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P:\604X\60479059\6. Draft docs\6.1 Reports\6.1.2 SAQP\6.1.2.2 Aquatic Biota SAQP\Final\WLM_Aquatic Biota SAQP_FINAL.docx Revision FINAL – 02-Feb-2016 Prepared for – Department of Defence – ABN: N/A

RAAF Base Williamtown

Department of Defence

02-Feb-2016

Doc No. 002

Aquatic Biota Sampling, Analysis and Quality PlanStage 2B EI RAAF Base Williamtown

AECOM RAAF Base Williamtown Aquatic Biota Sampling, Analysis and Quality Plan


Aquatic Biota Sampling, Analysis and Quality Plan Stage 2B EI RAAF Base Williamtown

Client: Department of Defence

ABN: N/A

Prepared by

AECOM Services Pty Ltd Level 21, 420 George Street, Sydney NSW 2000, PO Box Q410, QVB Post Office NSW 1230, Australia T +61 2 8934 0000 F +61 2 8934 0001 www.aecom.com ABN 46 000 691 690

02-Feb-2016

Job No.: 60479059

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Quality Information

Document Aquatic Biota Sampling, Analysis and Quality Plan

Ref 60479059

Date 02-Feb-2016

Prepared by Roisin Smit / Michael Archer

Reviewed by Amanda Lee / Paul McCabe

Revision History

Revision Revision Date

Details Authorised

Name/Position Signature

A 15-Dec-2015 Draft Paul McCabeTechnical Director

B 18-Dec-2015 Draft Paul McCabeTechnical Director

C 15-Jan-2016 Draft Paul McCabeTechnical Director

D 25-Jan-2016 Draft Paul McCabeTechnical Director

FINAL 2-Feb-2016 Rev 02 Paul McCabe Technical Director

roisin.smit

Stamp



Table of Contents 1.0 Introduction 6

1.1 Background 6 1.2 Objectives 6 1.3 Framework 6

2.0 Data Quality Objectives 8 2.1 Data Quality Objectives 8 2.2 Assessment of Data Quality 11

2.2.1 Precision 11 2.2.2 Accuracy (Bias) 11 2.2.3 Representativeness 12 2.2.4 Completeness 12 2.2.5 Comparability 12 2.2.6 Data Quality Indicators 12

3.0 Health, Safety and Environmental Management 13 3.1 Health and Safety 13

4.0 Scope of Work for Sampling and Analysis 14 4.1 Proposed Sampling Locations 14 4.2 Target Biota 14 4.3 Proposed Number of Samples 17

4.3.1 Finfish 17 4.3.2 Shellfish 17

4.4 Laboratory Analysis 17 4.5 Logistics 19 4.6 Analytical Suite and Laboratory Analysis Methods 19 4.7 Sample Nomenclature and Labelling 20 4.8 Quality Assurance/Quality Control Sampling 20

4.8.1 Field Duplicate and Triplicate Samples 20 4.9 Fieldwork Documentation 20

4.9.1 Field Sampling Documentation 20 4.9.2 Sample Labels 20 4.9.3 Chain of Custody Forms 21

5.0 Aquatic Biota Consumption HHRA Methodology 22 5.1 Objectives 22 5.2 Overview of Approach 22 5.3 Issues Identification 23 5.4 Data Collection and Evaluation 23 5.5 Toxicity Assessment 23

5.5.1 Hazard Identification 23 5.5.2 Dose-Response Assessment 24 5.5.3 Background Exposure 25

5.6 Exposure Assessment 25 5.6.1 Exposure Assumptions 26 5.6.2 Exposure Point Concentrations 26 5.6.3 Estimation of Chemical Intakes 26

5.7 Risk Characterisation 26 5.7.1 Hazard Quotient 27 5.7.2 Uncertainty/ Sensitivity Analysis 27

6.0 References 1 7.0 Limitations 2

7.1 Ownership of Report 2

Appendix A Figures A

Appendix B Closure Notification B



Appendix C Standard Operating Procedure C



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1.0 Introduction

1.1 Background

Aqueous film forming foam (AFFF) containing perfluorinated compounds (PFCs), including perfluorooctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA), was historically used for firefighting training and operations at RAAF Base Williamtown (the Site).

Various stages of environmental investigation since December 2011 have aimed to characterise the extent of environmental impacts from the historical use of AFFF at the Site including:

- groundwater sampling on-Site and off-Site, including more recently from privately owned bores

- surface water sampling on-Site and off-Site from creeks, dams and drainage channels

- soil sampling on-Site to investigate potential source areas

- sediment sampling from off-Site creeks, dams and drainage channels

- vegetation sampling comprising the collection of 26 vegetation samples on-Site and 13 samples off-Site.

- aquatic biota sampling, in the form of small fish and aquatic macroinvertebrates, from 12 off-Site sampling locations

- aquatic biota sampling conducted by NSW Department of Primary Industries (DPI) in 2015

The data from these investigations, with the exception of the most recent DPI data, have been used to develop a conceptual site model (CSM) which was summarised in the URS (2015) Stage 2 Environmental Investigation report for the Site. A number of potential exposure pathways have been identified as requiring consideration in a Human Health Risk Assessment (HHRA) and works are continuing to evaluate the extent of impacts and characterise potential exposure via each pathway.

The preliminary CSM has identified a potentially complete pathway for accumulation of PFCs in the tissue of aquatic biota which are then consumed by humans. As the area surrounding the Site is an important recreational and commercial fishing industry, this pathway has been prioritised for targeted investigation and the preparation of a stand-alone aquatic biota assessment. The outcomes of the aquatic biota assessment will be used to inform the contribution, if any, of the human consumption of aquatic biota pathway to the overall assessment of risk. The results will be presented as an ‘Aquatic Biota Consumption HHRA’ which will be an interim advice document and the findings will subsequently be incorporated into a HHRA examining cumulative exposure via all potentially complete exposure pathways.

This sampling, analysis and quality plan (SAQP) is intended to guide the collection of aquatic biota data and analysis of the data for use in a HHRA only. That is, the works presented herein do not consider ecological receptors. The work presented in this document forms part of a larger scope of works presented in the AECOM (2016) document titled ‘Sampling Analysis and Quality Plan, RAAF Williamtown – Stage 2B Environmental Assessment’ currently in draft format and dated 16 January 2016.

This separate SAQP (AECOM, 2016) documents the collection of data from other media, such as soil, groundwater, surface water and sediment, in order to refine the CSM.

1.2 Objectives

The objectives of this document are:

- Describe the scope of work and methodology for collecting aquatic biota samples representative of the populations relevant to recreational and commercial fishing within upper Tilligerry Creek and Fullerton Cove.

- Describe the methodology for undertaking a HHRA for the human consumption of aquatic biota pathway only.

1.3 Framework

The national framework for undertaking HHRAs within Australia as detailed below are proposed to be adopted within the aquatic biota assessment which will be utilised in the overall HHRA:



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- enHealth (2012) Environmental health risk assessment: Guidelines for assessing human health risks from environmental hazards.

- the National Environment Protection (Assessment of Site Contamination) Measure 1999 (as amended 2013) [ASC NEPM 2013], specifically:

Schedule B2 Guideline on Site Characterisation.

Schedule B4 Guideline on Site-Specific Health Risk Assessment Methodology.

Schedule B7 Guideline on Derivation of Health-Based Investigation Levels.



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2.0 Data Quality Objectives

2.1 Data Quality Objectives

The ASC NEPM 2013 Schedule B2 specifies that the nature and quality of the data produced in an investigation will be determined by the Data Quality Objectives (DQOs). As referenced by the ASC NEPM 2013, the DQO process is detailed in the United States Environmental Protection Agency (US EPA) Guidance on Systematic Planning Using the Data Quality Objectives Process (EPA QA/G-4 : EPA/240/B-06/001), February 2006.

The US EPA defines the process as ‘a strategic planning approach based on the Scientific Method that is used to prepare for a data collection activity. It provides a systematic procedure for defining the criteria that a data collection design should satisfy, including when to collect samples, where to collect samples, the tolerable level of decision errors for the study, and how many samples to collect’.

The process of establishing appropriate DQOs is defined by the US EPA according to the following seven steps:

Table 1 The seven steps in defining DQOs

Step Data Quality Objective Step

1 State the problem – Define the problem that necessitates the study; identify the planning team, examine budget, schedule.

2 Identify the goal of the study – State how environmental data will be used in meeting objectives and solving the problem, identify study questions, define alternative outcomes.

3 Identify information inputs – Identify data & information needed to answer study questions.

4 Define the boundaries of the study – Specify the target population & characteristics of interest, define spatial & temporal limits, scale of inference.

5 Develop the analytic approach – Define the parameter of interest, specify the type of inference, and develop the logic for drawing conclusions from findings.

6 Specify performance or acceptance criteria – Develop performance criteria for new data being collected or acceptable criteria for existing data being considered for use.

7 Develop the plan for obtaining data – Select the resource-effective sampling and analysis plan that meets the performance criteria.

The approach adopted relative to the seven steps presented above is discussed below.

Step 1 – State the Problem

The problem is that:

- An area of groundwater and surface water contaminated by PFCs has been identified in association with historic use of AFFF on the Williamtown Base.

- Surface waters in the local area are of importance both as recreational and commercial fishing grounds.

