOA or PFOS. Locations between 18 and 28 kilometres downstream of Fiskville
are on private property and were not accessible for testing.
The sediment and water in Lake Fiskville requires remediation, as does the dams
given they are an ongoing source of PFC contamination to Lake Fiskville and water
bodies downstream.
Recommendations
Surface Water and Sediment Contamination Assessment:
Recommendation Corresponding
section 53V audit
recommendation
Action Status
All reasonable measures be taken to
reduce or stop further discharge of
contaminated water from the water
management system at the site,
including Lake Fiskville, from
discharging to surface waters
downstream
1 Stage 1
Stage 4
Stage 1
complete
Surface soil sampling and testing
should be conducted along the
‘former’ drainage lines which
connected Dam 1 to Lake Fiskville
20 Stage 2* Partially
complete
Further sediment sampling and
testing should be undertaken to
confirm the extent of PFC
contamination in the creek and farm
dams on the creek downstream of
Fiskville on Beremboke Creek.
N/A Cardno
downstream
assessment
(see below)
Completed
The data in this report on water and
sediment quality be taken into
account in the assessment of
ecological or human health risk
undertaken for the site or
downstream
N/A Cardno HHRAs
and Ecological
Assessment
Completed
Assess the potential for nutrients
from the sewerage treatment plant
(the existing or upgraded unit) to
impact on the water quality of Lake
Fiskville
Stage 2* Not started
Assess the PFCs contribution from
leaching of residual aqueous film
forming foam adsorbed onto
22 Stage 4 Testing
undertaken
in January
63
Recommendation Corresponding
section 53V audit
recommendation
Action Status
infrastructure in the PAD Stage 2 2015.
Further surface water and/or
sediment assessments should
include a selective screening for
extended PFC also present at
Fiskville
Stage 2
Stage 6
Testing /
monitoring
commenced
in
September
2014.
Remediation works should be carried
out based on the assessments of risk
and the feasibility of remediation.
Following the conclusion of the
feasibility assessment, the most
suitable option for remediation and
management of surface water and
sediments in the on-site water
bodies should be implemented
3, 4 Stage 4 Three stage
procuremen
t process is
in progress
* Will be considered as the scope of further site assessments is set during Stage 2.
Supplementary Surface Water and Sediment Sampling Downstream (this report is
included as Appendix I to the Surface Water and Sediment Contamination
Assessment):
The objectives of this additional assessment are to investigate concentrations of
PFOS, PFOA including extended PFC screen, and selected metals downstream of
Lake Fiskville, and to provide data to be used as a basis of ecological and HHRAs.
The results show that this portion of Beremboke Creek has been impacted by the
discharge of contaminants in effluent discharged to Lake Fiskville and the surface
water downstream.
Recommendation Corresponding
section 53V audit
recommendation
Action Status
All reasonable measures be taken to
reduce or stop further discharge of
contaminated water from the water
management system, including Lake
Fiskville, from discharging to surface
waters downstream, including
monitoring data of surface water
flows from Lake Fiskville (time,
volumes and duration)
1, 2, 6 Stage 1
Stage 4
Stage 6
Stage 1
completed.
Stage 4 –
tender in
progress.
Stage 6 –
monitoring
commenced
in September
2014
Consideration should be given to
include extended PFC analysis for
future surface water and sediment
assessment
Stage 2
Stage 6
Commenced
and ongoing
64
Delineate the level of PFC
concentrations in water and
sediment extending downstream
between Lake Fiskville and the
confluence of the Beremboke and
Eclipse Creeks
Stage 6* Not started
*Will be considered as the monitoring regime is formulated
8. Environment – Investigation of Risks at Former Landfills, Cardno, March 2014
Objectives
(i) Assess landfills 1 (former Amalgamated Wireless Australasia landfill) and 2 (former
CFA landfill) to identify their extent and examine landfill cover and general
condition.
(ii) Identify any immediate risks and take action as needed to ensure the safety of
individuals who may come into contact with the landfill sites including users of the
walking track.
(iii) Assess the presence of buried drums.
(iv) Assess landfill gas emissions and potential risks.
