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Fire Training Water Quality Criteria - CFA Training Grounds, VictoriaCountry Fire Authority, Victoria Job No 212163.8 Prepared for AshurstMarch 2014

DOCUMENT CONTROL© Copyright 2014Cardno Lane Piper Pty Ltd (ACN 120 109 935)Bldg 2, 154 Highbury Road, Burwood Vic 3125Tel: (03) 9888 0100 Fax: (03) 9808 3511www.lanepiper.com.au www.cardno.com.au

This report is prepared solely for the use of Ashurst (the client) to whom this report is addressed and must not be reproduced in whole or part or included in any other document without our express permission in writing. No responsibility or liability to any third party is accepted for any damages arising out of the use of this report by any third party.

Report Title: Fire Training Water Quality Criteria - CFA Training Grounds, VictoriaDoc. Ref: 212163.8Report01.8

Date: 27 March 2014

Client: Ashurst

Signatures: Prepared By: Authorised By:

Giorgio DeNola M.A.Sc. (Toxicology)Project Manager

Anthony Lane CEnvPSenior Principal

Documents Distribution:No of

Copies Type Recipient Name Position & Company

1 Electronic Rob Jamieson Partner, Ashurst

1 Electronic File 212163.8 Cardno Lane Piper Pty Ltd

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Privileged & ConfidentialFire Training Water Quality Criteria - CFA Training Grounds, Victoria

Ashurst

FIRE TRAINING WATER QUALITY CRITERIA - CFA TRAINING GROUNDS, VICTORIA

EXECUTIVE SUMMARY

Background

Cardno Lane Piper was engaged by Ashurst (“the Client”), to prepare a set of water quality criteria applicable to fire-fighting training for adoption at the Country Fire Authority’s (CFA)Field Training Grounds across Victoria.

Objectives

The objectives of the current study were to:Propose a set of criteria for a ‘fit for purpose’, non-potable and sustainable water quality suitable for use in fire-fighter training; andEstablish 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.

Scope of Report

Water quality is a complex topic that is often over simplified for the purposes of mass communication. The quality of water is normally assessed based on published or peer-reviewed criteria which compare the physical, chemical, biological and aesthetic aspects thatare directly related to a potential use of that resource.

The primary aim of this document is not only to propose a set of derived Water Quality Criteria for use in provision of safe supply of water for training, but also to present a body of guidance and information available for the Country Fire Authority technical advisors and managers in their future management of fire training activities involving water.

The information provided to achieve this aim is presented in the report as follows:List of published guidelines that includes the use and reuse of water in industry;Discussion of published water quality criteria used for various water uses;Description of different sources of water potentially used in fire-fighter training activities;Identification of relevant physical, chemical and microbial parameters that have been used to define water quality;Description of how water has been used by CFA in training and operationally; andDerivation and/or selection of a series of site specific criteria for water uses relevant to protecting CFA training personnel and the environment.

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Conclusion

This report has been prepared for the CFA to provide Water Quality Criteria for non-potable, ‘fit-for-purpose’ water for fire-fighting training. The Water Quality Criteria provided in this report are considered to be conservative and provides safe water for use in fire-fighting training. The WQC proposed for use by CFA are selected and/or derived for hot-fire training and include:

Treatment Management Levels: Criteria used to monitor the performance of a Water 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 Personnelfor select compounds (organic and inorganic chemicals) and microbial pathogens based on an Human Health Risk Assessment prepared for CFA Fiskville Training College (Cardno Lane Piper, 2014a).Environmental Discharge Criteria: These criteria are used for protection of the ecology of the surface water bodies to which water is discharged. These are primarily based on established guidelines in Australia (ANZECC 2000) and SEPP Waters of Victoria (GoV 2003).

A proposed set of WQC for fire-fighting training is presented in Table 5-7 (reproduced below) which are suitable for use at Fiskville FTC and may be considered as a basis for similar criteria at other FTG. These should be reviewed for relevance at each FTG given the differences in water sources, treatments and modes of use.

A WQMP has been developed for Fiskville FTC using the WQC proposed here and is presented in a separate document.

Parameter WQ Trigger 1 (WQT-1)Treatment Management

Levels

WQ Trigger 2 (WQT-2)

OHS Target


Environmental Discharge

Target

Continuous Monitoring Parameters

pH 6 to 9 (90%) 5 to 10 6.5 to 8.3

Chlorine levels 1 mg/L (min) 0.5 mg/L (min) 0.013 mg/L

Turbidity2 NTU (median)

5 NTU (max)- 25 NTU

Suspended Solids 5 mg/L - -

Electrical Conductivity - - 500 S/cm

Dissolved oxygen - - >6 mg/L

Periodic Monitoring Parameters

Escherichia coli (E. Coli) 10 org/100mL 150 org/100mL -

BOD 10 mg/L - 15 mg/L

COD - - 40 mg/L

Total Phosphorous - - 0.025 mg/L

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Parameter WQ Trigger 1 (WQT-1)Treatment Management

Levels


OHS Target


Environmental Discharge

Target

Total Nitrogen - 0.6 mg/L

Surfactants - - 0.0001 mg/L

Oil and grease - - 0.3 mg/L

Perfluorinated Compounds (PFC)1

NCR3

0.0051 mg/L

Total Petroleum Hydrocarbons (TPH) NVI2

Arsenic (III) 0.024 mg/L

Arsenic (V) 0.013 mg/L

Chromium (total) 0.001 mg/L

Copper 0.0014 mg/L

Lead 0.0034 mg/L

Nickel 0.011 mg/LNote: NCR – WQC Not Currently Required NVI = No value identified1. Based on PFOS2. All practical efforts should be undertaken to remove residual TPH fractions from water used in fire-fighter training 3. Based on assessment of risks to human health for occupational exposures during fire-fighter training, refer to Appendix B.

Limitations

While this Executive Summary has endeavoured to accurately summarise the key points of the Report, the latter shall take precedence and the Executive Summary must be read in conjunction with the full report (Cardno Lane Piper document ref: 212163.8Report01.8)

Cardno Lane Piper Pty Ltd

March 2014

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Table of ContentsDOCUMENT CONTROL ........................................................................................................... I EXECUTIVE SUMMARY.......................................................................................................... II 1 INTRODUCTION...............................................................................................................9

1.1 Background...............................................................................................................9 1.2 Purpose & Objectives ...............................................................................................9 1.3 Scope of the Report ..................................................................................................9 1.4 Project Team ..........................................................................................................10

2 WATER QUALITY GUIDELINES & CRITERIA ................................................................11 2.1 National Water Quality Management Strategy ........................................................11 2.2 Guidelines for Water Use and Reuse in Victoria .....................................................13 2.3 Water Quality Parameters & Criteria .......................................................................15

2.3.1 Published Water Quality Criteria for Various Water Uses ......................................... 16 2.3.2 Microbial Criteria........................................................................................................ 16 2.3.3 Criteria applicable to water used by CFA in training ................................................. 19

3 WATER QUALITY PARAMETERS..................................................................................20 3.1 Water Sources – Definition .....................................................................................20

3.1.1 Potable Water ............................................................................................................ 20 3.1.2 Rainwater................................................................................................................... 20 3.1.3 Reclaimed Water ....................................................................................................... 21 3.1.4 Process Water ........................................................................................................... 21 3.1.5 Environmental Waters ............................................................................................... 22 3.1.6 Stormwater ................................................................................................................ 22 3.1.7 Sewage and Greywater ............................................................................................. 22

3.2 Water Sources – Identification ................................................................................23 3.3 Physical Characteristics of Water Quality................................................................23

3.3.1 Suspended Solids and Turbidity................................................................................ 23 3.3.2 pH .............................................................................................................................. 23 3.3.3 Biological and Chemical Oxygen Demand (BOD and COD)..................................... 23 3.3.4 Electrical conductivity ................................................................................................ 24

3.4 Chemical Parameters of Water Quality ...................................................................24 3.4.1 Metals ........................................................................................................................ 24 3.4.2 Industrial Chemicals .................................................................................................. 24

3.5 Microbiological pathogens.......................................................................................25 3.5.1 Endotoxins and Algal Toxins ..................................................................................... 26 3.5.2 Opportunistic and Enteric Microbial Pathogens ........................................................ 27

3.6 Water Pollution .......................................................................................................28 4 WATER USE IN CFA TRAINING.....................................................................................29

4.1 Water Source Categories........................................................................................29 4.2 Sources of Water at CFA Training Grounds............................................................30 4.3 Water Sources for Fire-Fighting Operations............................................................31

5 PROPOSED WATER QUALITY CRITERIA.....................................................................33 5.1 Treatment Management Levels...............................................................................33 5.2 Risk Based OHS Water Quality Criteria ..................................................................34

5.2.1 Summary of Risks for CFA Training Personnel during Hot-Fire Training ................. 35 5.2.2 OHS Risk Based Targets for Inorganic Chemicals ................................................... 35 5.2.3 Health Based Targets for Organic Chemicals ........................................................... 36 5.2.4 Health Based Targets for Microbiological Pathogens ............................................... 36

5.3 Environmental Discharge Criteria............................................................................38 5.4 Example Set of Criteria for a WQMP.......................................................................40

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6 CONCLUSION ................................................................................................................42 7 REFERENCES................................................................................................................43

Text TablesTable 2-1: Summary of available national water quality guideline documents......................... 11 Table 2-2: Guidelines for water use and re-use in Victoria......................................................14 Table 2-3: Summary of Physicochemical Parameters ............................................................15 Table 2-4: Summary of Water Quality Guidelines ...................................................................17 Table 3-1: Indicative log reduction values for drinking water...................................................20 Table 4-1: Water Source Categories ......................................................................................30 Table 4-2: Historical Water Sources CFA FTGs .....................................................................31 Table 5-1: Treatment Management Levels for use as Water Quality Triggers 1 (WQT-1)....... 34 Table 5-2 Hypothetical Health Based Targets – metals (mg/L) ...............................................35 Table 5-3: OHS Risk Based Targets derived for Compounds of Potential Concern ................ 36 Table 5-4: Health Based Target for microorganisms...............................................................36 Table 5-5: Target log reductions required for enteric pathogens in water ...............................37 Table 5-6: Environmental Discharge WQC.............................................................................39 Table 5-7: An example set of water quality parameters and relevant Criteria ......................... 41

Text FiguresFigure 4-1: Sources of Water Potentially Used at CFA Training Grounds...............................29

AppendicesAppendix A....................................................................................................... 4 Pages Historical Water Uses at Field Training Grounds

Appendix B..................................................................................................... 11 Pages Water Quality Criteria Derivation

Appendix C..................................................................................................... 11 Pages Literature Review of Ecological Criteria for Perfluorinated Compounds (PFC)

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LIST OF ABBREVIATIONS AND UNITS

Chemical Names6:2 FtS 6:2 Fluorotelomer

BTEX Benzene, Toluene, Ethylbenzene & Xylenes (subset of MAH)

CHC Chlorinated Hydrocarbons

MAH Monocyclic Aromatic Hydrocarbons

PAHs Polycyclic Aromatic Hydrocarbons

PCBs PolyChlorinated Biphenyls

PFCs Perfluoro Compounds

PFOA Perfluorooctanoic Acid

PFOS Perfluorooctane Sulfonate

PHC Petroleum Hydrocarbons

TDS Total Dissolved Solids (salinity of water)

TOC Total Organic Carbon

TPH Total Petroleum Hydrocarbons

TRH Total Recoverable Hydrocarbons (= TPH)

Technical TermsAFFF Aqueous Film Forming Foam

AGL Above Ground Level

ANZECC Australian and New Zealand Environment and Conservation Council

AST Aboveground Storage Tank

BDL Below Detection Limit

BGL Below Ground Level

BOD Biological Oxygen Demand

CL Confidence Limit

COD Chemical Oxygen Demand

CoPC Chemicals/Compounds of Potential Concern

DO Dissolved Oxygen

EC Electrical Conductivity

EILs Environmental Investigation Levels

EPA Environment Protection Authority

ESA Environmental Site Assessment

HILs Health Investigation Levels

HHRA Human Health Risk Assessment

LNAPL Light Non-Aqueous Phase Liquid

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LOR Limit of Reporting

LRV Log Reduction Value

MSDS Material Safety Data Sheet

WMP Wimmera-Mallee Pipeline

N/A Not Applicable

NAPL Non-Aqueous Phase Liquid

NEPM National Environmental Protection Measure

NTU Nephelometric Turbidity Units, NTU

PQL Practical Quantitation Limit

PSH Phase Separated Hydrocarbon

QMRA Quantitative Microbial Risk Assessment

SS Suspended Solids

TDS Total Dissolved Solids

TIT Triple Interceptor Trap

UST Underground Storage Tank

UnitsmBGS Metres Below Ground Surface

mg/L Milligram per Litre

ppb Parts per Billion

ppm Parts per Million

ppt Parts per Trillion

μg/L Microgram per Litre (equivalent to ppb)

μS/cm Micro Siemens per Centimetre (Electrical Conductivity - Water)

ng/L Nanograms per Litre (equivalent to ppt)

Site SpecificCFA Country Fire Authority

FTG Field Training Ground

HBT Health Based Target

PAD Practical Area Drill

PPE Personal Protective Equipment

WQC Water Quality Criteria

WQMP Water Quality Management Plan

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1 INTRODUCTION

1.1 Background

Cardno Lane Piper was engaged by Ashurst (“the Client”), to prepare advice on water quality criterion for fire fighting training that would be applicable for all the Country Fire Authority’s (CFA) Field Training Grounds (FTG)1.

1.2 Purpose & Objectives

The purpose of this report is to assist the CFA to develop a protocol for managing water quality at the FTGs in order to allow fire training to continue using sustainable sources of water that do not need to be of a potable water quality. The protocol would be presented in a Water Quality Management Plan (WQMP, Cardno Lane Piper 2014b) for adoption and use by the CFA as part of their FTG management procedures.