- The extent of accumulation of Contaminants of Potential Concern (CoPC) in aquatic biota species in association with these water uses is currently not fully understood.

- Potential health risks to consumers of aquatic biota that may have accumulated PFCs in their tissue have not yet been characterised. However the preliminary CSM has identified a potentially complete pathway for accumulation of PFCs in the tissue of aquatic biota. In addition, a ‘Section 8 –Fishing Closure’ notification under the Fisheries Management Act 1994 has been issued for upper Tilligerry Creek, and Fullerton Cove (Appendix B). These locations are presented on Figure 1 in Appendix A and will be referred to as Area 1 and Area 2 respectively (further discussed in Step 4) and define the boundaries of the investigation.

- It is noted that a wide range of PFCs may be associated with historic use of AFFF, in variable proportions depending on the source product and the age of environmental impacts.

PFOS and PFOA have been the focus of international toxicological research and are commonly considered to be risk drivers for the chemical group. These two analytes will be quantitatively assessed as further discussed in Section 5.5. The full list of CoPCs that will be included in this SAQP comprise the following PFC compounds:

- PFOS



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- PFOA

- 6:2 FtS (1H, 1H, 2H, 2H- perfluoro octane sulfonate fluorotelemer)

- PFHxA (Perfluoro hexanoic acid)

- PFHpA (Perfluoro heptanoic acid)

- PFNA (Perfluoro nonanoic acid)

- PFDA (Perfluoro decanoic acid)

- PFUdA (Perfluoro undecanoic acid)

- PFDoA (Perfluoro dodecanoic acid)

- PFHxS (Perfluoro hexane sulfonic acid)

- 8:2 FtS (1H,1H,2H,2H-perfluoro decane sulfonate)

- Perfluorobutanesulfonic acid (PFBS)

Step 2 – Identify the Goal of the Study

The study goal identification component of the DQO process represents the key steps/issues that need to be reviewed/ considered in order to resolve the problem identified in Step 1.

The decision statement is as follows:

At what concentrations are the CoPC present in groundwater and surface water also detectable in the tissue of aquatic biota that are recreationally or commercially caught for human consumption in the investigation area?

What is the potential health risk associated with consuming aquatic biota that are recreationally or commercially caught for human consumption in the investigation area?

The key issues to be addressed are as follows:

1) Are the reported concentrations of the CoPC, in aquatic biota tissue from within the boundaries of the investigation, above laboratory limits of reporting (LOR) and is the LOR appropriate?

2) Are the analytical data valid?

3) Have sufficient data been collected to characterise the variation in concentrations of CoPC in aquatic biota tissue within the boundaries of the investigation?

4) What are the mean and upper estimate CoPC intakes for consumers of aquatic biota from within the boundaries of the investigation?

5) Are the mean and/or upper estimate CoPC intakes for consumers of aquatic biota from within the boundaries of the investigation likely to present an unacceptable risk to human health?

Step 3 – Identify Information Inputs

To allow assessment of the data against the study goal listed above, the following inputs will be considered:

- Previous results from sampling undertaken by URS and other data collected at the Base and surrounding areas (including biota data reported by NSW DPI where data quality can be established) will be used to define the boundaries of the investigation.

- Information about recreational and commercial fishing within the boundaries of the investigation compiled through consultation with the local fishing communities and DPI.

- The analytes selected for this project and standard laboratory detection limits are summarised in Table 5.

- The medium to be sampled is aquatic biota tissues that are consumed by humans.

- Information about consumption of aquatic biota will be sourced from the 2011-12 National Nutrition and Physical Activity Survey (NNPAS) component of the 2011-13 Australian Health Survey and other sources as appropriate.

- Consult with relevant local fishing communities with regards to the consumption of aquatic biota using the Community Reference Group (CRG) as a primary point of contact. It is noted that all contact will be made through Defence.



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Step 4 – Define the Boundaries of the Study

The spatial boundaries of this investigation are those defined by the ‘Section 8 –Fishing Closure’ notification boundaries presented in Appendix B. This notification defines two closure areas. The area in the notification that is part of Port Stephens known as upper Tilligerry Creek will be referred to as ‘Area 1’ and the area defined in the notification as part of the Hunter River known as Fullerton Cove is defined as ‘Area 2’. The study is limited to aquatic biota that are caught recreationally or commercially within the boundaries of these two areas for human consumption. The samples will be collected from within the boundaries of the investigation area as defined by Figures 2 and 3.

All biota sampling will be undertaken in publicly accessible areas under applicable licences and ethics approvals, unless permission is obtained to access private property.

The initial biota sampling event is planned for the first quarter of 2016. The need for additional biota sampling events will be evaluated based on the outcomes of the interim advice document completed after the first biota sampling event. It is noted that there is the potential for seasonal variation in environmental concentrations of PFCs and subsequent accumulation in aquatic biota tissue as a result of contaminant mobilisation from source areas during heavy rainfall events and seasonal animal movement.

Step 5 – Develop the Analytic Approach

The laboratory will analyse the aquatic biota samples the full suite of CoPC as defined in Step 1, with the protocol for sample preparation as per Appendix C.

The decision rule is to evaluate the concentrations of the CoPC in aquatic biota species based on the following:

- If the laboratory quality assurance/ quality control data are within the acceptable ranges (refer to Section 2.2), the data will be considered suitable for use.

- If the CoPC are reported above the laboratory LOR in one or more biota samples from a particular species, then the data will be further evaluated in a HHRA.

- If the CoPC are reported below the laboratory LOR in all biota samples from a particular species, then it will be considered that there is no evidence of a potential complete source-pathway-receptor linkage for accumulation of the CoPC in that species.

- The primary laboratory that will be used is National Measurement Institute (NMI), with the secondary laboratory proposed as AsureQuality. NMI will use their test method AUTL07, reference method USEPA537/821 and AsureQuality proposed to use analysis code DX-PFCS04//01.

Quality control samples will be collected in the form of one inter and intra laboratory duplicate per 10 primary samples per biota group as defined in Section 4.4. In addition, rinsate blanks will be collected from the sampling equipment in each of the two Areas to understand if there is the potential for cross contamination from the materials being used in sampling. Samples will be kept frozen to allow additional inter-lab checking if required.

Step 6 – Specify Performance or Acceptance Criteria

A decision error in the context of the decision rules in Step 5 would lead to either under-estimation or over-estimation of the risk level associated with a particular sampling area. Decision errors may include:

- Sampling errors may occur when the sampling program does not adequately detect the variability of a contaminant spatially across the investigation area. To address this, it is proposed to collect a minimum of 10 samples per biota group (as defined in Section 4.4) in Area 1 and Area 2 to statistical analysis to be undertaken. Additional samples, if present at the time of sampling, will be collected, frozen and placed on hold at the laboratory. The need for further analysis to evaluate the species (based on grouping) population mean will be evaluated based on the variation observed within this initial sample set.

- Upon completion of the initial sampling event and the Aquatic Biota Consumption HHRA, consideration of the need for the collection of additional samples to characterise potential variability in the biota population will be based on:

The range of concentrations reported within each biota group.

Descriptive statistics of concentrations within each biota type (as recommended by the ASC NEPM 2013, Schedule B2, Section 13.2). In addition, statistics of biometric data per group per Area will be presented.



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The margin of exposure for intakes of each biota type based on the maximum reported tissue concentration.

Consideration of potential for seasonal variation in aquatic biota tissue concentrations to influence the outcome of the HHRA.

- Measurement errors can occur during sample collection, handling, preparation, analysis and data reduction. To address this the following measures are proposed:

Collection of sufficient sample mass (50 grams) to facilitate analysis reported to standard laboratory detections limits. Collection of insufficient sample mass may result in raised detection limits.

Collection of additional samples to be frozen in the event that additional data is required. By collecting these samples at the same time as the initial biota, these biota are representative of the same sampling event.

Field staff to follow a standard procedure when collecting samples as presented in Appendix C

Laboratories to follow a standard procedure when preparing samples for analysis and undertaking analysis.

Laboratories to report quality assurance/ quality control data for comparison with the Data Quality Indicators (DQI) established for the project.

Laboratories will be requested to report the measurement uncertainty for each analytical result as per ISO 17025 and NATA requirements.

Step 7 – Develop the Plan for Obtaining Data

The methodology presented in this SAQP is designed to meet the objectives described in Section 1.2, and to achieve the nominated DQOs.

2.2 Assessment of Data Quality

The quality of the data collected as part of the sampling is assessed on a range of factors including:

- Documentation and data completeness

- Data quality – comparability, representativeness, precision and accuracy of the analytical data

2.2.1 Precision

Precision is a quantitative measure of the variability (or reproducibility) of data. Suitable criteria and/or performance indicators for assessment of precision include:

- Performance of laboratory duplicate samples through the calculation of relative percentage differences (RPDs).

- Performance of intra-laboratory field duplicate sample sets through calculation of RPDs.

- Performance of inter-laboratory field duplicate sample sets through calculation of RPDs.