(v) Provide advice in accordance with most current regulatory guidelines.
(vi) Prepare a risk-based Landfill Management Plan, including a specification and
estimated costs for a new cover system.
Findings
The general condition of the cover over the landfill 1 area is unsatisfactory,
however there was no material that could be carried by wind, and there was no
offensive odour noticed.
There is contamination by lead and copper as well as petroleum hydrocarbons and
PFC at the base of the landfill, however there is no significant leachable source of
contamination in the waste material.
Fencing along both sides of the footpath, as well as round the entire former landfill
area, is required to discourage access to the landfill area. This is a temporary
measure and needs to be replaced with the application of a clay cover.
There are a small number of steel drums in various stages of crushing and decay,
as well as plastic drums. The drums did not have the appearance of a mass burial
of up to 100 drums as suggested by the anecdotal history of the area. The plastic
drums included foam concentrate drums as well as food containers. The steel
drums and the surrounding soil were assessed and evidence was found of residues
from fire fighting foams.
Given the lack of evidence of a mass burial of drums or widespread contamination
of seepage from the landfill, no exhumation of buried waste is considered
necessary. Rather, the area needs to be managed as detailed in a Landfill
Environmental Management Plan (presented as appendix J to this report).
Perched water was encountered in some test pits in landfill 2. This is localised, and
due to the clay soil profile, there is a negligible risk of this water migrating from
65
the landfill to impact the nearby creek (however, the Auditor indicated a preference
for further characterisation to confirm these findings).
The risk to groundwater due to the presence of waste is negligible, and will be
virtually eliminated following the placement of the clay and soil cover (the Auditor
has indicated a preference for further testing of the soil underlying the landfill to
add weight to the arguments that the landfill has not caused contamination to seep
below the base of the landfill).
There is a negligible risk to a user of the footpath or the residents situated to the
north-east of the area (or any other occupant of the site) due to landfill gas. There
is no justification for further monitoring of landfill gas other than as part of OHS
management of any intrusive works at the landfills.
Recommendations
Recommendation Corresponding
section 53V audit
recommendation
Action Status
The Auditor be consulted with regard
to the potential requirement for
further characterisation of the
perched water found within some
areas of landfill 2.
Stage 2* Not started
The Auditor be consulted with regard
to the need for any further soil
testing at the base of the landfill to
demonstrate lack of migration of
contamination from the landfill.
Stage 2* Not started
The adequacy of the Landfill
Environmental Management Plan be
discussed and agreed with the
Auditor.
Stage 4 Not started
Subject to Auditor review, the CFA
adopts the Landfill Environmental
Management Plan as a guide to the
rehabilitation and management of
the former landfill area in the south
western area of Fiskville.
16, 17 Stage 4
Stage 5
Not started
* Will be considered as the scope of further site assessments is set during Stage 2.
9. Environment – Environmental Sampling and PFC Analysis Program, Adjacent
Land, Fiskville, Cardno, March 2014
Objectives
The purpose of the investigation was to assess farmland adjacent to the south of
Fiskville for impacts from the fire fighting training activities at Fiskville.
The specific objective of this assessment was to investigate and identify, to the
extent practicable, the impact of PFCS, specifically PFOS, PFOA and 6:2
Fluoroteolmer Sulfonate (6:2FtS), on soil, sediments, grass, dam water and
drinking water. While PFCs were the primary Contaminant of Potential Concern,
selected sediment samples were also analysed for some metals, petroleum
66
hydrocarbons and the suite of analyses required by waste soil classification in
accordance with EPA Publication IWRG621, 2009.
The report is factual in nature and the level of interpretation was limited to
identification of the presence or absence of impact by PFCs. This information was
taken into account in a further assessment of risks to persons downstream of
Fiskville.
Findings
Soil
(i) The detection of PFCs in the near surface soil indicates that surface soil has
been impacted by fire fighting training activities at Fiskville.
(ii) The areas most impacted by PFCs were the flood plain of Beremboke Creek
and to a lesser extent the northern portion of the farm adjoining Fiskville.
Sediment
(iii) The sediments in the dam have been impacted by activities at Fiskville due
to the detection of PFCs.