The objectives of the current study were:Propose a set of criteria for non-potable water quality suitable for use in fire-fighter training; andEstablish 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.

1.3 Scope of the Report

Water quality is a complex topic that is often over-simplified for the purposes of mass communication. The quality of water is normally assessed based on predefined and agreed criteria which measure the physical (i.e. pH, temperature, conductivity), chemical (i.e. metals, nutrients, organic), biological (i.e. microbial levels, algae) and aesthetic (i.e. odour, taste) aspects which are directly related to a proposed use of that resource.

The primary aim of this document is to:Present a body of guidance and information available for CFA technical advisors and managers in their future management of fire training activities involving water.Prepare a set of derived Water Quality Criteria (WQC) for use in provision of safe supplies of water for hot-fire training.

The information provided to achieve this aim is presented as follows:List published guidelines that includes the use and reuse of water in industry (Section 2);Discuss published water quality criteria used for various water uses (Section 2.3);Describe different sources of water potentially used in fire-fighter training activities (Section 3.1);

1 CFA has its main FTG campus at the Fiskville Training College and smaller regional FTG campuses at Penshurst, Longerenong, Bangholme, Sale, Wangaratta and Huntly.

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Identify relevant physical, chemical and microbial parameters used to define water quality (Sections 3.2, 3.4 and 3.5);Summarise how water has been used by CFA in training and operationally(Section 4); andDerive and/or select of a series of site specific criteria for water uses relevant to protecting CFA training personnel and the environment (Section 5).

1.4 Project Team

This report was prepared by a team of specialists from Cardno Lane Piper including a Principal Environmental Auditor, Senior Toxicologist and Principal Water Engineer. This team was supported by a microbiologist specialist Nick O’Connor of Ecos Environmental Consulting.

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2 WATER QUALITY GUIDELINES & CRITERIAWater quality is commonly described using terms such as “water standards” and “safe levels” and sometimes “water quality criteria” or even “water quality guidelines”. The subtle but significant differences between these various concepts in communication of water quality arediscussed in this section as a resource for CFA and users of these WQC adopted in a WQMP.

2.1 National Water Quality Management Strategy

A National Water Quality Management Strategy (NWQMS) has been jointly developed by Australia and New Zealand. The aim of the NWQMS is “to protect the nation's water resource”and in doing so adopt an approach that achieves sustainable use of water resources and to improve water quality. The NWQMS consists of three major elements: policy (Documents 1and 2), process (Document 3) and guidelines (Documents 4 to 24). These documents may be accessed from the NWQMS website2. The guideline documents (i.e. Documents 4 to 24) have been developed to provide a national approach for management of:

Water quality;Groundwater;Diffuse and point sources;Sewage systems;Effluent management (not summarised here); andWater recycling.

These national guidelines were developed “to provide guidance on best practices” of water management. They were not designed to be “prescriptive and do not represent mandatory standards”. Instead, these guidelines were designed to be complimentary and were provided as a reference that can be integrated into state and regional (catchment area) documents. A short summary of relevant guideline documents for water reuse is provided in Table 2-1. The summary is neither extensive nor intended to be comprehensive for the respective guidelines, it is only provided here to bring to the attention of the reader their relevance to water quality and management.

Table 2-1: Summary of available national water quality guideline documents

Guideline Name Aim of guidelines Reference

Water Quality Guidelines

Document 4: An Introduction to the Australian and New Zealand Guidelines for Fresh and Marine Water Quality(Volumes 1 to 3)

The ANZECC Guidelines: This guideline “provide government and the general community (particularly catchment/water managers, regulators, industry, consultants and community groups) with a sound set of tools for assessing and managing ambient water quality in natural and semi-natural water resources”.

Note: An introductory document is also available (Document 4a).

ANZECC2000a

Document 5: Guidelines for managing risks in recreational water

“The primary aim of these guidelines is to protect the health of humans from threats posed by the recreational use of coastal, estuarine and fresh

NHMRC2008a

2 The NWQMS website: http://www.environment.gov.au/water/policy-programs/nwqms (accessed on 10 April 2013).

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waters”.

Document 6: The Australian Drinking Water Guidelines (2011):

The Australian Drinking Water Guidelines (ADWG):These guidelines were developed by NHMRC “to provide an authoritative reference to the Australian community and the water supply industry on what defines safe, good quality water, how it can be achieved and how it can be assured”.

NHMRC2011

Document 7: Australian guidelines for water quality monitoring and reporting –2000.

The monitoring guideline: This guideline “provides a comprehensive framework and guidance for the monitoring and reporting of fresh and marine waters and groundwater”.

ANZECC2000b

Groundwater management

Document 8: Guidelines for groundwater protection – 1995.

The objective of these guidelines is to provide a framework for protecting groundwater from contamination in Australia.

ANZECC1995

Diffuse and point sources management

Document 9: Rural land uses and water quality - acommunity resource document– 2000.

This guideline “provides background information on a number of the principal issues which affect water quality in rural environments. The document has been written in recognition that there are a range of land uses that can impact on water quality but which are not addressed in the other NWQMS guideline documents”.

ANZECC2000c

Document 10: Guidelines for urban stormwater management– 2000.

“These guidelines will help managers to identify objectives for stormwater management (including protecting social, environmental and economic values) and to integrate management activities at the catchment, waterway, and local development level”.

ANZECC2000d

Guidelines for sewerage systemsDocument 11: Guidelines for sewerage systems - effluent management – 1997.

“This document reviews the overall management of sewerage systems and specifically addresses effluent management”.

ANZECC1997

Document 12: Guidelines for sewerage systems -acceptance of trade waste (industrial waste) – 1994.

“This document provides national guidelines for trade wastes discharged to sewer and can assist sewerage authorities with the implementation of their trade waste management programs”.

ANZECC1994

Document 13: Guidelines for sewerage systems - sludge (biosolids) management –2004.

“The focus of the document is to facilitate the beneficial use of biosolids”.

ANZECC2004a

Document 14: Guidelines for sewerage systems - use of reclaimed water – 1999(Also see related documents 21-24 Guidelines for recycled water below).

“These Guidelines provide advice on reclaimed water quality, level of treatment, safeguards and controls and monitoring. The guidelines address effluent arising from municipal (i.e. community) wastewater plants; however, they do not consider reclaimed water from individual household systems or undiluted liquid wastes of industrial origin”.

ANZECC2000e

Document 15: Guidelines for sewerage systems - sewerage system overflows – 2004.

“The purpose of these guidelines is to show how to minimise and manage overflows and their impact through regulation, sewerage system design, and judicious selection of sites for overflow if it does occur, and operation and maintenance of the sewerage systems”.

ANZECC2004b

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Guidelines for Water Recycling

Document 21: Australian guidelines for water recycling: Managing health and environmental risks (Phase 1) - 2006.

“These guidelines deal with recycling of stormwater, greywater and treated sewage. This current document, the first module of Phase 2 of the guidelines, extends the guidance given in Phase 1 on the planned use of recycled water (treated sewage and stormwater) to augment drinking water supplies. The document focuses on the source of water, initial treatment processes and blending of recycled water with drinking water sources”.Note: These guidelines do not deal specifically with recycling of water from industrial and commercial sources however they can be used as a guide.

NHMRC2006

Document 22: Australian guidelines for water recycling: Managing health and environmental risks (Phase 2) -Augmentation of drinking water supplies – 2008.

“This document, the first module of Phase 2 of theguidelines, extends the guidance given in Phase 1 on the planned use of recycled water (treated sewage and stormwater) to augment drinking water supplies. The document focuses on the source of water, initial treatment processes and blending of recycled water with drinking water sources”.

NHMRC2008

Document 23: Australian guidelines for water recycling: Managing health and environmental risks -Stormwater harvesting and reuse – 2009.

This document “is the second module of Phase 2 of the guidelines and extends the guidance given in Phase 1 to cover the harvesting and reuse of stormwater”.

NHMRC2009a

Document 24: Australian guidelines for water recycling: Managing health and environmental risks - Managed aquifer recharge – 2009.

The document is the “third module of Phase 2 of the guidelines focuses primarily on the protection of aquifers and the quality of the recovered water in managed aquifer recharge projects”.

NHMRC2009b

2.2 Guidelines for Water Use and Reuse in Victoria

A number of guidelines have been developed that are applicable to the use and reuse of a variety of different water sources. Some of these may be available for fire-fighting activities. Guidelines that are relevant to the use and reuse of water in Victoria are listed below in Table 2-2. A risk profile is provided that qualitatively indicates the level of risk attributed to each water source with respect to the water being used in CFA training exercises. For some water sources there may be a requirement for regulatory approval where water is to be reused.

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Table 2-2: Guidelines for water use and re-use in Victoria

Watersource1

Training Water Risk

Profile2Guidelines for water use and re-use Reference

Potable Water Low Australian Drinking Water Guidelines 6, 2011. National Water Quality Management Strategy

NHMRC (2011)

Rainwater Low to medium

Guidelines for Non-Drinking Applications in Multi-residential, Commercial and Community facilities DHS 2007

Reclaimed Water

Low (class A) to high (class D)

Guidelines for Environmental Management: Use of Reclaimed Water (EPA publication 464.2, 2003) EPA 2003

Guidelines for Environmental Management: Dual Pipe Water Recycling Schemes––Health and Environmental Risk Management (EPA publication 1015, 2005)

EPA 2005

Process Water Low to highIndustrial Waste Resource Guidelines: Industrial Water Reuse Guidelines (EPA publication IWRG632,2009)

EPA 2009

Environmental Water(surface waters and groundwater)

Low to high



EPA 2005

Stormwater Medium to high

Australian Guidelines for Water Recycling: Managing Health and Environmental Risks (Phase 2) Stormwater Harvesting and Reuse

NHMRC 2009

Grey Water and sewage High



EPA 2005

Australian Guidelines for Water Recycling: Managing Health and Environmental Risks (Phase 1) NHMRC 2006

Note:1. The various water types listed here are described later in Section 3.1.2. A qualitative assessment of risk to human health has been performed for water used in hot fire training. The risk assigned is

based on the following risk profiles: i. Low Risk: site controls to minimise human contact with water unlikely to be required.ii. Medium Risk: site controls to minimise human contact with water potentially required.iii. High Risk: treatment required and/or minimise human contact with water.

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2.3 Water Quality Parameters & Criteria

Water quality can be assessed by using a series of parameters summarized in Table 2-3. The criteria derived for these parameters may be used to determine whether the desired water quality has been met for a particular use. In this document, the particular use is for water suitable for use in fire-fighting training and to ensure training does not have an impact on the environment. Other beneficial uses also require consideration.

Table 2-3: Summary of Physicochemical Parameters

Monitoring Parameters

Physical

Temperature

Suspended solids (SS)

Turbidity

Biological and chemical oxygen demand (BOD and COD)

Electrical conductivity (EC)

Chemical

Nutrients (e.g. phosphorus, nitrate, nitrite, iron)

Dissolved oxygen (DO)

pH

Metals

Manufactured chemicals

MicrobialEndotoxins and Algal Toxins

Opportunistic and enteric microbial pathogens

Water quality criteria have been derived for each of the above parameters by various agencies at international, national and at state levels. The main function of water quality criteria is to allow an objective decision to be made on whether water quality is suitable for a particularbeneficial use3 or environmental value to be protected. Criteria are also applied to provide triggers for pre-determined management or monitoring actions.

For example, in Victoria, water quality objectives have been established for various beneficial uses under the State Environment Protection Policy - Waters of Victoria (Government ofVictoria, 2003), and these uses are summarized below, but not limited to:

Aquatic ecosystems;Primary industries (i.e. irrigation and general water uses, stock drinking water, aquaculture and human consumption of aquatic foods);Recreation and aesthetics;Human consumption after appropriate treatment (i.e. Potable water);Industrial and commercial use; andCultural and spiritual values.

EPA has identified WQC (form various published references as well as within the gazetted policy) which they have adopted as the appropriate values to be applied as ‘objectives’ under the regulation.

3 It is important to note that the term ’Environmental Values’ has replaced or been adopted instead of ‘beneficial uses’ in the Australian and New Zealand Guidelines for Fresh and Marine Water Quality (NWQMS, 2000).

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2.3.1 Published Water Quality Criteria for Various Water UsesA compilation of generic/published criteria from various jurisdictions for primary contact recreation and reclaimed water is shown in Table 2-4.

2.3.2 Microbial Criteria

For drinking water the level of E. coli should be zero organisms per 100 mL of water. The water parameters provided (i.e. turbidity, chlorine, pH, thermotolerant coliforms, E. coli and BOD) were selected as per specifications in the Victorian guidelines which are summarized in Table 2-4. These water parameters are described in more detail in Section 3. E. coli or Enterococci have both been specified as indicator bacteria to identify the potential for faecal contamination to be present in water.

Typically, only one of these bacteria is chosen in a monitoring program. E. coli is typically chosen as an indicator in fresh water as it has a longer survival time than enterococci in afresh water environment. In marine waters, Enterococci would be used as the indicator. As water used at CFA Training Grounds is “fresh water” the criteria for E. coli are provided below. Note that an exceedance of criteria listed in Table 2-4 does not necessarily mean that effects to human health will be observed. This includes for E. coli which is used to indicate the presence of other faecal coliforms that may result in adverse health effects. Also note that the primary contact recreation criterion for E. coli (<150 organisms/100mL) is intended to be compared against an averaged value taken from at least 5 samples within a one month period with a maximum of 600 organisms/100mL (ANZECC 2000a, NHMRC 2008a).

In accordance with the existing Water Management Plans, CFA has routinely monitored for Ecoli in water used for fire-fighting training exercises at CFA Training Grounds. It has typically been reported at less than 100 organisms per 100 mL. Also an opportunistic pathogen (Pseudomonas aeruginosa) has been monitored as a management tool to restrict use of water should cell counts exceed set criteria (e.g. 10 organisms per 100 mL). Both P. aeruginosa and E. coli are ubiquitous in the environment. E. coli is consistently detected in natural and“artificial” surface water bodies in agricultural areas (e.g. 210 organisms per 100 mL) or urban areas (e.g. 450 organisms per 100 mL) (CRC, 20044).