- The RPDs will be assessed as acceptable if less than 30% as per the NEPM Schedule B3. Where the results shows greater than 30% difference a review of the cause will be conducted (NEPM, 2013) It is noted that RPDs that exceed this range may be considered acceptable where:

Results are less than 10 times the LOR

Results are less than 20 times the LOR and the RPD is less than 50%

2.2.2 Accuracy (Bias)

Accuracy is a quantitative measure of the closeness of reported data to the “true” value and is assessed through review of performance of:

- Method blanks, which are analysed for the analytes targeted in the primary samples

- Matrix spike and matrix spike duplicate samples

- Surrogate recoveries

- Laboratory control samples



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2.2.3 Representativeness

Representativeness is the confidence (expressed qualitatively) that data are representative of the media present in the two Areas. To ensure the data produced by the laboratory is representative of conditions encountered in the field, the following steps are taken by the laboratory and subsequently reviewed by AECOM:

- Review of RPD values for field and laboratory duplicates to provide an indication that the samples are generally homogeneous, with no unacceptable instances of significant sample matrix heterogeneities

- The appropriateness of collection methodologies, handling, storage and preservation techniques will be assessed to ensure/confirm there was minimal opportunity for sample interference or degradation.

2.2.4 Completeness

Completeness is a measure of the amount of useable data from a data collection activity. In validating the degree of completeness of the analytical data sets acquired during the program the following is considered:

- Whether standard operating procedures (SOPs) for sampling protocols have been adhered to

- Copies of all chain of custody (COC) documentation are reviewed and presented along with appropriate data validation.

It can therefore be considered whether the proportion of “useable data” generated in the data collection activities is sufficient for the purposes of assessing the problem as stated in Step 1 above.

2.2.5 Comparability

Comparability is a qualitative assessment in the confidence that data may be considered to be equivalent for each sampling and analytical event. Issues of comparability between data sets are addressed through adherence to SOPs and regulator endorsed or made guidelines and standards on each data gathering activity.

2.2.6 Data Quality Indicators

The acceptance criteria for DQIs are summarised in Table 2.

Table 2 Acceptance Criteria for Data Quality Indicators for Sample Analysis

Data Quality Indicators Acceptance Criteria

Rinsates (where sampling equipment is reused)

Less than the laboratory LOR.

Method blank Less than the laboratory LOR

Field duplicates/triplicates

RPD limits as follows:

- Results <10 times the (LOR : No Limit

- Results between 10-20 times LOR : RPD between 0-50%

- Results >20 times LOR : RPD between 0-30%

Laboratory duplicates RPDs less than: - 20% for high level laboratory duplicates (i.e. >20 x LOR) - 50% for medium level laboratory duplicates (i.e. 10 to 20 x LOR)

Matrix spikes Recoveries between 70-130% of the theoretical recovery or dynamic limits established by the laboratory.

Laboratory control samples Recoveries between laboratory specified range for each particular analyte/ analytical suite.

Surrogates Recoveries between 70-130% of the theoretical recovery or dynamic limits established by the laboratory.

In the event that acceptance criteria are not met, consideration will be given to either excluding the data or using the data as semi quantitative or with clarification on its interpretation.



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3.0 Health, Safety and Environmental Management

3.1 Health and Safety

A project-specific Health and Safety Plan (HASP) has been developed for the project. The implementation of the SAQP must be undertaken in conjunction with the HASP, and AECOM sampling methodologies (Appendix C). An activity-specific Safe Work Method Statement (SWMS) must be undertaken for all routine activities.



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4.0 Scope of Work for Sampling and Analysis

4.1 Proposed Sampling Locations

As noted in Section 2.1, the sampling locations are focused on two areas; Area 1 and Area 2 (Figure 1). It is proposed to sample five sampling sites in each location. The sampling sites presented on Figure 2 and Figure 3 are indicative locations. While every effort will be made to collect samples in the vicinity of these locations there may be external factors such as weather or absence of species that may require the locations to be revised.

- Area 1: five indicative sampling sites in the area comprising Tilligerry Creek and down-stream into Port Stephens. These sampling sites will be referred to as Site 1A to Site 1E and are presented on Figure 2.

- Area 2: five indicative sampling sites located in the area comprising Fullerton Cove and up-stream into the Hunter River. These sampling sites will be referred to as Site 2A to Site 2E and are presented on Figure 3.

The five sampling sites in each Area have been selected in consideration of information received from the NSW EPA and data listed in Section 1.1.

In addition it is proposed to sample an appropriate background location. The final location will be determined based on consultation with stakeholders. Sampling at such a location would facilitate an evaluation of the tissue PFC concentrations potentially resulting from environmental impacts in the investigation area in comparison to other similar environments potentially impacted by other activities. The sampling will aim to target similar or comparable species from each of the biota groups.

4.2 Target Biota

The aquatic biota of significance to recreational or commercial fishing understood to be present in the investigation areas are described in Table 3. It is understood that these species have been identified by EPA in consultation with commercial and local fisheries in the area and that the monitoring conducted to date has confirmed the presence of these species.

Table 3 Aquatic biota identified in the investigation area

Species Description (Sourced from NSW DPI, 2010)

Finfish

Sea Mullet (Mugil cephalus)

In NSW found primarily in estuaries and inshore waters. Spawning occurs at sea from Autumn to early winter. The larvae then enter estuaries and small juveniles live in sheltered shallow water habitats. Adults are found in association with shallow weed beds and bare substrates. Adult sea mullet leave estuaries between late summer and early winter and travel north along the open coastline to spawn. Mostly eat microscopic plants and detritus, often ingesting large amounts of substrate in the process. Maximum length is 60 cm. Minimum legal length is 30 cm. Majority caught commercially are sold as whole fish. Roe is sold to SE Asia and Middle East markets. Not a significant recreational species.

Luderick (Girella tricuspidata)

Found primarily in estuaries and around nearshore rocky reefs. Spawning occurs in surf zones near estuary entrances during winter, the larvae then enter estuaries and small juveniles live in sheltered shallow water habitats. Adults are mainly found in association with weedy habitats such as seagrass and rocky reefs. Adults migrate to near-coastal waters prior to spawning and may then return to estuaries. Mainly herbivorous, feeding on seagrass and green algae, and sometimes small invertebrates. Mature around 25 cm. Minimum legal length is 27 cm. Important recreational species, minor commercial species.

Silver Biddy (Gerres subfasciatus)

Found primarily in estuaries and inshore waters. Spawning occurs in coastal waters and marine dominated estuaries during summer and early autumn. Small juveniles live in sheltered shallow water habitats. Adults are generally found over sand and mud bottoms. Little is known about migration patterns. Diet consists of small invertebrates, particularly polychaetes.



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Mature around 20 cm and maximum length around 23 cm. One of the smallest finfish commercially harvested. Not a significant recreational species – often returned to the water due to small size.

Sand Whiting (Sillago ciliata)

Found in estuaries and coastal waters off ocean beaches. Spawning occurs in the lower reaches of estuaries and coastal waters near river mouths during summer, the larvae then enter estuaries and small juveniles live in sheltered shallow water habitats. Adults favoured habitats of bare sandy substrate. After spawning, adults may either enter estuaries or remain along ocean beaches. Eat bottom dwelling invertebrates, particularly polychaete worms, crustaceans and molluscs taken by fossicking through the sand. Mature around 25cm and maximum length around 50 cm. Minimum legal length is 27 cm. Popular recreational species (recreational catch estimated to be 2-3 times greater than commercial).

Yellowfin Bream (Acanthopagrus australis)

Found primarily in estuaries and around nearshore beaches and rocky reefs. Spawning occurs in inshore waters near estuary entrances during winter, the larvae then enter estuaries and small juveniles live in sheltered shallow water habitats. Adults are found in association with all types of habitat. Adults may return to estuaries after spawning. Eat a wide variety of food, including small fish, molluscs, crustaceans and worms. Mature around 22 cm and maximum length around 55 cm. Minimum legal length is 25 cm. Important commercial and recreational species.

Dusky Flathead (Platycephalus fuscus)

Bottom dwelling fish found primarily in estuaries and inshore ocean waters. Spawning occurs in both the lower reaches of estuaries and in the sea, typically during summer. The larvae then enter estuaries and small juveniles live in the same habitats as adults. Adults are normally found on soft substrates, including mud, seagrass and sand, often partially buried. Adults migrate to near-coastal waters prior to spawning and may then return to estuaries. Eat small fish and a variety of invertebrates including prawns, crabs and squid. Mature around 20 cm, majority of fish caught are 40 to 50 cm in length, but can grow up to 120 cm in length. Minimum legal length is 36 cm. Recreational catch exceeds the commercial catch

Shellfish

Eastern King Prawn (Melicertus plebejus)

Post-larval to adolescent prawns inhabit bare and vegetated substrate in areas of marine influence within estuaries and within shallow embayments within ocean waters. They migrate from estuaries over spring and summer and move north prior to spawning. Opportunistic omnivores that eat small crustaceans, annelid worms, bivalve molluscs and foraminifers. Maximum length around 6 cm. Large domestic market, also caught recreationally

School Prawn (Metapenaeus macleayi)

Inhabit both estuaries and inshore ocean waters. Spawn in near shore ocean waters between February and May. Post-larval prawns enter estuaries and move upstream. The following spring the adolescent prawns return down-stream and migrate to sea to mature and spawn. Prefer soft muddy substrates and areas of seagrass. Eat a variety of small invertebrates and detritus. Maximum length 16 cm. Important domestic market.