(iv) Petroleum hydrocarbons reported as TPH (C16-C34 and C29-C36) were
recorded in sediment samples collected from the main dam.
(v) Metals (arsenic, cadmium, chromium, copper, lead, molybedenum, nickel
and zinc) were also detected in the sediment samples; however, the
concentrations are indicative of background contaminations and not
necessarily derived from CFA activities.
Dam Water
(vi) The detection of PFCs in the water indicates that it has been impacted by
fire-fighting training activities at Fiskville.
Rain Water Storage Tanks
(vii) All tank water samples reported PFCs below the analytical laboratory
reporting limit and well below the drinking water criteria. Tank water is not
impacted by airborne fall-out from activities at the CFA site.
Grass results
(viii) There is evidence that some grasses at the site have been impacted by
PFCs from the CFA site.
(ix) The areas most impacted by PFCs were from the flood plain of Beremboke
Creek and to a lesser extent the northern boundary of the site adjoining
the CFA site.
10. Environment - Aquatic Ecology Assessment, Cardno, March 2014
Objectives
(i) Assess the ecological risks in Lake Fiskville, Dams 1-4, Beremboke and Eclipse Creeks
and Moorabool River of the discharge of water from the fire training ground based on
water quality and sediment results.
(ii) Assess the impacts of contaminants on a range of aquatic life such as fish,
crustaceans and macroinvertabrates.
(iii) Provide conclusions and recommendations based on results of assessments.
Findings
67
The primary effect of Fiskville on the ecological condition of Lake Fiskville is to
cause high levels of PFCs (particularly PFOS) to occur in surface water, sediment
and aquatic biota of the lake, which is likely to affect the health of aquatic biota
that currently do, or potentially could, live in the lake. The overall ecological
condition of the lake is affected by Fiskville and a range of other external factors as
noted above. Notwithstanding this, the lake does provide some ecosystem services
such as provision of habitat for fish (most of which are introduced species),
invertebrates and wetland birds, and primary production (i.e. growth of aquatic
plants). Overall, the condition of the Lake Fiskville within the context of land use
within the region is assessed as being a modified ecosystem providing a moderate
range of ecosystem services.
Bioaccumulation analysis identified PFOS in fish from Site J, Moorabool River (and
to a lesser extent in fish sampled upstream of Eclipse Creek), hence it is possible
that Fiskville provides a source of bioavailable PFCs into Moorabool River via Eclipse
Creek.
The likelihood of PFCs accumulating in aquatic biota is identified as certain to highly
likely in Beremboke and Eclipse creeks and certain within Lake Fiskville. However,
the ecological consequence of this for the creeks is uncertain because they have
limited beneficial use due, at least in part, to their highly modified and ephemeral
condition downstream of Lake Fiskville. The Auditor determined that the ecological
impacts off-site are low and acceptable.
Lake Fiskville has been shown to contain PFCs in sediments and surface waters
and, as result of this assessment, in fish, invertebrates and aquatic plants. Other
contaminants appear to be less problematic. Nutrient concentrations in both the
water and sediments of Lake Fiskville are elevated, but there are likely to be
numerous sources of these into Lake Fiskville other than Fiskville (e.g. surrounding
farming activities). Lake Fiskville is artificial, but is connected by creeks within the
catchment of Moorabool River and hence constitutes a modified ecosystem. The
lake is assessed as having moderate ecological value due to the ecosystem services
it provides. On this basis, whatever practical measures that can be implemented to
reduce actual or potential impacts to the ecology of the lake should be considered
as part of the overall management strategy for Fiskville. Notwithstanding this, the
overall consideration for management should be protection of the ecological
services provided by the greater catchment.
Recommendations
Recommendation Corresponding
section 53V audit
recommendation
Action Status
Take all reasonable measures to
reduce or stop further discharge of
contaminated water from the water
management system at Fiskville,
including Lake Fiskville, from
discharging to surface waters
downstream.