Following a rain event, the mean level of E. coli in surface water bodies will be elevated due tosurface runoff and in intensive agricultural areas can reach levels up to 17,700 organisms per 100 mL. The increase in E. coli levels may occur as a result of animal faecal contamination on the ground being washed into surface water bodies. Therefore, water from surface water bodies is likely to require a form of treatment before use. Natural background levels are an important consideration when interpreting water monitoring results.

4 CRC (2004) prepared a document titled “Pathogen Movement and Survival in catchments, groundwaters and Raw Water Storages” that discusses microbial pathogen loads in surface waters.

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2.3.3 Criteria applicable to water used by CFA in training

The criterion most applicable for CFA training personnel use of water is dependent on the exposure to water during a particular drill. For CFA training personnel, the amount assumed to be accidentally swallowed during a training exercise is 1 mL (best justified assumptions) or 12.5 mL for a more conservative assumption as assessed in the Human Health Risk Assessment (HHRA) reported separately by Cardno Lane Piper (2014a). The best justifiedvalue (i.e. 1 mL) is 3 orders of magnitude less than the typical daily consumption of drinking water (i.e. 2 L per day) and also well below that accidentally swallowed by people during primary contact recreation (i.e. swimming).

Guidelines derived for primary contact recreation may be applied for CFA fire-fighting trainingpurposes where it can be justified. The generic criteria for primary contact recreation are provided above for context (Table 2-4), and a criterion specific to CFA training personnel is discussed in Section 5.1.

The advice provided for these criteria varies widely between agencies. Differences are seen in the standards set and/or the monitoring frequencies. In some instances a value may not have been set. Other differences that may need clarification when selecting and applying criteria are:

Conversion factors between salinity and conductivity that differ between the states. In some jurisdictions, including Victoria, total dissolved salts is specified (ionic components estimated by measuring conductivity) while elsewhere total dissolved solids (determined by weighing residues of ionic or non-ionic components after drying) may be specified.Criteria for chlorine may be specified for different forms (e.g. residual, free or total).Thermo tolerant coliforms criteria are used as the indicator organism for faecal contamination, particularly for older monitoring plans. However, in Victoria, E. coli is often used as the indicator for microbial pathogen whereas thermo tolerant coliforms are suggested as possibly being used5. Note that analytical data sometimes include data for another coliform parameter, total coliforms.

5 For example, a criterion is set for Thermotolerant coliforms in reclaimed water guidelines prepared by ANZECC (NWQMS 2000) whereas a criterion is set for E. coli in the primary contact recreation guidelines (NHMRC 2008a). Refer to Table 2-4.

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3 WATER QUALITY PARAMETERSThe sources of water used in hot-fire training and the respective parameters sometimes used to assess water quality are described in this section. Most of these parameters are not specifically a measure of potential adverse human health impacts. The criteria that have been set for selected parameters specific to hot-fire training are provided in Section 5.

3.1 Water Sources – Definition

Training exercises at the CFA Training Grounds require a reliable and safe supply of water. There is a variety of water sources that may be used for CFA training exercises and they are summarised in this section.

3.1.1 Potable Water

Potable or drinking water is supplied by the respective water retailers to most CFA Training Grounds, with the exception of Longerenong and West Sale. The Longerenong site receives its water supply from the Wimmera Regional Water pipeline, and the West Sale site relies on groundwater to supplement its water supply. Potable water provided by a water utility companyis considered safe for human consumption and therefore it is suitable for any of the CFA training exercises.

A water treatment system will likely be required for most sources other than potable, particularly where water recirculation or reuse is considered. The level of treatment is dependent on intention to reuse water or potentially discharge it to the environment. Microbial pathogens are considered the greatest risks for water users. Treatment for microbial pathogens is often discussed in terms of ‘log reductions’, where one log reduction is equivalent to a 10 fold reduction in pathogen concentration. Indicative log reduction values (LRV) are provided in Table 3-1 for surface waters used as a source of potable water, and are applicable for drinking water only. The LRV required for untreated water used in fire-fighting training is discussed in Section 5.2.4.

Table 3-1: Indicative log reduction values for drinking water

Source Water Potential for faecal coliforms to be present in water

Indicative log reductions1

Virus Bacteria Protozoa

Protected surface water Nil 0 4 - 6 0

Unprotected surface water

Low 3 - 4 5 - 6 3

High 5.5 - 6.5 6 5.5Note:1. LRV sourced from NHMRC (2009). A draft discussion paper addressing health based targets for microbial

safety of drinking water supplies.

3.1.2 Rainwater

Rainwater is defined as water that is collected from a roof catchment and is considered tohave a low to medium risk as an alternative to a potable water supply (i.e. for uses other than as drinking water). Treatment of rainwater is unlikely to be required for most uses; however,treatment is recommended for uses that involve significant human contact (e.g. swimming). This is because rainwater may be contaminated with microbial pathogens and/or chemicals.

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Therefore, the roof catchment area used to collect rainwater should be protected and the storage roofed to prevent contamination and reduce the level of treatment that may potentially be required.

Note that rainwater does not include stormwater captured from rain events, e.g. run-off from acar park or other ground surface area. Refer to stormwater in Section 3.1.6.

3.1.3 Reclaimed Water

Reclaimed water is defined as water “that has been derived from sewerage systems or industry processes treated to a standard that is appropriate for its intended use” (EPA 2003). Reclaimed water refers to water treated off-site, typically at a sewage treatment plant and supplied to CFA for training. Reclaimed water does not refer to process water or sewage that is generated on-site, treated on site and then reused by CFA. These are discussed separately; process water in Section 3.1.4 and treated sewage in Section 3.1.7.

Reclaimed water is supplied in various classes (Class A being the best quality class through to class D). The level of contaminants, in particular microbial pathogens, suspended solids and BOD, determines the reclaimed water classification.

The reclaimed water classification is dependent on a water treatment process which includesas a minimum:

Primary treatment: sedimentation to remove solids from waterSecondary treatment: removal of more than 85% BOD and suspended solids using a chemical or biological process. This level of treatment is a minimum requirement for most agricultural and municipal water reuse schemes.Tertiary treatment: removal of a high percentage of BOD and suspended solids and disinfection of water. A requirement for Class A reclaimed water.

Note that reclaimed water may be supplemented with water from other sources to reduce elevated total dissolved solids (TDS). However, the respective treatment standards for E. coli,suspended solids, BOD and pH must be met prior to dilution.

3.1.4 Process Water

Process water, also called ‘Industrial water’, is waste water sourced from industrial or manufacturing processes. It has been used for a variety of industrial and non-industrial uses with appropriate controls. These uses may include washing, rinsing, cooling, dust suppression,toilet flushing and irrigation. Process water may require specific treatment to produce the quality of water required for the end use. The quality of process water is dependent on a number of factors including:

The industrial process that generates the water;The number of times the water has been reused; andAdditives and/or chemical residues in the water.

Process water includes the water collected at a CFA Training Ground that has been used in training. This water has been stored in surface water bodies and/or tanks and in some circumstances has been treated (e.g. chlorination). It is potentially contaminated and common hazards include:

Microbial pathogens such as endotoxins, algal toxins, opportunistic microbial pathogens and enteric microbial pathogens (e.g. viruses, bacteria, protozoa and helminths);

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Inorganic compounds including metals (e.g. arsenic, barium, cadmium, chromium, copper,lead, mercury and zinc); andOrganic compounds: Water used in fire-fighting training has been known to contain fluorosurfactants (an additive used in fire-fighting foams) and petroleum hydrocarbons (liquid fuels used as a source of flames during training).

Note that process water does not include sewage collected on-site and treated; this is considered separately (Section 3.1.7).

3.1.5 Environmental Waters

The concept of ‘environmental water’ is varied. In this report the term ‘environmental water’simply relates to residual water that is not used for human consumption. It may be water stored in surface water bodies (e.g. dams, lakes, wetlands, etc.) including waterways such as drainage channels, creeks, rivers or groundwater. In legislative terms, the term environmental water may refer to water which is protected for ecological benefits (planned environmental water) and/or that may be sold for economic use (held environmental water, e.g. water rights).

Groundwater is held in sediment and rocks (aquifers) below the surface, sometimes in very deep aquifers disconnected from the surface water systems. It is an important source of water used in agriculture, industry and as drinking water. Groundwater may potentially becontaminated from human activities. The extent of contamination from microbial pathogens is likely to be considerably less than the contamination in water in unprotected surface water bodies and waterways.

3.1.6 Stormwater

Stormwater is defined as “surface run-off from rain and storm events that enters the drainage system” (EPA 2012). The use of stormwater is not subject to specific health regulation. Approval for its use is not regulated; however, in some circumstances the right to harvest stormwater or the implementation of a stormwater re-use scheme may need to be regulated.

Stormwater is easy to capture and is an alternative source of water used at some RTGs.However, stormwater run-off potentially includes litter, suspended solids, pathogens, residualoil and chemicals that can contaminate the water. Therefore, use of stormwater run-off requires similar considerations as given to the use of environmental waters which include management protocols and good catchment management practices.

The Victorian EPA recommends that the Australian Guidelines for Water Recycling: Managing Health and Environmental Risks (Phase 2) Stormwater Harvesting and reuse (EPHC, 2009)be followed for industrial premises.

3.1.7 Sewage and Greywater

Recycling of sewage or greywater for use in activities which potentially involve direct human contact, such as in fire-fighting training, is considered high risk unless a rigorous regime of risk management is implemented and technical expertise is available to operate and manage the treatment systems.

It is considered unlikely that any sewage generated at a RTG would be recycled for use in fire-fighting training. Therefore this source of water is not considered nor discussed further.

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3.2 Water Sources – Identification

It is important that the CFA conduct a potential water source identification assessment for each of its FTG. This would involve an assessment of respective FTG regional water catchment or aquifers (groundwater sources) for which the potential water sources for fire fighting operations are identified or may be relied upon.

3.3 Physical Characteristics of Water Quality

Some water quality parameters are routinely monitored as management levels (see Section 5.1), such as temperature, suspended solids and turbidity.

3.3.1 Suspended Solids and Turbidity

Suspended solids (SS) in water may consist of soil particles (e.g. sand, silt and clay) and organic material. SS is a water quality criterion typically used as an indicator of the efficiency of a water treatment process. It is also an aesthetic parameter or an indicator of potential ecological effects. Typically it is specified to prevent damage to infrastructure such as blockages in pipes. It is not a direct indicator of potential human health effects. However, SSmay act as a source of both microbial pathogens and chemical compounds that have adsorbed to soil particles and organic content, and therefore requires consideration where SS are high.

Turbidity is a measure of the amount of particulate matter and dissolved solids in water. It could potentially be used as an index of the clarity of water (monitoring units as Nephelometric Turbidity Units, NTU) and to estimate suspended solids in water. Turbidity has not typically been measured in water used in hot-fire training.

3.3.2 pH

pH is a measure of the molar concentration of hydrogen ions in water and is controlled to minimise corrosion of infrastructure. It is used to indicate the acidity (pH < 7), neutrality (pH = 7) or alkalinity (pH >7) of a water body. pH in reticulated water supplies range from 6 to 10.8 and in surface water bodies may range from 6 to 9.

Alkaline water with pH greater than 10 may lead to irritation of the eye, skin and mucous membranes and/or leave a bitter taste in drinking water. It may possibly lead to gastrointestinal irritation at pH > 10. Extremely acidic water may lead to irritation of eye, skin and mucous membranes. The NHMRC provides the following summary with regards to pH that can cause “eye irritation and exacerbation of skin disorders have been associated with pH values above 11. Gastrointestinal irritation may occur in sensitive individuals at pH values above 10. Below pH 4, redness and irritation of the eyes have been reported, with the severity increasing with decreasing pH” NHMRC (2011).

3.3.3 Biological and Chemical Oxygen Demand (BOD and COD)

It is important to note that the measurement of Biological Oxygen Demand (BOD) andChemical Oxygen Demand (COD) are indicator parameters rather than a direct measurement of a ‘contaminant’. They provide an indication as to the health or degradation of a water body ecosystem and specifically the oxygen depletion potential.

BOD is a measure of the amount of dissolved oxygen used by microorganisms in degrading available organic matter under aerobic conditions. It may be used as an indicator that

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conditions in water are suitable for biodegradation to occur that may subsequently result in the presence of microbial pathogens (e.g. decomposition of algal bloom and toxins).

COD is a measure of the amount of dissolved oxygen which is consumed due to chemical oxidation in water due to the contaminant loading. The ratio of COD versus BOD is commonly used as an indicator for anthropogenic contamination.

Oxygen availability and demand in a water body is of vital importance in ensuring the health of an ecosystem. The quantity of dissolved oxygen (DO) is a water quality indicator for the health of a surface water body. The levels of DO are closely related to the relative oxidation status of a water body and or oxygen being consumed during degradation of organic matter.

3.3.4 Electrical conductivity

Electrical conductivity measures the electrical current conducted in water due to the presence of dissolved ions such as sodium, potassium and chloride and is used as a measure of total dissolved salts/solids (TDS in mg/L) and as an indicator with respect to the efficiency of some water treatment processes.

3.4 Chemical Parameters of Water Quality

Chemical parameters include measures of substances such as manufactured chemicals, nutrients and metals.

3.4.1 Metals

Metals are found naturally in both surface water bodies and groundwater or may come from anthropogenic origins. Some are essential human nutrients; however, they may also pose an inherent health hazard when in high concentrations. No metals were identified as Compounds of Potential Concern - CoPC (from the measured analytes: arsenic, cadmium, chromium, copper, lead, nickel and zinc) in the HHRA prepared for Fiskville Training College. This does not preclude metals as being a cause of concern in the future or at other FTGs. Therefore, verification is required during design and commissioning of any water treatment system if/when installed at a FTG.