Crustaceans

Mud crab (Scylla serrata)

Favour soft muddy bottoms below the low tide level. Generally live in sheltered estuaries, mud flats, mangrove forests and the tidal reaches of some rivers. Can reach a maximum size of approximately 24 cm carapace width. Juveniles feed on planktonic animals, benthic molluscs and crustaceans while adults feed on bivalve and gastropod molluscs (mussels and pipis), small crabs and polychaete



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worms. Commercial and recreationally caught, with recreational catches outweighing commercial in some areas.

Blue crab (Portunus pelagicus)

Maximum length of about 21 cm across the carapace. Found primarily in estuaries and inshore coastal waters. Found in mud, sand and seagrass habitats, often buried in sediment. Commercially and recreationally caught species. Minimum legal carapace length of 6 cm.

Molluscs

Pipi (Donax deltoids) Found in the surf zone (intertidal and shallow subtidal waters along high energy beach coastlines). Not normally found in estuaries. Feed by extracting microscopic matter (particularly phytoplankton) from the water. Mature around 3.7 cm shell length; grow to more than 6 cm shell length. Collected exclusively by hand by licensed fishers.

Sydney Rock Oyster (Saccostrea glomerata)

Inhabit sheltered estuaries and bays. Reach approximately 60 g in 3 years. Obtain food by filtering and extracting minute marine plants (algae), bacteria and nutrients from the surrounding water. Commercially and recreationally caught species.

It is noted that not all species above may be present at each sampling site during the initial sampling event. Therefore, for the purpose of the initial sample collection and HHRA, AECOM proposes to group the species above on the basis of similarity in physiology, habitat and feeding habits, as follows:

- Benthic carnivores (whiting and flathead). This group will be referred to as Group X and in Section 4.7 assigned the reference GX.

- Benthic grazers: (silverbiddy and bream). This group will be referred to as Group Y and in Section 4.7 assigned the reference GY.

- Midwater column fish: (luderick and mullet). This group will be referred to as Group Z and in Section 4.7 assigned the reference GZ.

- Prawns (School prawns and eastern king prawns). This group will be assigned a reference PR in Section 4.7.

- Crab (Mud crab and blue crab). This group will be assigned a reference CR in Section 4.7.

- Molluscs (commercially raised oyster will be the primary target considered representative of this group, as pipi are not normally found in estuaries). It is understood that both Sydney Rock Oysters and Pacific Oysters may be commercially farmed in the area. During the sampling consideration will be given to the presence of both types of oysters and if Pacific Oysters are identified they may also be collected. This group will be assigned a reference OY in Section 4.7.

In the event that no species from a group can be collected from a site, alternative species that may be considered include:

- Tarwhine (Rhabdosargus sarba)

- Garfish (Hemiramphidae – several species)

- Pacific Oyster (Crassostrea gigas)

- Mulloway (Argyrosomas japonicus)

- Other species of mullet, Mugilidae, for example sand mullet (Myxus elongatus) and goldspot or flat-tail mullet (Liza argentea)



17

4.3 Proposed Number of Samples

4.3.1 Finfish

At each of the five sampling sites in each of the two Areas, it is proposed to collect up to five primary samples of each of the three finfish biota groups discussed above (Group GX, GY and GZ) (depending on availability). That is, in total up to 75 primary samples of which 30 will be analysed and 45 will be frozen and put on hold.

The 30 samples will comprise 10 primary samples from each of the three target groups. That is a total of 30 primary finfish samples from Area 1 and 30 samples from Area 2. The remaining samples (up to 15 primary samples per group and 45 per Area) will be frozen and placed on hold.

In addition, three duplicate and three triplicate samples from each Area will be prepared from the primary samples. One duplicate and one triplicate sample from each Area will be initially analysed and the remaining four QA/QC samples (two duplicates and two triplicates) will be placed on hold.

Compositing of finfish samples is not proposed because composite sampling has the potential for individual high results to be masked by low results, which would result in a loss of information regarding the variation of PFC accumulation in tissue within a population. Therefore it is proposed to analyse samples from individual finfish specimens where possible in order to calculate descriptive statistics for the biota type.

4.3.2 Shellfish

To achieve the required mass for laboratory analysis, the edible portion of prawns, crabs and molluscs will need to be composited. Composite samples will comprise up to 10 individual specimens. Therefore it is proposed to collect 50 individual specimens per location per grouping (Group PR, CR and OY) per Area. That is 750 specimens per Area equalling 75 samples on the basis of 10 specimens per composite sample. Of these 75 samples, similar to the finfish, 30 will be analysed and 45 will be frozen and put on hold.

In addition, three duplicate and three triplicate samples from each Area will be prepared. One duplicate and one triplicate sample from each Area will be initially analysed and the remaining four QA/QC samples (two duplicates and two triplicates) will be placed on hold.

Aquatic biota samples will be collected in accordance with sample collection methodologies presented in Appendix C. Sampling will be conducted by a qualified subcontractor with applicable licences and ethics approvals (currently anticipated to be NSW DPI) and documented in the field by an AECOM environmental scientist.

4.4 Laboratory Analysis

Samples will be prepared for analysis at the primary laboratory in accordance with the sample preparation methodology described in Appendix C. This will include removal of scales/ shell, head and internal organs. Fillets will be taken with skin on and homogenised prior to sub-sampling and analysis. Any internal organs that are commonly consumed (e.g. fish roe) will be removed from the species and sampled separately. If there is sufficient sample mass from the species collected, it is proposed to analyse this separately from muscle tissue. Due to the uncertainty surrounding the presence or absence of fish roe, a nominal sample size of 10 primary composite samples and two QA/QC samples have been considered.

As noted in Section 4.1, it is proposed to initially schedule 10 primary samples for laboratory analysis, as per Table 4. Assuming species are plentiful in each of the five locations in each Area, the samples submitted for analysis will be selected from each of the five sites in each Area.

The remainder will be placed on hold, frozen, at the laboratory. Samples will be scheduled for analysis for the full PFC suite.

Table 4 Specimens proposed for initial analysis

Target biota group Number of samples proposed to initially be submitted for analysis from each Area

Number of samples proposed to be placed on hold (frozen) from each Area

Area 1: Tilligerry Creek and Port Stephens

Primary QA/QC Primary on hold QA/QC on hold

Finfish

Benthic carnivores (GX) 10 2 15 4



18



Benthic grazers (GY) 10 2 15 4

Midwater column fish (GZ) 10 2 15 4

Shellfish

Prawns (PR) (made up of a composite of approximately 10 samples)*

10 (composite) 2 (composite) 15 (composite) 4 (composite)

Crab (CR) (made up of a composite of up to 5 samples)*


Molluscs (OY) (made up of a composite of up to 5 samples)*

10 (composite) 2 (composite) 15 (composite)15 4 (composite)

Area 2: Fullerton Cove and Hunter River

Primary QA/QC Primary on hold QA/QC on hold

Finfish




Shellfish







Background Area Primary QA/QC Primary on hold QA/QC on hold

Finfish




Shellfish







Roe

Nominal amount 10 2



19



TOTAL 190 38 270 72

*Number of individual composites will be dependent on the weight of the species at the time of sampling.

Upon receipt of the results of the initial run of laboratory analysis, the results will be reviewed and evaluated in the context of the DQOs described in Section 2.0. Based on the variation within tissue concentrations for each biota group an assessment will be made of the need for additional samples to be analysed to decrease the margin of error associated with estimating the population mean with acceptable confidence.

This approach is proposed because it will allow the Aquatic Biota Consumption HHRA to progress in a timely manner on the basis of reasonable maximal exposure assumptions while additional analysis are conducted to refine the estimates of mean concentrations (if required).

4.5 Logistics

All primary samples collected will be sent to the primary laboratory (NMI in Sydney) accompanied with the CoC. All secondary samples will be also be sent to MNI and prepared in accordance with Appendix C. NMI will send samples to the secondary laboratory under chain of custody. At the time of writing, it is proposed to use Asure Quality in New Zealand as the secondary laboratory.

4.6 Analytical Suite and Laboratory Analysis Methods Table 5 Sample Analysis Suites and Methods Biological Matrices

Sample Type Parameter Technique/Method Reference

Limit of Reporting*

Primary Duplicate

PFCs (full screen as presented in Section 2.1)

AUTLO7

0.2 to 0.5 ng/g except PFHxA with LOR of 5 ng/g

Triplicate

PFCs (full screen as presented in Section 2.1)

LC-MS/MS DX-PFCS04//01

1-2 ng/g

* Specific compounds reportable and LORs for any screen can be sample matrix dependant. LC/MS-MS = Liquid chromatography–mass

spectrometry, GC = Gas chromatography



20

The biota samples will be analysed for the suite of PFCs identified in Section 2.1 as CoPC.

Samples are spiked with isotopically labelled internal standards (IS) prior to extraction. The PFC concentrations are calculated using the IS response. Both the primary and secondary laboratory will be requested to utilise a mixed branched and linear isomer calibration standard for PFOS analyses.

Laboratory QA/QC for each batch of samples will include a method blank and a matrix spike. Standard reference materials for use as a control matrix are not available for these analytes.

4.7 Sample Nomenclature and Labelling

The sample nomenclature presented in Table 6 is proposed. The example in Table 6 is assuming that sampling occurs in Area 2 at Site 2D with one eastern king prawn, one school prawn, one sea mullet, one silver biddy and one sand whiting caught.

