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

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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.

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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:

28

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

29

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.

32

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.

33

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.

35

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 .

38

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.

39

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.