3.4.2 Industrial Chemicals

Two classes of organic compounds have previously been identified as CoPC in the HHRA conducted by Cardno Lane Piper. They are:

Perfluorinated compounds (PFC): a constituent present in some fire-fighting foam formulations, in particular Class B foams which are used to fight liquid fuel fires; andPetroleum hydrocarbons (PHC): used as a fuel source for providing flames during fire-fighting training.

Perfluorinated compounds

PFCs are key ingredient in some aqueous film forming foams (AFFF) used in fighting Class B fires (i.e. fires that involve flammable liquids). They are also known as fluorosurfactants. Perfluorooctane sulfonic acid (PFOS) and Perfluorooctane carboxylic acid (PFOA) are two PFCs that were in foams traditionally used by CFA at Fiskville until approximately 2007 (Joy, 2012). The use of these two PFCs has been restricted or banned in many countries. They

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continue to be detected in some water bodies and sediments at FTGs due to their persistence in the environment.

The precise makeup of fluorosurfactants currently used in foams supplied to CFA for training is not always fully disclosed by manufacturers, suppliers or in product Material Safety Data Sheets (MSDS). Four different foams are known to be or have been used at CFA Training Grounds, including:

Tridol 3/6 AR: Class B foam containing PFC. This foam contains a structurally similar PFC to PFOS, commonly known as a fluorotelomer (FTS), (such as 6:2 FtS);Tridol S3: Class B foam containing PFCs that are shorter and longer chain analogous (i.e. similar chemical structure) of PFOS and PFOA, possibly a mixture that includes but is not limited to: perfluorinatedhexyl sulphonate (PFHxS), perfluorinatedhexyl octanoate (PFHxA) and perfluorinatedheptyl sulphonate (PFHpS). Cardno Lane Piper understands that thesecompounds are currently used in portable fire extinguishers;Forexpan: Class A foams which contain standard surfactants that do not contain PFCs; andSolberg RF: Class B foam that is believed not to contain PFCs, and is reportedly used by the Metropolitan Fire Brigade, during training exercises at Fiskville.

The chemistry and toxicity of the majority of PFCs that are potentially used in Class B foam formulations are limited at this time, therefore WQC were derived for PFCs as three distinct classes. The specific details of this assessment are provided in the HHRA report (Cardno Lane Piper, 2014a). A surrogate was assigned to represent each class, namely:

PFAS: Perfluorinated alkyl sulfonic acids assessed using PFOS as a surrogate;PFAA: Perfluorinated alkyl carboxylic acids assessed using PFOA as a surrogate; andOPC: Other perfluorinated compounds assessed using 6:2 FTS as a surrogate.

Petroleum Hydrocarbons

Petroleum hydrocarbons (PHC) refer to a range of different products with quite varied chemical makeup of aliphatic, cyclic and aromatic hydrocarbons. PHC are sourced from crude oil that contains a mixture of several hundred chemical compounds made entirely from carbon and hydrogen atoms. The chemical constituents in PHC are quite variable depending on the source of the crude oil and refining practices. Different types of PHC used at FTGs include:unleaded petrol, liquid petroleum gas (LPG), kerosene and diesel fuel. PHC may be assessed using a methodology developed by the Total Petroleum Hydrocarbon Criteria Working Group (TPHCWG). They are separated into different total petroleum hydrocarbon fractions (TPH). The following TPH fractions were identified as CoPC in the HHRA prepared for CFA training personnel:

TPH >C10 – C16 (aromatic): Molecules with more than 10 and up to 16 carbon atoms in a molecule that may be straight, branched, cyclic and/or aromatic. They were assumed to bearomatic in the HHRA; andTPH >C16 – C34 (aromatic): Molecules with more than 16 and up to 34 carbon atoms in a molecule that may be straight, branched, cyclic and/or aromatic. They were assumed to be aromatic in the HHRA as a conservative approach.

3.5 Microbiological pathogens

Microbial pathogens in water quality can be harmful to health or may be nuisance organisms that can have an adverse impact on the aesthetics of a water source (i.e. taste, odour or appearance). Human health is the driver for the discussions in the following subsections as the

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criteria described are selected for water used in hot-fire training and not for drinking water. AQuantitative Microbial Risk Assessment (QMRA) was conducted for CFA training personnel exposed to water during fire-fighting training (Ecos, 2013). The information provided here on risks including any recommendations are based on those provided in the QMRA.

The following microbial pathogens may have an adverse health effects for CFA training personnel exposed to water used for fire fighter training at the CFA training grounds:

Endotoxins: biological toxins that may occur in water as a by-product of bacterial activity.Endotoxins consist of cellular debris which, if introduced into the bloodstream, may result in fever, asthma, and shock (Pepper, 2006);Algal toxins: biological toxins occurring as a result of blue-green algae dieback (i.e. cyanobacteria) due to excessive population blooms in water bodies. A bloom of blue-green algae in water may result in the production of toxins which are harmful to human and animal health; andMicrobial pathogens: include opportunistic bacterial species (e.g. Pseudomonas aeruginosa) or enteric pathogens (e.g. viruses, bacteria, protozoa and helminths). Opportunistic bacteria include common environmental bacteria that may potentially have impacts on human health whereas enteric pathogens typically arise from human and animal faecal waste that potentially result in gastroenteritis including various sequelae6.

3.5.1 Endotoxins and Algal Toxins

Algae and cyanobacteria are present in all natural surface waters. These microorganisms can become a nuisance when conditions are ideal and excessive growth occurs.

Risks posed by endotoxins and algal toxins were not quantified as there was insufficient monitoring data and/or a lack of published dose-response relationships. A qualitative assessment of risk for CFA training personnel exposed to water used in fire-fighting training identified that the “available evidence suggests the use of control measures to ensure a safe working environment is warranted” (Ecos, 2013). This finding was based on nutrient levels noted from surface water monitoring from the water used in training exercises that was stored in an open surface water body. The surface waters were considered enriched, as far as nutrient levels are concerned, and indicated that algal blooms, including potentially toxic species, were at risk of occurring (Ecos, 2013).

Algal blooms can cause major problems for the natural ecosystems and may interrupt water supply at the FTG, if not considered appropriately when reliant on surface water as a source or storage of water prior to treatment. Species of cyanobacteria in Australia which are commonly found to be toxic are Microcystis spp. and Anabaena spp. Water with sufficient concentrations of nutrients, in particular nitrogen and phosphorous, may exhibit algal blooms if other conditions are conducive such as temperature, light, pH; the availability of nutrients; lack of competition from other micro-organisms and the absence of predators.

Monitoring for algal and cyanobacteria levels are by means of cell count (e.g. using total biovolume) and are routinely used in monitoring programs during warmer months. Total biovolume is an indicative parameter. Where exceeded further investigation is required that includes analyses for actual species (e.g. microcystis).

6 Medical complications arising from the infection that affect a subset of those infected.

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3.5.2 Opportunistic and Enteric Microbial Pathogens

Microbial pathogens that have the potential to impact health of CFA training personnel exposed to water during fire-fighting training are separated into two categories:

Enteric pathogens that are excreted in faeces from the body of a host. Hosts may include birds, mammals and humans; andOpportunistic pathogens that are ubiquitous in the environment and grow in water supplies.

Enteric Pathogens

Enteric pathogens can be transmitted in contaminated drinking water and include viruses, bacteria, protozoa and helminths. The number of known water borne pathogens capable of impacting human health is large and assessing exposure to each is impractical. Instead, specific reference enteric pathogens were selected in the QMRA consistent with NHMRC (2011) and WHO (2011) water quality guidelines.

Monitoring for these pathogens is not routine and an indicator enteric pathogen, E. coli, is typically used to identify whether water is potentially contaminated with enteric pathogens. Ashort summary of enteric pathogens is provided below and includes the specific reference enteric pathogens selected in the QMRA for which WQC have been derived:

Virus (Reference pathogen: Rotavirus): Viruses of most importance in water monitoringare those found in the human intestines, that multiply and are excreted in large numbers. Testing for viruses is required where exposure to water contaminated with sewage is identified. They are amongst the smallest of infectious agents and include adenovirus, enterovirus, hepatitis viruses and rotavirus. Monitoring is not generally conducted for rotavirus due to the costs involved with the analysis; hence testing is used for investigative purposes only if conducted. Note that the surface water bodies, at the CFA training grounds, are not known to be exposed to effluent from sewage discharges.Bacterial (Reference pathogen: Campylobacter spp): Bacteria that are resistant to decay or highly infectious are those most likely to be transmitted in water. Enteric bacteria pathogens are sourced from domestic animals, wildlife and humans with Campylobacter identified as the species of interest. Bacterial pathogens such as Salmonella spp, E. coliand Campylobacter jejuni decay at different rates once they are released into surfacewater and gradually lose the ability to create infections (NHMRC 2011). Due to analysis costs associated with the reference pathogen, the bacteria E. coli is typically used as an indicator species for routine monitoring. Testing of Campylobacter is typically conductedfor investigative purposes only.Protozoa and helminths (Reference pathogen: Cryptosporidium): The majority of protozoa are organisms found in freshwater that feed on microbial pathogens and do not have an impact on human health. Protozoa are typically used as a reference for helminths. Enteric protozoa (e.g. Cryptosporidium, Giardia and Entamoeba histlyica) and a few free-living protozoa (Naegleria, Acanthamoeba spp.) may cause adverse health effects. Enteric protozoa occur in water as dormant cysts and can lead to enteritis (i.e. inflammation of the small intestines) while free-living protozoa may result in infections. Enteric protozoa are sourced from domestic animals and humans with the species of interest identified as Cryptosporidium hominis and C. parvum.

Opportunistic Pathogens

The opportunistic bacterial pathogen of most concern is Pseudomonas aeruginosa due to its widespread occurrence in nature and adverse health effects associated with exposure to skin, and mucous membranes of eye, mouth and throat. People with impaired immune systems or

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general defence mechanisms are most at risk from opportunistic pathogens. In the absence of a published dose-response relationship, detailed quantification of the risks posed by P. aeruginosa was not possible for CFA training personnel (Ecos, 2013). Risks from accidental ingestion of water for CFA training personnel are expected to be far greater for the enteric pathogens (e.g. Cryptosporidium, Campylobacter and Rotavirus). Controls implemented to manage the enteric pathogens (e.g. UV light and chlorination) are anticipated to be sufficient in managing risks associated with opportunistic bacteria such as P. aeruginosa.

Pseudomonas is a useful monitoring indicator of “the general cleanliness of water distribution systems” (NHMRC 2011). Its presence may indicate the deterioration of water quality and the presence of other bacterial organisms.

3.6 Water Pollution

Water pollution occurs as a result of diffuse sources, or point sources reaching a water body.

Diffuse sources refer to contamination that originates from multiple or broad sources including run-off from agricultural and urban areas. Agricultural run-off refers to water from rainfall that moves over the ground, washing away contaminants as it moves and carrying thecontaminants into environmental water. In contrast, urban run-off is storm water that is washed off parking lots, hard stand areas and roads. Contamination from these diffuse sources (or run-off) includes microbial pathogens, chemicals (e.g. nutrients and metals) and physical characteristics (e.g. turbidity).

Point source pollution refers to contaminants in water sourced from an identifiable source, such as a pipe (e.g. sewer effluent, stormwater) or from an industrial process (e.g. fire-fighting training effluent run-off). Industrial processes may result in an increased loading of chemicals in environmental waters. This is particularly the case where the treatment of discharged water is insufficient. Concentration of chemicals discharged into a receiving surface water body at the point of release can be relatively high compared with background concentrations. Sewerage treatment systems can result in a point source release of nutrients and microbial pathogens (i.e. bacteria, viruses, algal toxins) in to environmental waters.

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4 WATER USE IN CFA TRAINING

4.1 Water Source Categories

The various sources of water that have been used at the CFA Training Grounds are shown in Figure 4-1. Most FTG use a combination of sources to supply sufficient water to meet training requirements. The historical sources of water used in training at the CFA Training Grounds are briefly described in Appendix A. For context, a discussion of water sources used in operational duties is also provided.

Figure 4-1: Sources of Water Potentially Used at CFA Training Grounds

The amount of treatment required for a water to be suitable for fire-fighting training is dependent on the source of the water. Table 4-1 presents a summary of the various categories of water potentially used by CFA. Category 1 includes pre-treated supply from awater utility such as potable water or reclaimed Class A water. In most circumstances no further treatment is required for pre-treated water if it is not stored for extended periods.Storage of potable water for extended periods will result in the loss of residual chlorine (below 0.5 mg/L) and potentially lead to a build-up of pathogen levels.

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Table 4-1: Water Source Categories

Water Cat.

Description Potential water source Comments on catchment area

1 Pre-treated water

Potable water and/or reclaimed Class A water sourced from a “Water Utility”. Other waters (e.g. groundwater and potentially rainwater) may be included if they are known to be pathogen free.

Potable water is typically taken from ‘protected waters’ (i.e. water category 2) and treated prior to supply. Monitoring of residual chlorine levels is required ifthese waters are stored prior to use.

2 Protected water

Water from various catchment areas including rainwater, environmental waters (e.g. surface waters), groundwater and stormwater. It may include treated process water.

The catchment area used to collect water should be protected and have no agricultural or pastoral production (i.e. sheep and cattle). Further, there is nocontribution to pathogen loads from upstream sewerage or grey-water systems.Pathogen loads are assumed to be from natural environmental sources such as from birds and other wildlife that frequent surface water bodies, roof of buildings and paved areas where fire-fighter training occurs.

3Partially

Protected Water

As above (Water Type 2) except that water from anunprotected water body (see Type 4 below) may occasionally be used as a top-up of storage tanks (e.g. once per year).

4aUnprotected

water

Environmental Water collected from unprotected catchment areas and reclaimed Class B water. It may include process waters.