Table 6 Sampling Nomenclature

Site Species Group

Sample number

Date Sample ID Comment

2D PR 001 20160111 2D_PR_001_20160111 eastern king prawn

2D PR 002 20160111 2D_PR_002_20160111 school prawn

2D GX 003 20160111 2D_GX_003_20160111 whiting

2D GY 004 20160111 2D_GY_004_20160111 bream

2D GY 005 20160111 2D_GY_005_20160111 silverbiddy

Samples will also be labelled with the time and weight of the sample.

4.8 Quality Assurance/Quality Control Sampling

4.8.1 Field Duplicate and Triplicate Samples

Intra-laboratory field duplicate samples will be collected at a rate of one per 10 primary samples (minimum of one per batch). Inter-laboratory field triplicate sample are also proposed at a rate of one per 10 primary samples (minimum of one per batch).

4.9 Fieldwork Documentation

4.9.1 Field Sampling Documentation

Field sampling sheets will be completed for each location and will include the following information (as appropriate for the type of sample collected):

- Name of sampler

- Sample location (geocoordinates)

- Date /time of sampling

- Sampling method (any deviations from the standard procedure and rationale)

- Observations of the condition of the sampled biota

- Photograph each animal with a reference measure (e.g. a ruler).

- Weight of each animal.

- Length of each animal.

The location of quality control (e.g. duplicate and triplicate) sample collection points shall also be noted.

4.9.2 Sample Labels

Laboratory supplied sample containers shall be labelled, as a minimum, with the following information:

- AECOM project number



21

- Name of sampler

- Sample ID

- Date of sample collection.

An indelible felt pen shall be used for labelling, to ensure that the lettering is not erased during transit to the laboratory.

4.9.3 Chain of Custody Forms

A CoC form shall be completed, documenting the sample identification number and analytes. The CoC documents the chain of events from sample collection to delivery at the laboratory and provides a traceable account of sample handling. The CoC form shall be signed by both the sample collector and the receiving laboratory.

The CoC form shall include the following information:

- Job number (Note: Name of site is not listed for confidentiality of project)

- Date and time of sample collection

- Sample ID

- Type of containers

- Name of sampler

- Laboratory to be used

- Analyses required

- Any comments

- Signatures of the sampler and laboratory receiver.

Upon receipt of the original documents accompanying the samples at the laboratory, the laboratory shall provide a sample receipt document (noting temperature of samples upon receipt, analyses required and any non-conformances) and return the signed CoC form to confirm analyses to be performed.



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5.0 Aquatic Biota Consumption HHRA Methodology

5.1 Objectives

The objectives of the aquatic biota consumption HHRA will be to assess the potential for adverse human health risks associated with consumption of aquatic biota caught recreationally or commercially within Area 1 and Area 2.

It is noted that in any HHRA the identification of all potential exposure pathways should be considered. As the objective of this assessment is to focus on one pathway only, the findings of the assessment will be presented as an interim advice document.

5.2 Overview of Approach

The assessment will be undertaken following the tiered HHRA process that is illustrated on Figure 1.

Figure 1 HHRA Process (Source: ASC NEPM 2013)



23

5.3 Issues Identification

Issues Identification identifies the key issues for the risk assessment and establishes a context for the risk assessment by a process of identifying the concerns that the risk assessment needs to address (enHealth, 2012). Fundamental to identifying the risk assessment issues is the development of a CSM. The assessment conducted to evaluate data collected for tissue concentrations of PFCs in aquatic biota will be limited to the following source-pathway-receptor linkage:

- Source: Historical use of AFFF at RAAF Williamtown which has resulted in PFCs in groundwater and surface water down-gradient.

- Pathway: Direct contact of aquatic biota with impacted surface water and consumption of lower order biota by higher order aquatic biota, resulting in accumulation within edible tissues that may subsequently be consumed by humans.

- Receptor: Consumers of aquatic biota (children and adults).

5.4 Data Collection and Evaluation

Data to be considered in the assessment include:

- Biota data reported in URS (2015) Stage 2 Environmental Investigation

- Biota data reported in NSW DPI (2015) Preliminary PFOS Risk Assessment for Seafood – Tilligerry Creek and Fullerton Cove

- Biota data reported from the investigations described in this SAQP.

The analytical results incorporated into the assessment will be those that were considered to be valid in terms of precision and accuracy of the primary data sets and representative of concentrations of the analysed compounds at the sample locations tested. Prior to using data in the assessment, an evaluation will be undertaken to confirm that the data are suitable for use. The analytical data reported in URS (2015) and as an outcome of this SAQP will have been reviewed and assessed to ensure that the data is in compliance with method requirements and project DQOs for each individual data collection event. The data validation process includes checking the analytical procedure compliance and an assessment of the accuracy and precision of the analytical data from a range of quality control measurements generated from both the sampling and analytical programs. A description of project DQOs, sampling methodology, analytical methodology and QAQC assessment will be requested from NSW DPI to support use of those data in the HHRA.

The HHRA will include a consideration of the quantity of data available and an evaluation of remaining data gaps at the completion of the works described in this SAQP which may impact the HHRA. Identified data gaps, their significance to the outcomes of the HHRA and the manner in which they are addressed will be summarised in the HHRA report.

5.5 Toxicity Assessment

The toxicity assessment stage of a risk assessment is separated into two components; hazard identification and dose-response assessment. The hazard identification stage is a qualitative description of the capacity of a contaminant or agent to cause harm. The dose-response assessment includes the selection of appropriate toxicity criteria from a hierarchy of sources, in accordance with the ASC NEPM 2013 and will be presented as a toxicological profile further discussed in Section 5.5.1.and Section 5.5.2.

5.5.1 Hazard Identification

The hazard identification process requires a review of existing toxicological information from a variety of appropriate sources to describe the capacity of a specific agent to produce adverse health effects.

It is noted that the availability of toxicity reference values (TRVs) is likely to limit the CoPC that are quantitatively assessed within the HHRA for the human consumption of aquatic biota pathway. The proposed approach within the assessment is to focus on two compounds (namely PFOS and PFOA). It is understood from historical data that there is the presence of “other” CoPC within sediment and surface water at and off the Site. For these reasons, AECOM will specify analysis for the full suite of PFCs, as defined in Section 2.1. The presence or absence of concentrations above the laboratory LOR will support the overall CSM. In addition, the information can be utilised in future assessments at the Site, as soon as reputable toxicological data becomes available.



24

PFOS and PFOA have been the focus of international toxicological research and the available data are sufficient to derive TRV with acceptable confidence. The hazard identification step will include a review of whether defensible toxicological data are available for each of the CoPC by ToxConsult. Where ToxConsult identifies that defensible toxicological data are available, then these compounds will be included in the Tier 2 quantitative HHRA.

AECOM understands that there is limited information of the relative toxicity and modes of action for the remaining CoPC reported within the PFC suite. Therefore, in terms of quantifying human health risks this is problematic and it is considered that until scientifically defensible information becomes available, the assessment and potential quantification of potential risks to human health cannot be logically undertaken. AECOM is of the opinion that assuming the relative toxicity of PFOS and sulfonates within the PFC group are the same will potentially provide an unrealistic overconservative assessment of the risks which are likely to result in some risk indices being above the adopted target risk level. This is particularly the case for multiple exposures from ingestion of biota combined with other significant exposure pathways such as drinking water. As this Aquatic Biota Consumption HHRA will be a public document, the messaging adopting this approach will be difficult to clearly communicate to the general public. This may also be the case if AECOM adopted an approach where “other” PFC compounds are assigned a relative toxicity equivalent to PFOS or PFOA similar to what is utilised in the assessment of polycyclic aromatic hydrocarbons.

AECOM is of the understanding that this interim advice document will form part of a larger evolving HHRA which will be informed as various information is gathered during the Stage 2B sampling works. It is also considered that should technically defensible toxicology data become available, then further consideration of the PFCs listed in Section 2.1, as appropriate, will be warranted within the assessment.

AECOM has subcontracted ToxConsult Pty Ltd (ToxConsult) on another Defence project to undertake a detailed literature review of available human and animal toxicology data for PFOS and PFOA and prepare a toxicological profile report that will:

- Document that data sources have been reviewed following the hierarchy specified in the ASC NEPM 2013, Schedule B4, Table 4 and enHealth 2012, Section 5.12.

- Include a qualitative hazard identification section, which provides discussion of:

Mode of action

Acute toxicity

Sub-chronic toxicity

Chronic toxicity

Reproductive toxicity

Developmental toxicity

Genotoxicity

Potential threshold and non-threshold effects

Potentially sensitive populations

It is proposed to adopt this toxicological profile for this HHRA.

5.5.2 Dose-Response Assessment

The objective of the dose-response assessment is to identify the toxicity values for each CoPC to be used for the quantification of human health risk. The numerical values derived from toxicity dose-response studies are referred to collectively as toxicity values. The toxicity values adopted are based on two different approaches to the characterisation of dose-response (NHMRC, 1999 and USEPA, 2005):

- For chemicals that have the potential to result in carcinogenic effects that are associated with a genotoxic mechanism, any level of exposure is assumed to result in some incremental lifetime risk. These chemicals are therefore assessed on the basis of a non-threshold dose-response relationship.