1 Stage 1
Stage 4
The first
stage of
this work is
complete
Take all reasonable measures to
ensure that there is no stocking of
fish into Lake Fiskville
8 Communicate
d to staff and
management
Stage 5
Completed
68
Recommendation Corresponding
section 53V audit
recommendation
Action Status
Undertake further investigations in
relation to Moorabool River in the
reach downstream of its confluence
with Eclipse Creek (and if necessary
at appropriate reference locations).
Investigations that should be
considered include chemical analysis
of aquatic biota, quantitative surveys
of aquatic macroinvertebrates and
ecotoxicological experiments.
N/A Stage 6* Not started
Undertake further investigations of
Beremboke and Eclipse Creeks,
including the confluence of Eclipse
Creek with at Moorabool River (this
would require access to private
property). This investigation would
help to facilitate ecological risk
assessment and may provide more
data on PFOS in aquatic biota to help
define a gradient between Fiskville
and Moorabool River. Key objectives
would be to:
Confirm presence or absence of
any fish in farm dams (or any
large, natural pools) occurring
below downstream of Lake
Fiskville
Collect aquatic biota for analysis
of contaminants, particularly
PFCs
Describe in-channel and riparian
habitats
Undertake rapid assessment of
in-stream habitats (as described
in ANZECC 2000)
Investigate selection of sites for
possible longer term
quantitative monitoring.
N/A Stage 6* Not started
* Will be considered as the scope of further site assessments is set during Stage 2.
CFA notes that the recommendations to stop discharges from Lake Fiskville, and in
respect to stocking and fishing in Lake Fiskville, may warrant review after the planned
remediation work. If all contaminated sediment is removed and no further discharges
were planned, there may be no reason to continue with such restrictions depending on the
efficacy of these remedial works.
11. Ecological Risk Assessment, Fiskville Training Grounds, Senversa, 28 January
2015
Objectives
69
The Ecological Risk Assessment (ERA) was undertaken to refine the current
understanding of potential ecological risks on-site at Fiskville associated with
historical releases of PFCs during fire training activities.
The ERA used the available data collected by Cardno to assess whether the impacts
reported at the site would pose an unacceptable risk to ecological receptors at the
site (terrestrial receptors which may be exposed via direct contact with PFCs in
soil; aquatic plants and invertebrates which may absorb PFCs from the water
column; bird species which live on the water bodies; and higher order predators).
Of particular interest was the potential for PFOS to bioaccumulate within the food
web, with subsequent potential for higher order predators to be exposed to
elevated concentrations of PFOS.
Given the likelihood that exposure concentrations would decrease significantly in
the future, following active remediation of key source areas, exposure
concentrations were selected for the following scenarios:
(i) current "worst-case" exposure scenario, based on maximum reported
concentrations on-site;
(ii) current "average" exposure scenario, using a mean concentration calculated
from biota data collected on-site; and
(iii) a potential future risk profile, where it is assumed that surface water and
sediment within the on-site dams and drainage channels, and surface water
within Lake Fiskville, are remediated, but that sediment impacts in Lake
Fiskville remain. As the possibility of future re-partitioning of PFCs from Lake
Fiskville sediments to surface water cannot be ruled out, it has been
conservatively assumed for this scenario that future (post remediation) surface
water concentrations within Lake Fiskville may be similar to those reported
currently.
Findings
Based on current site conditions, risk estimates for the majority of identified
receptors were low and acceptable. The exceptions were the following:
(i) Potentially unacceptable risk was estimated for piscivorous birds where they
are assumed to consume 100% of their diet from the site (all dams and Lake
Fiskville), it is expected that biota concentrations within Lake Fiskville would
reduce following remediation of the dams, and therefore this risk estimate is
considered conservative and likely to overestimate actual risk;
(ii) Potentially unacceptable risk was estimated for predatory birds, where site
derived portion of the diet was assumed to the maximum estimated dietary
concentration. This risk prediction is considered overly conservative as their
average dietary concentration will be less. Risk estimates which assumed
ingestion of averaged biota concentrations are low and acceptable.
Overall, it was considered that the proposed remediation activities (Dams 1-4
sediment and surface water; and waters of Lake Fiskville) will reduce ecological
risks at the site to low and acceptable levels.