The catchment area is unprotected therefore pathogen loads are anticipated from birds and mammals that frequent surface water body and PAD areas, andlivestock that graze in the catchment area.

4bAs above (Water Type 4a) with additional pathogen loads from upstream grey water systems.

5 Other

Grey water, sewage and other water with suspected high enteric pathogen loads. It may include process waters

Treat as per processes used to deliver reclaimed Class A water.

4.2 Sources of Water at CFA Training Grounds

The sources of water discussed in this section are based on historical information. Note thatduring the time of the site inspections conducted by Cardno Lane Piper, with the exception of the Longerenong and West Sale FTG, all of the other FTG were operating on potable water supplies as an interim measure to manage water quality concerns.

A summary of water sources used at CFA Training Grounds is provided in Table 4-2. All types of water previously described (Section 3.1) have been used as sources of water at FTG except for on-site treated sewage. Triple interceptors traps (TIT) have been installed at all locations to treat water that has been discharged from the Flammable Liquid PAD areas to remove sediments and separate phase PHC present in water (Note that a TIT does not provide any treatment of dissolved phase PHC). On-site water storages are noted (i.e. dams and/or tanks) as well as the potential for water to be discharged off-site.

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Table 4-2: Historical Water Sources CFA FTGs

Water source &Systems

CFA Field Training Ground

Fiskville Bangholme West Sale Huntly Wangaratta Penshurst Longerenong

Potable Water

Rainwater

Reclaimed Water 1 2

Process Water3

EnvironmentalWaters

Stormwater

Water Recirculated

TIT

On-site Dam

AST or UST on-site

Water dischargeoff-siteNotes:Symbols: - yes (i.e. currently in use, present or has been used), - no1. Class A reclaimed water, has been imported for use on limited occasions during drought at Fiskville2. Bangholme receives up to 10% of its sourced water is Class A reclaimed water from the neighbouring sewage treatment

facility.3. Process water includes recirculated water, i.e. water that has been used in fire-fighting and captured for re-use on site.

(Since June 2012 all RTG except Longerenong are using potable water as in interim measure)

4.3 Water Sources for Fire-Fighting Operations

Water sources used by station officers and volunteers (fire-fighters) during operational duties are diverse and opportunistic. This is because fire-fighters must have quick access to a watersource, and in most cases there is no readily available information with respect to the quality of a surface water source.

Operational duties conducted in an area with a reticulated potable water supply would typically use this water to fight fires. Where potable water use is restricted, insufficient to meet operational needs or unavailable, the fire-fighters may draw water from alternate sources. Water service providers make provisions for supply of water specifically for fire fighting (i.e. fire hydrants).

The first consideration for a source of water is whether a dedicated water source, separate from a reticulated water supply, is available for fire fighting. This is a more likely scenario in rural areas and/or larger industrial complexes. The dedicated water supply is typically stored in on-site tanks. Alternatively, fire-fighters are permitted by law to obtain water, during emergency events for fire suppression/operations, from domestic water tanks, surface water bodies including streams, creeks and private dams. However, sourcing environmental waters is not considered reliable as it may be seasonally unavailable (particularly in summer) and has access hazards.

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Another source of water that has recently become an option for fighting fires during operational duties is reclaimed water (generally Class A). It has become more widely available in outer urban residential areas, and advice has been obtained by fire agencies and unions about the safety of this source. A comparison of the quality of recycled water with other water sources has been reported (WSA 2004). The WSA report identified that reclaimed water can be “expected to be as safe as, or safer than, many alternative water sources used for fire fighting, such as urban streams and private swimming pools” (WSA, 2004). Note that the CFA and MFB have agreed to the use of reclaimed water (i.e. Class A) for both training and operational duties as the need arises (CFA and MFB Media Release, March 20087).

This WQC report does not address water quality criteria for fire-fighting operation procedures.It is only mentioned in this instance for clarification with regards to potential access to water sources during operation activity.

7 Media Release by CFA and MFB titled “MFB and CFA announce joint recycled water agreement” published in March 2008. Document retrieved online from www.mfb.vic.gov.au/media/docs/ (Web access on 23 April 2013).

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5 PROPOSED WATER QUALITY CRITERIAWQC are an essential element of any water quality management plan which incorporates awater monitoring and testing program. They may be used to monitor the performance of a Water Treatment Plant (WTP) or as indicators of potential impact to health or environment. Therefore, WQC are organised in this report by organising criteria into three groups:

Treatment Management Levels: These criteria most relevant to monitoring the performance of a Water Treatment Plant;Risk-based OHS water quality criteria: These are derived for:

Organic chemicals (PFC and TPH fractions): Forward calculated risk based criteriaderived to protect of health of CFA Training PersonnelInorganic chemicals (metals): Adjusting drinking water guidelines to account for exposure during hot-fire trainingMicrobial pathogens: As a set of log reduction values (LRV) used as a specification for a WTP.

Environmental discharge criteria: Used for protection of the ecology of the surface water bodies to which water is discharged.

These criteria are discussed in order below followed by a summary of the criteria selected for an example fire training ground.

5.1 Treatment Management Levels

These criteria are a set of management criteria that are required for the management of a WTP. They are referred to in WQMP as Water Quality Trigger 1 (WQT-1) and are values based on requirements of water quality objectives for industrial use (open systems with worker exposure potential) from the following documents:

Use of Reclaimed Water (EPA Victoria, 2003) for Class A reclaimed water; andDisinfection of Treated Wastewater (EPA Victoria, 2002)

It is important to note that these management levels are not indicative of human health effects occurring should they be exceeded. Instead they should be used to indicate whether the WTPis operating to specification and whether unscheduled maintenance should be undertaken.Other more indicative testing may be performed for some of these criteria (e.g. E. coli) should they be exceeded.

A summary of parameters provided in the guidelines listed are provided below in Table 5-1.The list of parameters and chemicals in this table is not exhaustive and other criteria may be required based on an identified need.

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Table 5-1: Treatment Management Levels for use as Water Quality Triggers 1 (WQT-1)

Parameter


Treatment Management

Levels

Monitoring Regularity Basis of Criteria Source

pH 6 to 9 (90%)

These values can all be monitored on a continuous basis. They should also be included in analytical laboratory schedules to confirm continuous results.

Reduce corrosion to pipes and fittings.

EPA Vic 2002 and

2003

Chlorine levels 1 mg/L (min)

Reduces potential hazards associated microbial pathogens in water.

Turbidity2 NTU (median)

5 NTU (max)

May affect UV treatment for microbial pathogens(consider in conjunction with residual chlorine levels).

Suspended Solids 5 mg/L Specified to prevent

damage to infrastructure.

Escherichia coli(E. Coli)

10 org/100mL Measured on a regular basis.

A mechanism for monitoring process performance related to disinfection.

Biological Oxygen Demand(BOD)

10 mg/L

Measured on a regular basis. Continuous monitoring is available using correlated results.

An indicator of degradation of water quality that may be linked to ecological health.

5.2 Risk Based OHS Water Quality Criteria

Risk based OHS criteria are provided here for the protection of worker health in the event that contaminants are found in the water used for training. This section provides a set of OHS risk based criteria which may be used in a WQMP, where a need has been identified, as Water Quality Trigger-2 (WQT-2) for a range of potential contaminants. These contaminants may include chemicals (inorganic or organic) and microbial pathogens. Regular monitoring for microbial pathogens is common in WQMP where there is potential for human exposure to untreated waters. Chemicals are not routinely included in a WQMP unless a need has been identified according to DHS (2008):

“Chemicals are not generally envisaged to be a human health risk where wastewater is derived from largely domestic catchments, and recycled water is not used for drinking.”

However this does not apply where:

“Chemical inputs from the catchment are considered to be significant”.

Water supplies at some CFA Training Grounds include the use of process water, i.e. water captured from PAD areas during hot-fire training and reused. The use of this process water

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has the potential to introduce chemicals and microbial pathogens into water collected for reuse. The source of the chemicals in process water at training grounds includes (but is not limited to) foaming agents, liquid fuels, combustion products and metals.

The methodology used to derive OHS risk based criteria (see Appendix B) can be applied to other compounds that may potentially be identified in water used in hot-fire training from future monitoring events.

Note that the risk based OHS criteria provided here are only used where a hazard or risk associated with the presence of these compounds in water is identified.

5.2.1 Summary of Risks for CFA Training Personnel during Hot-Fire Training

The OHS risk-based criteria are based on a site-specific health risk assessment conducted for CFA Training Personnel (including PAD Instructors and Trainee recruits) at CFA Fiskville Training Ground (Cardno Lane Piper 2014a). This risk assessment was peer reviewed by Dr Roger Drew of ToxConsult.

The risks to the CFA Training Personnel were considered negligible for exposure to chemicals (inorganic and organic), however there was a risk identified for exposure to microbial pathogens requiring management. A set of forward calculating risk based criteria have been derived here for chemicals using the individuals with the highest level of exposure (Leading fire-fighters). This cannot be done for microbial pathogens. Instead, log reduction values have been derived for all water categories (except for pre-treated waters such as potable water). The LRV are design criteria for specification of a WTP (e.g. water storage and chlorine contact time) and are not intended as criteria for a Water Quality Management Plan (WQMP).

The exposures for CFA Training Personnel were assessed using ‘worst case’ and ‘best justified’ parameter sets. The criteria provided in this section are based on the ‘best justified’parameter set as the ‘worst case’ exposure is unlikely to ever occur.

5.2.2 OHS Risk Based Targets for Inorganic Chemicals

Hypothetical OHS risk based targets have been derived for a select number of inorganiccompounds (metals), see Table 5-2 below. These targets are based on drinking water guidelines (DWG, NHMRC 2011) and take in to account the exposure to water during hot-fire training. Derivation of these OHS risk based targets is provided in Appendix B. As these targets greatly exceed the concentrations for inorganics in waters observed (tested) at training grounds, OHS risk based targets do not need to be adopted for metals. This will need to be verified during design and commissioning studies for any WTP proposed at a training ground.

Table 5-2 Hypothetical Health Based Targets – metals (mg/L)

Compound Drinking Water Guideline (DWG)

OHS Risk Based Targets 1

Arsenic 0.01 3.5Cadmium 0.002 1Chromium (as VI) 0.050 25Lead 0.01 5Nickel 0.02 10Notes: DWG = drinking water guideline (NHMRC 2011)1. See Appendix B for derivation of the OHS Risk Based Targets

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5.2.3 Health Based Targets for Organic Chemicals

WQC for two classes of organic chemicals are listed in Table 5-3. The chemical classes identified in the HHRA were perfluorinated compounds (PFC) and petroleum hydrocarbons (PHC). These chemicals are associated with water used in fire-fighter training activities andhave the potential to contaminate water that is reused for training. WQC have been derived for these compounds based on the risks assessed in the HHRA prepared by Cardno Lane Piper(2014a) and their derivation is provided in Appendix B. The targets presented in Table 5-3 are to provide confidence to CFA training personnel and management with regards to the OHS Risk Based Targets. For example the PFOS concentrations in the water in disused Dam 2 at Fiskville in 2012 were about two hundred times less than the health based target shown in Table 5-3. Further, the OHS Risk Based Targets for TPH fractions exceed solubility limits for these compounds therefore rather than rely on a set of criteria for TPH fractions it is considered that practical measures should be undertaken to remove residual petroleum hydrocarbon fractions from water used in fire-fighter training.

Table 5-3: OHS Risk Based Targets derived for Compounds of Potential Concern

Compounds of Potential Concern Acronym OHS Risk Based Target (mg/L)

Perfluoroalkyl Sulfonic Acid (including PFOS) PFAS 56

Perfluoroalkyl Carboxylic Acid (including PFOA) PFAA 57

Other perfluorinated compounds (including 6:2 FTS) OPC 171

Volatile petroleum hydrocarbons (e.g. benzene, toluene, xylene and ethyl benzene) - Not derived 1.

Total Petroleum Hydrocarbon >C10 – C16 TPH >C10 – C16 4,700

Total Petroleum Hydrocarbon >C16 – C34 TPH >C16 - C34 2,800Note:PFAS includes perfluorooctyl sulfonic acid (PFOS), PFAA includes Perfluorooctane carboxylic acid (PFOA), OPC includes 6:2 fluorotelomer and other perfluorinated chemicals that do not have the sulfonic acid (PFAS) or carboxylic acid (PFAA) functional groups. OPC = Other perfluorinated compounds1. These compounds been not been identified as CoPC in water at CFA Fiskville Training Ground (Cardno Lane Piper

2014c).

5.2.4 Health Based Targets for Microbiological Pathogens

A set of WQC for cyanobacteria and select microbial pathogens have been tabulated in Table 5-4 below. The OHS risk based targets for total Microcystin were calculated using an approach similar to that used for drinking water guidelines (see Appendix B). WQC for the other algal toxins were adopted from guidelines for primary contact recreation.

Table 5-4: Health Based Target for microorganisms

Microbial Pathogen Units

OHS Risk

Based Target

Comment Source

Total Microcystin(microcytin-LR TEQ)

μg/L 47Based on drinking water guideline (NHMRC (2011). Adjusted based on exposure during hot-fire

Appendix B

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Microbial Pathogen Units

OHS Risk

Based Target

Comment Source

training

Microcystis aeruginosa Cells/mL 50,000Guideline for primary contact recreation. Exposure during hot-fire training assumed to be lower than during primary contact recreation.

DSE (2010)Total combined biovolume (Toxic) mm3/L 4

Total combined biovolume (Known) mm3/L 10

Escherichia coli (bacterial) Org./100ml <150 NHMRC (2008)

Pseudomonas aeruginosa Org./100ml - No guidelines derived. -

The detection of E. coli in water only indicates the possible presence of faecal contamination including microbial pathogens that may result in health risk. . Usable criteria are not currently available for the pathogens present therefore WTS pathogen removal performance targets have been derived instead. The type and level of treatment applied to water is dependent on the water category as shown in Table 4-1. A treatment method is then selected for the WTPthat meets the performance specified targets to ensure water is “safe” in terms of microbial pathogen risk, for use in hot-fire training.