- For other chemicals that may be associated with non-carcinogenic effect or other carcinogenic effects that are not genotoxic, a threshold is considered relevant. The threshold level is considered a level whereby exposure below the threshold will not result in any adverse effects. Exceedance of the toxicity reference value does not imply that adverse effects will occur, as there are a number of uncertainties and safety



25

factors applied to the no effect threshold exposure in order to set the toxicity reference value. Rather an exceedance signals that exposure needs to be further evaluated.

Based on currently available information, the identified CoPC of PFOS and PFOA will be assessed as threshold chemicals. Potential health effects that are assessed on the basis of a threshold dose response utilise a threshold value which is typically termed an Acceptable Daily Intake or Tolerable Daily Intake (ADI or TDI) or Reference Dose (RfD). For the purpose of this assessment, the threshold value adopted has been termed a TDI. A TDI is a chemical intake below which it is considered unlikely that adverse effects would occur in human populations, including sensitive sub-groups (e.g. the very young or elderly). Hence, the TDI relates to intakes from all sources, the Site related impacts as well as background intakes (where relevant).

In accordance with recent communication received from Food Standards Australia New Zealand (FSANZ), adverse effects from PFCs including PFOA and PFOS are thought to occur following long term exposure therefore no acute health based assessment is required.

The toxicity profile report prepared by ToxConsult for PFOS and PFOA will:

- Provide a critical review of available dose-response TRVs

- Provide recommendations for TRVs to be used in a HHRA.

- Include a sensitivity analysis for the range of toxicological parameters reviewed and adopted.

5.5.3 Background Exposure

Background levels of contamination comprise chemical concentrations present in the environment as a result of everyday activities or natural sources. These chemicals may be present in food, air, water and consumer products and represent the non-Site sources of contamination exposure. This is commonly referred to as background exposure. The ASC NEPM 2013 Schedule B4 and enHealth (2012) require that ‘background exposure’ be taken into account during the assessment of potential human health risk. The HHRA will give consideration to potential background exposure through adjustment of tolerable daily intake thresholds to account for non-site related exposure. The adjustments will be based on literature studies that cover a wide range of exposures, including but not limited to aquatic biota. ATSDR (2015) indicates that general population exposure to perfluoroalkyls is widespread, as PFCs are present in the environment due to their use in surface protection products such as carpet and clothing treatments and coating for paper and cardboard packaging. Dietary background intakes may be sourced from a wide area which may not be practicable to characterise by sampling and literature data may therefore provide a more conservative estimate.

The toxicity profile report prepared by ToxConsult for PFOS and PFOA will:

- Provide a quantitative assessment of potential background exposure.

Background exposure is only applied to threshold contaminants (i.e. non-carcinogens) because intakes of non-threshold contaminants (i.e. carcinogens) are considered on the basis of an increase in risk, which is irrespective of background exposure.

5.6 Exposure Assessment

Exposure Assessment involves the estimation of magnitude, frequency, extent, and duration of exposure to Site-derived contamination (enHealth, 2012).

“Direct measurement of the exposures of the (potentially) affected population provides the best exposure data but this is not always available or practicable and default exposure factor data is often required.” (Langley, AJ (1993). In absence of direct measurement data, environmental sampling and predictive models are commonly used to estimate intakes of CoPC by the exposed populations. The key elements of exposure assessment in the context of contaminated land risk assessment are to:

- identify input values for contaminant concentrations and pathways

- identify input values for exposed populations

- estimate exposure concentrations

- estimate chemical intake



26

5.6.1 Exposure Assumptions

In undertaking the exposure assessment component of this Aquatic Biota Consumption HHRA, AECOM will aim to further understand the recreational and commercial human exposure assumptions associated with each of the groups of target biota. This will involve, in consultation with the relevant stakeholders, collating information on the commercial catches in the area, along with the recreational dietary intakes. It is proposed to develop a community survey to establish records of recreational use in relation to the human consumption of the target species within the two Areas and to identify exposure parameters. It is noted that this SAQP relates to one of potentially many exposure pathways for human receptors and this will be acknowledged in the overall outcomes of the assessment of potential risks to human health.

The community specific information will be further supplemented by data from the following recognised Australian and international resources:

- ASC NEPM 2013.

- enHealth, 2012. Australian Exposure Factor Guide. Department of Health and Aging.

- enHealth, 2012. Environmental Health Risk Assessment, Guidelines for Assessing Human Health Risks from Environmental Hazards. Department of Health and Aging, 2012 Update.

- Australian Bureau of Statistics Australian Health Survey 2011-13, National Nutrition and Physical Activity Survey.

- Food Standards Australia New Zealand 2014 – 24th Australian Total Diet Study Phase 1 and Phase 2.

- USEPA (2011) Exposure Factors Handbook 2011 Edition (Final).

- USEPA, 1989. Risk Assessment Guidance for Superfund Volume I – Human Health Evaluation Manual Part A. United States Environmental Protection Agency Office of Emergency and Remedial Response. Washington DC, Revised December 1989; and associated updates.

Where specific guidance is not available from the above or other literature sources, conservative estimates for exposure parameters will be adopted. Human exposure parameters adopted for the assessment, their source and justification will be presented in the HHRA along with the exposure assessment algorithms.

5.6.2 Exposure Point Concentrations

A key element of the exposure assessment process is estimation of the concentration of Site-derived CoPC in environmental media.

- This concentration is commonly termed the Exposure Point Concentration (EPC). It should be selected as a conservative estimate of the chemical concentration in an environmental medium at the point of exposure.

- EPCs are identified for each site-impacted ‘exposure unit’. This is defined as the area throughout which a receptor moves and encounters an environmental medium for the duration of exposure.

- Typically, an individual receptor is assumed to be equally exposed to media within all portions of the exposure unit over the time frame of the risk assessment.

- EPCs will be selected based on both mean and maximum measured tissue concentrations reported in each identified biota type.

5.6.3 Estimation of Chemical Intakes

Modelled intake concentrations relevant to the assessment of exposure to the CoPC by identified receptors and pathways will be estimated using the equations presented in the ASC NEPM 2013, Schedule B4 and Schedule B7. Relevant algorithms will be included within the HHRA report.

5.7 Risk Characterisation

Risk characterisation is the final step in the risk assessment process whereby information gathered and derived from the toxicity assessment and exposure assessment is used to derive quantitative estimates of risk to human health. Conclusions reached during the risk characterisation process conveys the nature and existence of (or lack of) human health risks in a manner useful for decision makers. A variety of risk characterisation methods are available and will be considered in this HHRA. The most common and arguably the simplest is comparison with a toxicity reference value such as the TDI. This is explained further below.



27

5.7.1 Hazard Quotient1

For threshold (non-carcinogens), potentially unacceptable chemical intake/exposure is indicated if the exposure level exceeds the TDI (i.e. if the Hazard Quotient is greater than 1).

Where the risk acceptability criteria are exceeded, a more detailed and critical evaluation of the risk may be conducted, or further investigation or appropriate risk management measures may be recommended.

The HHRA will be based on both an average exposure scenario and reasonable maximum exposure scenario (which as a conservative approach would assume that a receptor may be exposed at the maximum EPC to all impacted biota). It is acknowledged that not all receptors will be exposed via consumption of all biota and therefore the HHRA will include estimates of intakes for human receptors for each biota group. These can be used to calculate margins of exposure for each biota group, relative to the biota group with the estimated greatest potential health risk. This can be used as a communication tool to explain how different combinations of biota consumption could result in different risk estimates.

5.7.2 Uncertainty/ Sensitivity Analysis

The risk assessment process involves a number of assumptions regarding Site conditions, human exposure and chemical toxicity. These assumptions are based on Site-specific information (where available), but it is not always possible to fully predict or describe site conditions and human activities at a site for the exposure period considered in the risk assessment. The assumptions adopted for the risk assessment will therefore be selected to cover two scenarios: both average exposure and, to be conservative in nature, an assumed reasonable maximum exposure scenario which provides a deliberate margin of safety.

A discussion of some of the key uncertainties associated with different components of the risk assessment process will be included in the report, including:

- Sampling and Analysis – consideration of identified data gaps and whether collection of further data is warranted to further reduce the uncertainty in the exposure modelling.

- Toxicity Assessment – consideration of the uncertainty associated with the derivation of adopted TDIs.

- Human Exposure Parameters – consideration of potential variability of exposure parameters based on available site specific information and whether a survey of residents may be required to further reduce the uncertainty in the exposure modelling.

The report will include a quantitative sensitivity analysis of the risk assessment outcomes to the plausible ranges for each of the key quantifiable uncertainties.

1 HQ is the ratioi of the mean daily intake to the reference dose of TDI for threshold exposure.



1

6.0 References AECOM 2016 - Sampling Analysis and Quality Plan, RAAF Williamtown – Stage 2B Environmental Assessment DRAFT

Agency for Toxic Substances and Disease Registry (2015) Draft Toxicological Profile For Perfluoroalkyls

Australian Bureau of Statistics Australian Health Survey 2011-13, National Nutrition and Physical Activity Survey.

enHealth, 2012. Australian Exposure Factor Guide. Department of Health and Aging.

enHealth, 2012. Environmental Health Risk Assessment, Guidelines for Assessing Human Health Risks from Environmental Hazards. Department of Health and Aging, 2012 Update.

Food Standards Australia New Zealand 2014 – 24th Australian Total Diet Study Phase 1 Published April 2014

NSW DPI (2010) Status of Fisheries Resources in NSW 2008/09

National Environment Protection (Assessment of Site Contamination) Measure 1999 (as amended 2013) [ASC NEPM 2013] Schedule B2 Guideline on Site Characterisation.