Various treatment options are available for treating microbial pathogens in water (e.g. UV light, chlorination, among others). The effectiveness of the treatment varies depending on the pathogen and on the water treatment process. Instead of describing specific details for the treatment process, a set of Log Reduction8 Values (LRV) has been developed that the specification of a Water Treatment System is required to meet. The LRV are derived in this report for:

Each enteric pathogen class (virus, bacteria and protozoa including helminths); andEach water category

The target LRV derived is listed below in Table 5-5. The LRV were estimated based on “best justified” and “worst-case” exposure assumptions from a Quantitative Microbial Risk Assessment (QMRA) that assessed risks for CFA Training Personnel exposed to reused water during hot-fire training. Due to the uncertainty in the QMRA related to estimation of pathogen loads in water, the worst case assumptions are selected as the ideal level of protection for hot-fire training.

Table 5-5: Target log reductions required for enteric pathogens in water

Water Category Water Description

Pathogen

Rotavirus Campylo1 CryptoLog reductions (LRV) – best justified assumptions

1 Pretreated water Not required, pre-treated2

2 Protected water 0 0.02 0

3 Partially Protected water 0 0.1 0

8 Treatment for microbial pathogens is often discussed in terms of log reductions, where one log reduction is equivalent to a 10 fold reduction in pathogen concentration.

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Water C t

Water Description Pathogen

4a Unprotected water Type A 0 0.5 0

4b Unprotected Water Type B 0.4 1.1 0

5 Other Treat as for sewage

Log reductions (LRV) – worst assumptions

1 Pretreated water Not required, pre-treated2

2 Protected water 0 1.9 0.6

3 Partially Protected water 0.3 1.9 0.6

4a Unprotected water Type A 0 2.9 1.6

4b Unprotected Water Type B 2.3 2.9 1.7

5 Other Treat as for sewageNotes:1. Campylo = campylobacter, crypto = cryptosporidium, units are Org/L = organisms per litre,2. Chlorine level to be maintained above 0.5 mg/L. for stored water supply.

5.3 Environmental Discharge Criteria

Water used on the FTGs may need to be discharged periodically from the site to local surface waters for operational reasons. The quality of such discharges must comply with the relevant environmental water quality objectives under SEPP Waters of Victoria.

Environmental discharge criteria have been collated in Table 5-6 for use as WQT-2 in a WQMP for the protection of the ecological receptors in receiving waters. These criteria are sourced from the following documents:

SEPP Waters of Victoria Gazette (Government of Victoria 2003); Australian and New Zealand Guidelines for Fresh and Marine Water Quality, Volume 1(ANZECC 2000a); andPeer-reviewed documents in the public domain literature where referenced.

There is a range of protection levels for other contaminants in ANZECC guidelines (ANZECC 2000a) that have not been provided here. Contaminants, not listed below in Table 5-6, may be identified as being a cause for concern in future work (e.g. during design and commissioning studies for a new WTP) and suitable criteria may be adopted from Table 3.4.1 of the ANZECC guidelines (ANZECC 2000a). Peer reviewed documents are another source of ecological guidelines suitable for use as WQT-2 environmental discharge levels. A literature review was conducted by Cardno Lane Piper to identify WQC relevant to beneficial uses downstream of the Site, refer to Appendix C.

This set of criteria should also be used in any specification for a water quality monitoring program for offsite discharge, if required.

A set of ecological criteria were not identified for the TPH fractions. This is most likely because they most likely have low toxicity to ecological receptors and consequently environmental agencies have not set specific criteria for them. As stated in Section 5.2.3 practical measures should be undertaken to remove residual petroleum hydrocarbon fractions from water used in fire-fighter training.

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Table 5-6: Environmental Discharge WQC

Parameter WQ Trigger 2 (WQT-2) Comment Source


Chlorine levels 0.013 mg/L80% level of protection for freshwater species, (see Table 3.4.1, ANZECC 2000) ANZECC

(2000a)Turbidity 25 NTU Based on upper value in range for

upland rivers of South-east Australia

pH 6.5 to 8.3 Environmental quality objective for rivers and streams uplands of the Moorabool river (see Table A1, GoV 2003)

GoV(2003)Electrical Conductivity 500 μS/cm

Dissolved oxygen >6 mg/L

Based on 80-90% saturation. This value is consistent with the environmental quality objective for rivers and streams uplands of the Moorabool river (see Table A1, GoV 2003) and explained in section 3.3.3.3 of ANZECC (2000a).

ANZECC (2000a)

Periodic Monitoring ParametersBOD 15 mg/L Physico-chemical stressor guidelines

for the protection of aquaculture species. (See Table 4.4.2, ANZECC 2000a)

ANZECC (2000a)COD 40 mg/L

Total Phosphorous 0.025 mg/L Environmental quality objective for rivers and streams uplands of the Moorabool river (see Table A1, GoV 2003)

GoV (2003)Total Nitrogen 0.6 mg/L

Surfactants 0.0001 mg/L Toxicant guidelines for the protection of aquaculture species. (See Table 4.4.3, ANZECC 2000a)

ANZECC (2000a)Oil and grease 0.3 mg/L

Perfluorinated Compounds (PFC)10.0051 mg/L

95% level of protection for freshwater species based on Criteria Continuous Concentration (CCC), see section 3.4.1 of Giesy (2009).

Giesy (2009)

4.7x10-5mg/L Protection of avian predators (e.g. eagles)

Benzene 950 μg/L 95% level of protection for freshwater species. (See Table 3.4.1, ANZECC 2000a)

ANZECC (2000a)o-Xylene 350 μg/L

p-xylene 200 μg/L

Toluene and ethyl benzeneNVI2

No suitable values identified in the literature for these fractions. n/a

TPH >C10 – C16 and TPH >C16 - C34

Arsenic (III) 0.024 mg/L 95% level of protection for freshwater species.(See Table 3.4.1, ANZECC 2000a) ANZECC

(2000a)Arsenic (V) 0.013 mg/L


Copper 0.0014 mg/L

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Parameter WQ Trigger 2 (WQT-2) Comment Source

Lead 0.0034 mg/L

Nickel 0.011 mg/L

Zinc 0.008 mg/LNote: GoV = Government of Victoria., NVI = No Value Identified, n/a – applicable1. Based on PFOS.2. All practical efforts should be undertaken to remove residual TPH fractions from water used in fire-fighter training.

5.4 Example Set of Criteria for a WQMP

An example table of WQC for use in a WQMP is provided below in Table 5-7. This table was developed for CFA Fiskville Training College assuming that:

Sources of water used include potable water and process water from the PAD areas (protected water, type 2).Water treatment is required for Microbial pathogens. The WTP needs to meet LRV for protected water (water category type 2). Treatment management levels are required to be monitored for ensuring optimum performance of the WTP. Where permitted monitoring is to be continuous otherwise performed on a quarterly basis (following commissioning).Water may be discharged periodically to the environment therefore environmental discharge targets are required. Water Quality Triggers (WQT-2 Environmental Discharge Targets) are required for PFC and a range of physical parameters (pH, chlorine etc.). Metals may also require monitoring.Water is reused in hot-fire training however OHS risk based targets are not currently required (NCR) for PFC or TPH fractions at this FTG. This is because levels of these contaminants in water measured during recent investigations are well below the criteria derived and for TPH are approaching or exceeding solubility limits which is unlikely to ever occur in the water systems at FTG.

These criteria could also be suitable for implementation in WQMPs to be developed separately for each FTG, depending on the site-specific data on water quality, water treatment systems available and the mode of water use.

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Table 5-7: An example set of water quality parameters and relevant Criteria

ParameterWQ Trigger 1 (WQT-1)

Treatment Management Levels


OHS TargetEnvironmental

Discharge Target


pH 6 to 9 (90%) 5 to 10 6.5 to 8.3

Chlorine levels 1 mg/L (min) 0.5 mg/L (min) 0.013 mg/L

Turbidity 2 NTU1 - 25 NTU

Suspended Solids 5 mg/L - -

Electrical Conductivity - - 500 S/cm

Dissolved oxygen - - >6 mg/L

Periodic Monitoring Parameters

Escherichia coli (E. Coli) 10 org/100mL 150 org/100mL -

BOD 10 mg/L - 15 mg/L

COD - - 40 mg/L

Total Phosphorous - - 0.025 mg/L

Total Nitrogen - 0.6 mg/L

Surfactants - - 0.0001 mg/L

Oil and grease - - 0.3 mg/L

Perfluorinated Compounds (PFC)2

NCR4

0.0051 mg/L

Total Petroleum Hydrocarbons (TPH) NVI3

Arsenic (III) 0.024 mg/L

Arsenic (V) 0.013 mg/L


Copper 0.0014 mg/L

Lead 0.0034 mg/L

Nickel 0.011 mg/LNote: NCR – WQC Not currently required, NVI = No value identified1. 2 NTU is a 95% percentile value. A maximum value is 5 NTU.2. Based on PFOS3. All practical efforts should be undertaken to remove residual TPH fractions from water used in fire-fighter training 4. Based on assessment of risks to human health for occupational exposures during fire-fighter training, refer to Appendix B.

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6 CONCLUSIONThis report has been prepared for the CFA to provide Water Quality Criteria for non-potable, ‘fit-for-purpose’ water for fire-fighting training. The Water Quality Criteria provided in this report are considered to be conservative and provides safe water for use in fire-fighting training. The WQC proposed for use by CFA are selected and/or derived for hot-fire training are:

Treatment Management Levels: Criteria used to monitor the performance of a Water 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 based on an Human Health Risk Assessment prepared for CFA Fiskville Training College (Cardno Lane Piper, 2014a).Environmental Discharge Criteria: These criteria are used for 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 Waters of Victoria (GoV 2003).

A proposed set of WQC for fire-fighting training presented in Table 5-7 which are suitable for use at Fiskville FTC may be considered as a basis for similar criteria at other FTG. These should be reviewed for relevance at each FTG given the differences in water sources, treatments and modes of use.

A WQMP has been developed for Fiskville FTC using the WQC proposed here and is presented in a separate document.

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7 REFERENCESLegislation and Guidelines1. Environment Protection Act, 1970 (Act No.8056/1970), Victoria.2. Government of Victoria (1997) State Environment Protection Policy (Groundwaters of

Victoria). Victorian Government Gazette, S160, 17 December 1997.3. Government of Victoria (2002). State Environmental Protection Policy (Prevention and

Management of Contamination of Land). Victorian Government Gazette, S95, 4 June 2002.

4. Government of Victoria (2003) State Environment Protection Policy (Waters of Victoria).Victorian Government Gazette, S107, 4 June 2003.

5. Water Act, 1989. (Act No. 80/1989), Victoria.

General References6. ANZECC (1992) Australian Water Quality Guidelines for Fresh and Marine Waters.

National Water Quality Management Strategy. Australian & New Zealand Environment & Conservation Council.

7. ANZECC (1992) Australian and New Zealand Guidelines for the Assessment & Management of Contaminated Sites. January 1992. Australian & New Zealand Environment & Conservation Council / National Health and Medical Research Council

8. ANZECC (1994). Guidelines for sewerage systems - acceptance of trade waste (industrial waste), Document 12. National Water Quality Management Strategy. Australian & New Zealand Environment & Conservation Council and Agriculture & Resource Management Council of Australia and New Zealand.

9. ANZECC (1995). Guidelines for groundwater protection, Document 8. National Water Quality Management Strategy. Australian & New Zealand Environment & Conservation Council and Agriculture & Resource Management Council of Australia and New Zealand.

10. ANZECC (1997). Guidelines for sewerage systems - effluent management, Document 11.National Water Quality Management Strategy. Australian & New Zealand Environment & Conservation Council and Agriculture & Resource Management Council of Australia and New Zealand.

11. ANZECC (2000a) Australian and New Zealand Guidelines for Fresh and Marine Water Quality. National Water Quality Management Strategy. Australian & New Zealand Environment & Conservation Council and Agriculture & Resource Management Council of Australia and New Zealand.

12. ANZECC (2000b). Australian guidelines for water quality monitoring and reporting –Summary, Document 7A. National Water Quality Management Strategy. Australian & New Zealand Environment & Conservation Council and Agriculture & Resource Management Council of Australia and New Zealand.

13. ANZECC (2000c). Rural land uses and water quality - a community resource document, Document 9. National Water Quality Management Strategy. Australian & New Zealand Environment & Conservation Council and Agriculture & Resource Management Council of Australia and New Zealand.

14. ANZECC (2000d). Guidelines for urban stormwater management, Document 10. National Water Quality Management Strategy. Australian & New Zealand Environment & Conservation Council and Agriculture & Resource Management Council of Australia and New Zealand.

15. ANZECC (2000e). Guidelines for sewerage systems - use of reclaimed water, Document 14. National Water Quality Management Strategy. Australian & New Zealand

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Environment & Conservation Council and Agriculture & Resource Management Council of Australia and New Zealand.

16. ANZECC (2004a). Guidelines for sewerage systems - sludge (biosolids) management,Document 14. Australian & New Zealand Environment & Conservation Council and Agriculture & Resource Management Council of Australia and New Zealand

17. ANZECC (2004b). Guidelines for sewerage systems - sewerage system overflows,Document 15. Australian & New Zealand Environment & Conservation Council and Agriculture & Resource Management Council of Australia and New Zealand

18. CRC (2004). Pathogen Movement and Survival in catchments, groundwaters andRaw Water Storages. The Cooperative Research Centre for Water Quality and Treatment, 2004.

19. DHS (2007). Rainwater Use in Urban Communities Guidelines for Non–drinking Applications in Multi-residential, Commercial and Community Facilities.Department of Health Services, Victorian Government.

20. DPIWE (2002). Environmental Guidelines for the Use of Recycled Water in Tasmania. December 2002. Department of Primary Industry, Water and Environment, Tasmania.

21. DSE (2010). Blue-Green Algae Circular 2010-11. The State of Victoria Department of Sustainability and Environment, September 2010

22. DWE (2008). Interim NSW Guidelines for Management of Private Recycled Water Schemes. Department of Water and Energy, NSW Government.

23. EA (1999). ACT Wastewater Reuse for Irrigation. Environment Protection Policy. July 1999. Environment ACT, Australian Capital Territory.

24. Ecos (2013). Quantitative Microbial Risk Assessment (QMRA) for Occupational Exposure to Recycled Water during Fire fighter Training. Ecos Environmental Consulting Pty Ltd, February 2013.

25. EPA (2000). A Guide to the Sampling and Analysis of Waters, Wastewaters, Soils and Wastes. Publication 441, 7th edition, March 2000, Environment Protection Authority, Victoria.

26. EPA (2000). Groundwater Sampling Guidelines. Publication 669, April 2000, Environment Protection Authority, Victoria.

27. EPA Victoria (2002). Guidelines for Environmental Management. Disinfection of Treated Wastewater. Publication 730, September 2002, Environment Protection Authority, Victoria.

28. EPA Victoria (2003). Guidelines for Environmental Management. Use of Reclaimed Water. Publication 464.2, June 2003, Environment Protection Authority, Victoria.

29. EPA (2009). Soil Hazard Categorisation and Management. Publication IWRG621, June 2009, Environment Protection Authority, Victoria.

30. EPHC (2009) Australian Guidelines for Water Recycling, Storm Water Quality Management Strategy. Document No. 23. National Resource Management Ministerial Council, Environment Protection and Heritage Council and National Health and Medical Research Council. July 2009.

31. HC (2012). Guidelines for Canadian Recreational Water Quality. Third Edition. Health Canada.

32. NEPC (National Environment Protection Council) (1999) National Environment Protection (Assessment of Site Contamination) Measure, December 1999.

33. NHMRC (2006). Australian guidelines for water recycling: Managing health and environmental risks (Phase 1). National Health and Medical Research Council, Australian Government.

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34. NHMRC (2008a). Australian guidelines for water recycling: Managing health and environmental risks (Phase 2) - Augmentation of drinking water supplies. National Health and Medical Research Council, Australian Government.

35. NHMRC (2008b). Guidelines for Managing Risks in Recreational Water. National Health and Medical Research Council, Australian Government.

36. NHMRC (2009a). Australian guidelines for water recycling: Managing health and environmental risks - Stormwater harvesting and reuse. National Health and Medical Research Council, Australian Government.

37. NHMRC (2009b). Australian guidelines for water recycling: Managing health and environmental risks - Managed aquifer recharge. National Health and Medical Research Council, Australian Government.

38. NHMRC (2011). Australian Drinking Water Guidelines 6, 2011. National Water Quality Management Strategy. National Health and Medical Research Council, Australian Government.

39. NWQMS (1994) National Water Quality Management Strategy – Policies and Principles, AReference Document. Prepared by the Agriculture and Resource Management Council of Australia and New Zealand and Australia and New Zealand Environment and Conservation Council. April 1994.

40. NWQMS (2000) National Water Quality Management Strategy Paper No. 4. Australia and New Zealand Environment and Conservation Council and Agriculture and Resource Management Council of Australia and New Zealand, October 2000.

41. NWQMS (2000a) National Water Quality Management Strategy. Guidelines for Sewerage Systems, Use of Reclaimed Water. Australia and New Zealand Environment and Conservation Council, Agriculture and Resource Management Council of Australia and New Zealand, and National Health and Medical Research Council, November 2000.

42. NWQMS (2006) National Water Quality Management Strategy: Managing Health and Environmental Risks, Paper No. 21. Natural Resource Management Ministerial Council, Environment Protection and Heritage Council and Australian health Ministers Conference. November, 2006.

43. NSW EPA (1994) Guidelines for Assessing Service Station Sites. Environment Protection Authority, New South Wales EPA.

44. Pepper, L.L, Brooks, J.P. and Gerba, C.P. (2006) Pathogens in biosolids. Advances in Agronomy.

45. QEPA (2005). Queensland Water Recycling Guidelines. December 2005. Queensland Government Environmental Protection Agency.

46. SAH (2012). South Australian Recycled Water Guidelines. South Australian Health. SAHealth, Government of South Australia.

47. Standards Australia (2005) Guide to the sampling and investigation of potentially contaminated soil Part 1: Non-volatile and semi-volatile compounds. AS4482.1-2005

48. Standards Australia (1999) Guide to the sampling and investigation of potentially contaminated soil Part 2: Volatile substances. AS4482.2-1999.

49. USEPA (1990).I The Lake and Reservoir Restoration Guidance Manual 2nd Ed. UnitedStates Environmental Agency, Publication EPA-440/4-60-006. August 1990.

50. USEPA (2003). Bacterial Water Quality Standards for Recreational Waters (Freshwater and Marine Waters Status Report). United States Environmental Agency, Publication EPA-823-R-03-008. June 2003.

51. USEPA (2012). 2012 Guidelines for Water Reuse. United States Environmental Agency, Publication EPA/600/R-12/618. September 2012.

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52. WHO (2003). pH in Drinking Water, Background document for development of WHO Guidelines for Drinking-water Quality. World Health Organization, Geneva, 2003.

53. WHO (2011). Guidelines for Drinking Water. Fourth edition. World Health Organization, Geneva, 2011.

54. WSA (2004). Health Risk Assessment of Fire Fighting from Recycled Water Mains. Water Services Association of Australia.

Site Specific References55. Cardno Lane Piper (2014a). Summary report – Human Health Risk Assessment – CFA

Training Personnel. Fiskville Training College, 4549 Geelong–Ballan Road, Fiskville, Victoria. March 2014.

56. Cardno Lane Piper (2014b) CFA Water Quality Management Plan – CFA Fire Training Grounds, Victoria. Cardno Lane Piper, March 2014.

57. Cardno Lane Piper (2014c). Surface Water and Sediment Contamination Assessment. Fiskville Training College, 4549 Geelong – Ballan Road, Fiskville, Victoria. March 2014.

58. CFA (2012). Management Plan. Firefighting water, CFA Training College, Fiskville. May 2012. Country Fire Association.

59. Joy, 2012. Understanding the Past to Inform the Future, Report by the Independent Fiskville Investigation for the Country Fire Authority, Chairman Professor Robert Joy.

60. Wynsafe (2007). Management of the Quality of Firefighting water at CFA Field Training Grounds. October 2007.

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Appendix A4 Pages

Historical Water Uses at Field Training Grounds

212163.8Report01.8 Appendix A


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Appendix A.docx Page 1

FIRE TRAINING WATER QUALITY CRITERIA -CFA TRAINING GROUNDS, VICTORIA

APPENDIX A

WATER USE AT FIRE TRAINING GROUNDS

INTRODUCTION

Water used at the CFA fire training grounds is derived from a range of sources. The following table summarises these sources and other relevant information on the ‘water systems’ at each site.

Water source& Systems

CFA Field Training Ground

Fiskville Bangholme West Sale Huntly Wangaratta Penshurst Longerenong

Potable Water

Rainwater

Reclaimed Water

1 2

Process Water3

EnvironmentalWaters

Stormwater

Water Recirculated

TIT

On-site Dam

AST or UST on-site

Water dischargeoff-siteNotes:Symbols: - yes (i.e. currently in use, present or has been used), - no1. Class A reclaimed water, has been imported for use on limited occasions during drought at Fiskville2. Bangholme receives up to 10% of its sourced water is Class A reclaimed water from the neighbouring sewage treatment

facility.3. Process water includes recirculated water, i.e. water that has been used in fire-fighting and captured for re-use on site.

(Since June 2012 all RTG except Longerenong are using potable water as in interim measure)


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FISKVILLEThe water used at Fiskville has historically been drawn from a variety of sources that include: mains water, environmental waters, reclaimed water (Class A, on limited occasions)and stormwater. To keep up with demand, the CFA have progressively installed a catchment and treatment system that includes a sediment basin (e.g. settling pond), TIT and various surface water bodies (Dams 1 to 4) and discharged into Lake Fiskville. Water had been recirculated, up to June 2012, for re-use in training exercises.

The primary source of water used at Fiskville training ground is drawn from the water supply Pit, an underground concrete storage tank with approximately 220 kL capacity. This water supply pit has recently been replaced with a 250 kL above ground plastic tank. The Water Supply Pit was typically filled with potable water and supplemented with additional water from Dam 2 up to June 2012. A back up supply tank has been placed adjacent to Dam 2 (i.e. 250 kL above ground tank) to provide an additional water supply since water recirculation has ceased at Fiskville.

Water from Dam 2 was also used as a secondary source of water. The water collected in this dam comes directly from Dam 1, or from Lake Fiskville when it used to be pumped into Dam 2; however, this only occurred during dry seasons. Dam 1 collects discharge from the large flammable liquid PAD, once it passes through the sediment basin and TIT, as well as from other PAD areas.

Dam 2 has been taken off-line and a 250 kL above ground tank (filled by potable water) used as a secondary source of water only. . Note that Dams 1 and 2 collect a limited amount of surface water from the surrounding areas (as land falls away to the East, South and West). Water then flows to Dam 3, Dam 4, and Lake Fiskville via open drain channels or pipes before release to a tributary of the East Beremboke Creek.

Another source of water has been Class A recycled water. This has been used only on one known occasion during a period of severe water shortage.

BANGHOLMEThe CFA Training ground at Bangholme is located on a disused sewerage treatment facility. Water used in fire-fighting training exercises at Bangholme has previously been taken from various sources.

Water is sourced primarily from stormwater, process water (i.e. water captured from training exercises) and class A reclaimed water. Reclaimed water is sourced from the adjacent sewage treatment plant and comprises of approximately 10% of the water usage at the site (Pers. Comm. Site Manager). Stormwater and process water are captured, “channelled via the stormwater system to storage locations” (CFA, 2007) and treated in an open and closed systems for re-use in fire-fighting training exercises. Water is also sourced from domestic potable water source (South East Water) when stormwater volumes are insufficient to keep water tanks full and re-cycled water supplies are low. According to CFA “South East Water has indicated that there is no restriction on the volume of potable water’ that may be drawn for fire-fighting training purposes (CFA, 2007).

Water used in training is sourced from four different tank storage systems; the Concrete and Green water tank located near the flammable liquid PAD, and the two Megalitre water tanks complex (i.e. South and North Megalitre tanks). Water from these storage systems are chlorinated before use. The Concrete tank is used as a backup source of water and receives the reclaimed water (i.e. Class A) intake. These water storage tanks are described as follow:


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Green tank: water collected from the flammable liquids PAD is passed through a TIT and stored in this tank. Water in this tank may be supplemented by water from a 90 kLconcrete tank Megalitre water tanks: Water from other PAD areas are directed in through an in-ground sediment removal and flows by gravity to the 1.0 ML North megalitre tank. Water is then transferred to the 1.0 ML South megalitre tank.Concrete Tank: The concrete tank may receive reclaimed Class A water and also water from the North megalitre tank or potable water. It may be used as a source of water for the Green Flammable Liquids tank or the megalitre tanks. Water used on the PADs may be taken directly from the Concrete tank if required, when other tank storages have been taken off-line.

GIPPSLAND – WEST SALEWater for fire fighting at the Gippsland Training Ground at West Sale is combined environmental water and surface water run-off stored in a dam. The dam is filled primarily from a groundwater bore on-site and excess surface water collected in a retention tank. Water used during training activities on the ‘fire ground’ passes through a TIT and flow back into the dam.

There is no water treatment process at West Sale, the TIT would only serve as a sediment and oil separator.

NORTHERN DISTRICTS – HUNTLYEnvironmental water in the dam at Huntly in the Northern Districts has been the primary source of water for fire fighting training exercises. The dam is used to store water from two sources; stormwater and water from the PAD that had previously been used for fire fighting training. Stormwater and water from the PAD areas are channelled either via the roadways or an underground stormwater drainage system to the main dam. Water from the flammable liquids PAD is passed through a series of three TIT.

An alternative source of water used for backup supply are the on-site rainwater tanks (7 x 22.5 kL AST and one 4.5 kL UST) and/or sourced directly from the dam via draughting. Until recently, there was no provision at Huntly to draw potable water from the local water supplier, Coliban Water.

WANGARATTAThe Wangaratta Training Ground uses potable water only as the primary source of water. This water is stored in an underground storage tank (105 kL). Water used in training passes through a TIT and then discharged to an adjacent creek. Water is not recirculated at the Wangaratta RTG. The only source of flammable propellant used at Wangaratta is LPG and minor volumes of kerosene used for starting cold fires.

WESTERN DISTRICTS – PENSHURSTPotable water is the primary source of water used for fire fighting training at Penshurst Training Ground in the Western Districts. This water is stored in an above ground storage tank and may be topped up from an on-site dam or directly from a water tanker. The dam receives stormwater and water from the ’fire ground’ training area via a TIT. Historically, the water at Penshurst has also been recirculated..


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WIMMERA – LONGERENONGThe primary source of water at Wimmera Training Ground at Longerenong is from the Wimmera-Mallee Pipeline - WMP. Water in this pipeline is drawn from a surface water body (i.e. Lake Bellfield) and pumped to towns and agricultural areas without treatment. It is unlikely that the water drawn from the WMP has been treated prior to use. This water is stored in a large above ground tank which has been topped up at times from a small on-site dam. The dam receives stormwater as well as water from the “fire ground” which passes through a TIT.

A secondary source of water has been supplied from a safety line tank, and in some instances, from a tanker. The type of water as a secondary source was not ascertained by Cardno Lane Piper.