National Environment Protection (Assessment of Site Contamination) Measure 1999 (as amended 2013) [ASC NEPM 2013] Schedule B4 Guideline on Site-Specific Health Risk Assessment Methodology.

National Environment Protection (Assessment of Site Contamination) Measure 1999 (as amended 2013) [ASC NEPM 2013] Schedule B7 Guideline on Derivation of Health-Based Investigation Levels

United States Environmental Protection Agency (US EPA) Guidance on Systematic Planning Using the Data Quality Objectives Process (EPA QA/G-4 : EPA/240/B-06/001), February 2006

National Nutrition and Physical Activity Survey (NNPAS) 2011-2012

URS, 2015. Stage 2 Environmental Investigation, AFFF PFAS, RAAF Base Williamtown, Williamtown, NSW. 14 September 2015. USEPA (2011) Exposure Factors Handbook 2011 Edition (Final)

USEPA, 1989. Risk Assessment Guidance for Superfund Volume I – Human Health Evaluation Manual Part A. United States Environmental Protection Agency Office of Emergency



2

7.0 Limitations AECOM Services Pty Limited (AECOM) has prepared this report in accordance with the usual care and thoroughness of the consulting profession for the use of Department of Defence and only those third parties who have been authorised in writing by AECOM to rely on the report.

The Report is based on generally accepted practices and standards at the time it was prepared. No other warranty, expressed or implied, is made as to the professional advice included in this report.

This report should be read in full. No responsibility is accepted for use of any part of this report in any other context or for any other purpose or by third parties.

The methodology adopted and sources of information used by AECOM are outlined in the Report.

Where this report indicates that information has been provided to AECOM by third parties, AECOM has made no independent verification of this information unless required as part of the agreed scope of work. AECOM assumes no liability for any inaccuracies in or omissions to that information.

The information in this Report is considered to be accurate at the date of issue and is in accordance with conditions at the site at the dates sampled. Opinions and recommendations presented herein apply to the site existing at the time of our investigation and cannot necessarily apply to site changes of which AECOM is not aware and has not had the opportunity to evaluate. This document and the information contained herein should only be regarded as validly representing the site conditions at the time of the investigation unless otherwise explicitly stated in a preceding section of this Report. AECOM disclaims responsibility for any changes that may have occurred after this time.

Except as required by law, no third party may use or rely on, this Report unless otherwise agreed by AECOM in writing. Where such agreement is provided, AECOM will provide a letter of reliance to the agreed third party in the form required by AECOM.

To the extent permitted by law, AECOM expressly disclaims and excludes liability for any loss, damage, cost or expenses suffered by any third party relating to or resulting from the use of, or reliance on, any information contained in this Report. AECOM does not admit that any action, liability or claim may exist or be available to any third party.

AECOM does not represent that this Report is suitable for use by any third party.

Except as specifically stated in this section, AECOM does not authorise the use of this Report by any third party.

It is the responsibility of third parties to independently make inquiries or seek advice in relation to their particular requirements and proposed use of the relevant property.

Any estimates of potential costs which have been provided are presented as estimates only as at the date of the Report. Any cost estimates that have been provided may therefore vary from actual costs at the time of expenditure.

7.1 Ownership of Report

Readers are advised that this Report has been produced under contractual arrangements such that the Consultant grants to Defence a permanent, irrevocable, royalty free, non-exclusive licence (including the right to grant a sub-licence) to use, reproduce, adapt and exploit the intellectual property rights in the Report anywhere in the world. Notwithstanding Part VII of the Copyright Act (1968), publication of the Report in accordance with this licence shall not affect such ownership.



AAppendix A

Figures

SALT ASH

CLARENCE

TOWN

PORT

STEPHENS

PINDIMAR

RAYMOND

TERRACE

KOORAGANG

PHOENIX

PARK

HEXHAM

EAGLETON

NELSON

BAY

TOMAGO

FERN BAY

THORNTON

OYSTER

COVE

NORTH

ARM COVE

SEAHAM

WILLIAMTOWN

FERODALE

WALLSEND

WOODBERRY

FULLERTON

COVE

TEA

GARDENSEAST

SEAHAM

TANILBA

BAY

SWAN BAY

CHISHOLM

TWELVE

MILE CREEKBUTTERWICK

CAMPVALE

TARRO

MEDOWIE

KARUAH

BLACK

HILL

WOODVILLE

SALAMANDER

BAYMILLERS

FOREST

NELSONS

PLAINSSHOAL

BAY

FINGAL

BAY

HINTON

MINMI

ANNA BAY

BOBS

FARM

BALICKERA

HEATHERBRAE

MORPETHDuckenfield Road

Nelson Bay

Road

Medowie Road

Lemon Tree Passa

geRoad

PacificHighway

New

EnglandHighway

Medo

wie R

oad

Richardson Road Nelson Bay Road

Cabbage Tree Road

Myall Street

Woodberry

RoadRaymond Terrace Road

Tarean Road

Pacific

Highw

ayHinton Road

MasoniteRoad

MaitlandRoad

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STAGE 2B ENVIRONMENTAL INVESTIGATION

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PRELIMINARY AND SUBJECT TO CHANGE

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FIGURE 1 - Aquatic Biota Sampling Areas

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0 2 4 km!«N#Disclaimer Spatial data used under licence from Land and

Property Management Authority, NSW © 2015.

AECOM makes no representations or warranties of any kind,

about the accuracy, reliability, completeness, suitability or

fitness for purpose in relation to the map content.

SALT ASH

PORT

STEPHENS

PINDIMAR

RAYMOND

TERRACE

EAGLETON

NELSON

BAY

OYSTER

COVE

WILLIAMTOWN

TAHLEE

CORLETTE

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FULLERTON

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Port Stephens

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Anderson Drive

New England Highway

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Richardson Road

Richardson Road

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FIGURE 3 - Area 2: Fullerton Cove

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BAppendix B

Closure Notification

Government Notices

3426 NSW Government Gazette No 92 of 30 October 2015

Primary Industries Notices

FISHERIES MANAGEMENT ACT 1994

Section 8 Notification – Fishing Closure

Port Stephens and Hunter River

I, Geoff Allan, Deputy Director General Fisheries, with the delegated authority of the Minister for Primary Industries and the Secretary of the Department of Industry, Skills and Regional Development pursuant to sections 227 and 228 of the Fisheries Management Act 1994 (“the Act”), and pursuant to section 8 of the Act, prohibit the taking of any species of fish, by any person, from the waters described in the Schedule to this notification.

The provisions of this fishing closure have effect in respect of endorsement holders in the Estuary General Fishery despite any provisions in the Fisheries Management (Estuary General Share Management Plan) Regulation 2006.

The provisions of this fishing closure have effect in respect of endorsement holders in the Estuary Prawn Trawl Fishery despite any provisions in the Fisheries Management (Estuary Prawn Trawl Share Management Plan) Regulation 2006.

This fishing closure has effect for a period commencing on 1 November 2015 and ending on 30 June 2016, unless sooner amended or revoked.

Schedule

Waters

Port Stephens

That part of Port Stephens known as Tilligerry Creek and its bays and tributaries upstream of the line between:

(a) the point on the mean high water mark nearest to 32°45.299′S, 151°59.857′E on the northern shore of Tilligerry Creek, and

(b) the point on the mean high water mark nearest to 32°45.687′S, 152°0.266′E on the southern shore of Tilligerry Creek.

Hunter River

That part of the Hunter River known as Fullerton Cove upstream of the line between

(a) the point on the mean high water mark nearest to 32°51.394′S, 151° 47.564′E on the eastern shore of Fullerton Cove, and

(b) the point on the mean high water mark nearest to 32°51.386′S, 151°46.908′E on the southern shore of Fullerton Cove, and

(c) the point on the mean high water mark nearest to 32°50.517′S, 151°46.160′E on the northern shore of Fullerton Cove.

In this Schedule, latitude and longitude coordinates are in WGS84 datum.

Dated this 27th day of October 2015

Dr GEOFF ALLAN Deputy Director General Fisheries Department of Primary Industries (an office within the Department of Industry, Skills and Regional Development)

Note: The purpose of this fishing closure is to prohibit the taking of fish because of a pollution event.



CAppendix C

Standard Operating Procedure

Standard Operating Procedure for Aquatic Biota Sampling

1.0 Introduction

This procedure describes the methods for collecting representative aquatic biota samples from open water bodies, lakes and creeks. If followed properly, use of this procedure will promote consistency in each of the above areas and ensure regulatory compliance across Australia where best practice guidelines have been developed.

It is assumed that AECOM will engage an appropriately experienced sub-contractor to undertake the sampling. The AECOM project manager is required to ensure that the subcontractor holds the appropriate sampling permits and ethics approvals for the specific activity that is being undertaken. The sub-contractor engaged will supply all the necessary equipment to catch and store the samples on the vessel.

It is anticipated that an AECOM Environmental Scientist will be present at all times during the sampling stage of the works. In instances where this may not be possible due to the restrictions of the vessel, the sub-contractor will be fully briefed by the AECOM team as to the procedure required. An overview of the key steps is presented in the flowchart at the end of this document.

2.0 Health and Safety

Health and Safety Plan (HASP) and task specific Safe Work Method Statements (SWMS) will be prepared prior to field works. The SWMS or Job Safety Analysis (JSA) will also be prepared by the sub-contractor for their specific tasks.

Prior to commencement of the works the project team will review the SWMS/JSA and discuss the potential hazards and mitigation measures.

Once the project team arrive at the sampling location, the hazards must be identified and adequate precautions must be taken to ensure the safety of the sampling team.

All sampling personnel must wear personal flotation devices (life vests). In addition it is assumed that the majority of the sampling will be from a boat, where appropriate protective measures must be identified and implemented in accordance with reviewed and approved HASP and SWMS/JSA. In addition, the use of electronic position indicating radio beacons (EPIRBs) will be considered.

3.0 Equipment

Equipment needed by AECOM for collection of aquatic biota samples may include:

- Stainless Steel buckets.

- Two Stainless Steel Identification Board.

- Stainless steel ruler.

- Laboratory supplied Polypropylene containers.

- GPS.

- Camera.

- Clipboard.

- Analytical-quality de-ionised water (15 L).

- Notebook.

- Felt-tipped markers.

- Labels.

- Digital scales.

- Cool box and ice.

- Figures of the sampling sites.

- Life vests.

4.0 Procedure

The following steps will be performed:

Planning, Mobilisation and Setup

- Prior to mobilisation, the AECOM team will review the Sampling Analytical and Quality Plan (SAQP) to ensure they are familiar with the sampling plan, the sampling methods to be employed, and the types and amounts of equipment and supplies needed. This will be conducted by a project kick off meeting.

- A kick-off meeting will also be conducted with the sub-contractor to ensure that the appropriate documentation in terms of permits are in place.

- The laboratory will be contacted at a minimum of one week prior to the intended sampling date to confirm the mass of tissue required and to order the appropriate sampling containers for the volume of sampling.

- Field staff will arrange field sampling equipment, as required.

- Weather forecast will be checked in the lead up to the sampling event. In the event that the forecast indicates stormy conditions, the sampling will be postponed until the weather clears.

On Arrival to Site/ Daily

- The conditions on arrival at site will be evaluated and discussed during the Toolbox talk. The sampling team will review the HASP and any modifications to the HASP and SWMS/JSA will be documented.

- Date, time of arrival on site, and site conditions (including weather) will be recorded.

- General locations for sampling will be marked or identified on a site map with a geo-reference to landmarks/topography. GPS coordinates will be recorded for each location. As required, the proposed locations may be adjusted based on site conditions and access.

- Photographs of the sampling locations and surrounding conditions will be taken.

Sampling

- Prior to sampling all dissection equipment will be decontaminated using laboratory supplied deionized water and 3 separate rinse stages. Sampling and monitoring equipment will also be decontaminated between sampling events at the same location, and following completion of the sampling event.

- Buckets will be prepared for sample holding and cleaning. One bucket (Bucket 1) will be filled with the local water and labelled and a second (Bucket 2) and third bucket (Bucket 3) with DI water. Scrubbing brushes will be used to clean the sample, where required. All scrubbing brushes will be kept in their appropriate buckets – labelling buckets and scrubbing brushes will ensure they are not mixed.

- Samples will be captured utilising the process agreed with the subcontractor.

- Samples will be placed on the first identification board, and assigned one of six groupings; Group X, Group Y, Group Z, Group PR, Group CR or Group OY by the sub-contractor. Groupings are presented in Table 1. The species will be logged and measured to confirm if the sample is the legal length, where applicable.

- Where sample does not meet the legal requirements, the sample details will still be recorded, but returned to the water.

- If sample meets the appropriate requirements, it will be placed in Bucket 1 and rinsed of foreign matter.

- The sample will be assigned a sample ID, as per the sample naming system presented in the SAQP and reproduced in Table 1 below. The sample will be moved from Bucket 1 and euthanized.

- The sample will be weighed and the weight recorded together with the biometric information as per Table 2. Where the specie is from one of the sample groups that are to be composited, sufficient species will be grouped together, with sufficient mass, to form the one sample (with one sample ID).

- After weighing, the sample will be placed in Bucket 2 (containing DI water), scrubbed with a brush and rinsed, the sample will then be rinsed in Bucket 3. The sample will be photographed after it is rinsed. Rinsate samples will be collected as documented in the SAQP.

- The sample will be placed into the appropriate sample containers and labelled with the ID. In addition, the sample will also be labelled with the time the sample was bagged and weight of the sample. The sample will be photographed after it is bagged.

- Samples will be placed on ice, the chain of custody documentation completed including the job number. Date and time of sample collection, Sample ID, type of containers, name of sampler, laboratory to be used, analyses required, any comments and signatures of the sampler and laboratory receiver.

- The samples will be transported to the laboratory as soon as practicable.

- Upon receipt of the original documents accompanying the samples at the laboratory, the laboratory will provide a sample receipt document (noting temperature of samples upon receipt, analyses required and any non-conformances) and return the signed CoC form to confirm analyses to be performed. Subject to laboratory processing times the samples will be processed and dissected on the day following capture (within the laboratory).

On Leaving Site

- Place all specimens in appropriate containers and chilled.

- Ensure all samples are appropriately labelled and kept out of sunlight once sampled.

- Call the laboratory and let them know that the samples are being delivered.

- Call the project manager and provide an overview of the activities undertaken during the day.

5.0 Sample Preparation

As noted in Section 4.0, samples are caught whole, washed at the point of sampling and then transported to the laboratory.

The samples will be registered in line with the laboratory procedures (as noted in Section 4.0) and transferred to a DPI representative who will carry out preliminary preparation on all samples (primary, duplicate, triplicate samples and samples that will be placed on hold) for analysis.

Two types of sample preparation will be required depending on the Biota Group:

- Group PR, Group CR or Group OY will be prepared as composite samples as detailed in Section 5.1; and

- Group X, Group Y or Group Z will be prepared as whole samples.

The approach will ensure that all primary, duplicate and triplicate samples are subject to the same preparation procedures in terms of obtaining the sample.

5.1 Composite sampling (prawns, crabs and molluscs)

This step relates to samples with an ID relating to Group PR, Group CR or Group OY

The sample will be removed from its storage container and deshelled. The edible portion of the sample will removed from the remainder of the sample. The portion of the sample removed from the shell will be weighed and recorded.

For samples from Group CR, all internal meat is to be removed and placed together. Each sample bag will contain a number of species, so care will be taken to prepare one sample bag at a time. Once the species are deshelled, the sample will be placed into any appropriate container.

Primary and duplicate samples will then be passed to NMI for preparation for analysis in line with their procedure. Triplicate samples will be transported (chilled and under chain of custody) to the secondary laboratory.

All samples to be held will be placed into appropriate storage containers and placed in freezers in the laboratory.

5.2 Whole samples (fillets)

This step relates to samples with an ID relating to Group GX, Group GY or Group GZ.

The sample will be descaled and gutted.

If the contents of the gut are identifiable, it will be recorded.

Where roe is present, it will be removed from the fish and recorded. The roe will be placed in separate containers and assigned an ID of the parent fish, with a sub ID ROE. The sample will be frozen and placed on hold and will be analysed, pending discussion with project team.

Once the sample is descaled and gutted, the sample will be filleted with the skin intact. The right side fillet will be used as the primary sample and the left side fillet will be placed on hold. Where a fish is earmarked for duplicate or triplicate analysis the left fillet of the primary will be used.

Table 1 Species List and Groupings

Species Legal length* cm Saltwater

Group X (GX)

Sand Whiting (Sillago ciliata) 27

Dusky Flathead (Platycephalus fuscus) 36

Group Y (GY)

Silver Biddy (Gerres subfacsiatus) -

Yellowfin Bream (Acanthopagrus australis) 25

Group Z (GZ)

Luderick (Girella tricuspidata) 27

Sea Mullet (Mugil cephalus) 30

PR

Eastern King Prawn (Melicertus plebejus) -

School Prawn (Metapenaeus macleayi) -

CR

Mud crab (Scylla serrata) 8.5

Blue crab (Portunus pelagicus) 6

OY

Pipi (Donax deltoids) -

Sydney Rock Oyster (Saccostrea glomerata) -

*Legal Length (should be confirmed with NSW DPI website at the time of sampling)

The sample nomenclature is presented in Table 2, the example assumes that sampling occurs in Area 2 at Site 2D with one eastern king prawn, one school prawn, one sea mullet, one silver biddy and one sand whiting caught.

Table 2 Sampling Nomenclature

Site Species Group

Sample number

Date Sample ID Comment

2D PR 001 20160111 2D_PR_001_20160111 eastern king prawn

2D PR 002 20160111 2D_PR_002_20160111 school prawn

2D GX 003 20160111 2D_GX_003_20160111 whiting

2D GY 004 20160111 2D_GY_004_20160111 bream

2D GY 005 20160111 2D_GY_005_20160111 silverbiddy

Table 3 Information to be recorded per sample

Comments

Sampling Location

Date

Time

Weather conditions

Species: Name

Photo

Length

Weight

Observations:

Abundance of species in the area?

Sample Preparation

How was sample caught

Was sample washed

All whole samples will be filleted in the primary laboratory.

or sent to secondary laboratory

Overview of key steps in the Aquatic Biota Sampling

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