Cardno Lane PiperDecember 2013


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Appendix B11 Pages

Water Quality Criteria Derivation

212163.8Report01.8 Appendix B


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APPENDIX B

DERIVATION OF OHS RISK BASED TARGETS1 BACKGROUNDThis appendix sets out the calculations and assumptions used to calculate Water Quality Criteria (WQC) for the following OHS risk based targets:

Inorganic compounds (Section 2); Organic compounds (Section 3), i.e. perfluorinated chemicals (PFC) and petroleum hydrocarbon fractions (TPH); andMicrobial pathogens (Section 4).

The OHS Risk Based targets provided take into account exposure of CFA Training Personnel during Hot-Fire Training as assessed in the Human Health Risk Assessment (HHRA) conducted by Cardno Lane Piper (2014a). The criteria for organic compounds were reverse calculated using the same equations as used in the HHRA (however the equations are transposed to isolate water concentration and use a maximum permissible level of risk, Hazard index = 0.33). A quantitative Microbial Risk Assessment (QRMA) conducted by Ecos (2013) was used as the basis for calculating log reduction values (LRV), i.e. a set of disinfection goals, for a Water Treatment Plant (WTP), to achieve the targets was calculated for microbial pathogens based on an exposure assessment conducted.

The WQC derived in this appendix are specific to CFA Training Personnel exposed during hot-fire training at Field Training Grounds (FTG). They are not to be used as WQC for protecting the environment, for water that is used as a drinking source or other beneficial uses.

2 INORGANIC COMPOUNDSWQC derived for select inorganic compounds (metals) are provided in Table 2-1 below. The metals (Arsenic, Cadmium, Chromium VI, Lead and Nickel) were selected based solely on the metals included in the analytical suite during investigations at CFA Fiskville Training Groundand whether they are relevant to human health impacts1. These criteria were derived by making a simple adjustment to Drinking Water Guidelines (DWG) from NHMRC (2011) using a conversion factor estimated using Equation 4-1 below. This conversion factor adjusted the DWG to account for the reduced volume of water assumed to be accidentally swallowed by CFA Training Personnel during hot-fire training. The leading fire-fighter involved in delivering training exercises is the CFA Training Personnel with the highest exposure (1 ml for up to 2 hours training per day2). This is considerably lower than the daily consumption of water consumed by an adult (2 L/day, enHealth 2012). The conversion factor is then used to derive the WQC for inorganic compounds using Equation 2-2 below.

1 Note that copper and zinc were also included the analytical suite at CFA Fiskville Training Ground however they are not considered here as they were considered for environmental impacts rather than human health impacts.2 The amount of water assumed to be accidental ingestion by CFA Training Personnel during hot-fire training is up to 1ml/day water per day. This is a best justified value as described in the Human Health Risk Assessment prepared for Fiskville Training Ground (Cardno Labe 2014a). A conservative value of 12.5ml/day (1 hour of training) is likely an overestimate of actual exposure and not used in derivation of OHS risk based Targets for inorganic and organic compounds in this report.

Appendix B.docx Page 1


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EFWDPYW

CFFFTIngest

Consumed Equation 2-1

Where:CF = Conversion factor (3000 = [2000×365] ÷[1×240])WIngest – FFT = Amount of water ingested during fire-fighting training (1mL/day)EF = Exposure frequency (240 days per year based)

CFDWGWQC Equation 2-2

Where:WQC = Water Quality Criteria (mg/L)CF = Conversion factor (3000 = [2000×365] ÷[1×240])DWG = Drinking Water Guideline (Chemical Specific, NHMRC 2011)

Table 2-1 Water quality criteria derived for inorganic compounds

Compound Drinking Water Guideline1 (mg/L)

OHS Risk Based Target2 (mg/L)

Metals (tested in water at RTG)Arsenic 0.01 20Cadmium 0.002 6Chromium (III,VI) 0.050 150Lead 0.01 30Nickel 0.02 601. Drinking Water Guidelines sourced from NHMRC (2011).2. The OHS risk based target is calculated assuming that CFA Training Personnel are

exposed to up to 1ml/day water per day. This is a best justified value as described in the Human Health Risk Assessment prepared for Fiskville Training Ground (Cardno

3. Lane Piper 2014a).

Equation 2-2 above can be used for calculating an OHS risk based Target for other compounds where a suitable DWG is available and dermal absorption is not a significant exposure pathway. As a default position this would calculation is not applicable to calculating OHS risk based Targets for organic compounds (discussed in Section 3). This table can simply be updated where drinking water guidelines are updated in the future.

3 ORGANIC COMPOUNDSWQC have been derived for those compounds identified as Compounds of Potential Concern (CoPC) in the Human Health Risk Assessment (HHRA) conducted by Cardno Lane Piper (2014a). The CoPC identified in the HHRA were from the following two groups of compounds;

Perfluorinated compounds (PFC): This group of compounds are split in to 3 classes;Perfluoroalkyl Sulfonic Acid (PFAS) using Perfluorooctane Sulfonic Acid as a surrogate;Perfluoroalkyl Carboxylic Acid (PFAA) using Perfluorooctane Carboxylic Acid as a surrogate; andOther Perfluorinated Compounds (OPC) using 6:2 FTS as a surrogate.

Petroleum hydrocarbons (PHC); Two fractions were identified as being CoPC. They are:Total Petroleum Hydrocarbon >C10 – C16

Total Petroleum Hydrocarbon >C16 – C34

These WQC are OHS risk based using best justified assumptions as shown in Table 3-1 and best justified assumptions as shown in Table 3-2.They were derived using the equations as set out in Section 3.1 below which are simple rearrangements of the equations used in the human



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health risk assessment from Cardno Lane Piper (2014a). The equations and parameter values used to derive WQC are based on those equations used in the HHRA. Note that other organic compounds may be identified as CoPC at different FTG or during verification and commissioning of water treatment systems. The OHS risk based targets for these compounds would need to be derived by a suitably qualified person.

Table 3-1 Water quality criteria (mg/L) derived for Perfluorinated compounds (PFC) and Total Petroleum Hydrocarbons (TPH)

Compound Acronym

OHS Risk Based targets (mg/L)

Fire Fighter

Perfluorinated ChemicalsPerfluoroalkyl Sulfonic Acid PFAS 56Perfluoroalkyl Carboxylic Acid PFAA 57Other Perfluorinated Compounds OPC 170Petroleum HydrocarbonsTotal Petroleum Hydrocarbon >C10 – C16 TPH C10 – C16 Greater than

solubility limitsTotal Petroleum Hydrocarbon >C16 – C34 TPH >C16 - C34Note:PFAS includes perfluorooctyl sulfonic acid, PFAA includes Perfluorooctane carboxylic acid, OPC includes 6:2 fluorotelomer and other perfluorinated chemicals that do not have the sulfonic acid (PFAS) or carboxylic acid (PFAA) functional groups.

It is noted that the risk based targets for TPH are greater than solubility limits. This is relevant to chronic exposures however measures should be taken to reduce TPH levels to the practical extent possible to reduce aesthetic concerns.

3.1 Derivation of formula for calculating Risk Based Criteria (RBC) for PFAS and PFAA

Derivation of an equation to calculation risk Based Criteria (RBC) for PFC was based on equations provided in the HHRA (Cardno Lane Piper 2014a). The equations used to calculate risk are rearranged and combined to isolate “Cwater”, the OHS risk based Target, to give Equation 3-1 below:

EDEFDAFt

CFKFASSAEDEFBIOCFI

ATBWBITRVTHICWQC

EventEventDApORALWater

ChronicWater

6

Equation 3-1



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Table 3-2 Parameter values used for estimating Risk Based Criteria

Acronym Description Units PAD Instructor or Leading Fire fighter

WQC Water Quality Criteria (The Concentration in water, CWater)

μg/L To be calculated using equation 3

TRV Toxicity reference value μg/kg/d 0.5 (PFAA and PFAS) 1.5 (OPC)

BI Background Intake μg/kg/d 0.0008 (PFAS), 0.0004 (PFAA), nil (OPC, TPH fractions)

THQ Target Hazard Quotient 0.33 (PFC), 0.5 (TPH fractions)

EF Exposure frequency d/yr 240

ED Exposure duration years 20

BW Body weight kg 78

ATchronic Averaging time for chronic risks day 7,300

IWater Amount of water ingested mL/d 1

CF A conversion factor L/mL 0.001

BIOORAL Oral bioavailability of chemical Unitless 1

SSA Surface skin area cm2 1,400

DAF The dermal absorption factor Unitless 1

CF A conversion factor L/cm3 0.001

FA The fraction of absorbed water Unitless 1

tEvent Event duration hrs/d 2

Event The lag time per event hoursMW

Event0056.010105.0 (PFC), 0.66

(TPH fraction C10-C16), 1.9 (TPH fraction >C16-C34)

KP Dermal permeability coefficient cm/hr 1.5x10-5 1

MW Molecular Weight g/mol 500 (PFAS), 414 (PFAA) and OPC (450)

1. Dermal Permeability coefficient based on PFOA (Fasano 2005)

4 MICROBIAL

4.1 Endotoxins

No WQC have been derived for endotoxins. Endotoxins are widespread in the environment. They would not pose health risks following inhalation of water unless a large quantity of aerosol was released and inhaled over a long period. Recommendations for control measures were not required (Ecos 2013).

4.2 Algal Toxins

There is inadequate data to derive DWG for specific algal toxins except for microcystins-LR toxicity equivalents (TEQ). A DWG of 1.3 μg/L was derived by NHMRC (2011) assuming 90% of the toxin was sourced from drinking water.



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WQC were derived for microcystins-LR (TEQ) based on exposure of CFA personnel exposed to water during hot fire training events at Fiskville. The methodology used to derive the WQC for total mycrocystins was equivalent to that used by NHMRC (2011) when deriving a guideline value for drinking water using Equation 4-1 below except that:

The amount of water ingested (WIngest) has been changed to reflect the volume of water accidentally swallowed daily by CFA training personnel during a training session. This was assumed to 1mL/day for 240 days per year based on CFA Training Personnel with the highest and most regular water exposure.The proportion of daily intake (ratio) was considered to be 0.1, considered a site-specificvalue. This assumes that only 10% of intake is permitted from accidental swallowing of water as the NHMRC (2011) assumptions is that an adult will have 90% of their permissible intake during the course of a day.

UFWRatioBWNOAELWQC

FFTIngest

Equation 4-1

Where:WQC = Water Quality Criteria (μg/L)NOAEL = No observed effect Level (40μg/kg/day, NHMRC 2011)BW = Body weight of an adult (70kg, NHMRC 2011)Ratio = The proportion of daily intake attributed to accidental swallowing of water

(0.1, site specific)WIngest – FFT = 0.001 L per day, (Cardno Lane Piper 2014a)UF = Uncertainty factor of 1000 (e.g. Intraspecies variability, interspecies variability,

limitations in the database (NHMRC 2011)

The calculation of the WQC for total mycocystin is shown below using Equation 4-1 from above.

2801000001.01.07040WQC

The management of algal bloom risk in Victoria is regulated by a framework document released by the Department of Sustainability and Environment (DSE) (DSE 2011). This framework most likely applies to the on-site surface water bodies at Fiskville as they drain into public waterways. Routine monitoring of algal cell counts/biovolume in the surface water bodies at Fiskville was recommended (Ecos 2012). Trigger values for algal cell counts/biovolume would be required to identify when a particular surface water body should be taken offline. This was considered “an appropriate risk management framework for ensuring that CFA personnel were not exposed to algal toxins above the tolerable guideline” (Ecos 2012). WQC have not been derived for the indicators of algal toxins such as:

Microcystin aeruginosaTotal combined biovolume (Toxic), andTotal combined biovolume (Known).

Instead, guidelines already derived for these indicators have been adopted as WQC fromNHMRC (2011) using primary contact recreation values. This is because exposure during hot-fire training over the year (1 mL/day for 240 days) is less than expected during primary contact recreation therefore a conservative assumption. The WQC adopted are shown below in Table 4-1.



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Table 4-1 Water quality criteria derived for algal toxins

Algal toxin Water Quality Criteria (mg/L)

Total microcystins (microcytin-LR TEQ) 280

Microcystin aeruginosa 50,000 1

Total combined biovolume (Toxic) 10 1

Total combined biovolume (Known) 10 1

1 Primary Contact Recreation guidelines (DHS 2011) adopted as best justified water quality criteria.

4.3 Opportunistic Pathogens (Pseudomonas aeruginosa)

The most likely opportunistic pathogen to be found in Victorian surface water bodies was considered to be P. aeruginosa. Risk associated with exposure to this pathogen is low when compared to enteric microbial pathogens. Controls implemented to manage the enteric pathogens are anticipated to be sufficient in managing risks associated with opportunistic bacteria such as P. aeruginosa. Water quality criteria have not been derived for P. aeruginosa.

4.4 Enteric Pathogens (virus, bacteria and protozoa)

It is considered impractical to derive WQC for enteric pathogens (enHealth 2012, NHMRC 2011). This is because risks are associated with pathogen concentrations that are well below 1 organism per litre (1org/L). The large volumes of water required to be sampled and tested to meet WQC if they were derived makes this proposition impractical. However, this does not preclude investigative testing for these pathogens.

Instead, the approach to protect human health from these pathogens should include a multi barrier approach from prevention by catchment management (including PAD Training Area if recirculation is considered) to storage and to the tap (hydrants from which water is drawn for hot fire training). This is consistent with the approach recommended by NHMRC (2011) for rotavirus, cryptosporidium and other microorganisms (viruses, cyanobacteria, protozoa and bacteria).

One step in this process is to set performance based targets for enteric pathogens. The following four step process has been established for setting the performance targets (enHealth 2012, NHMRC 2011):

Estimating pathogen concentrations in water;Use of QRMA to determine the extent of infection and illness;Translate illness to burden of disease; andCalculating the reductions in pathogen concentrations required.

These steps were followed in the QRMA prepared by ECOS (2012) for exposures at CFA Fiskville Training Ground. LRV values were calculated to treat water such as that in Dam 2 (as a worst case scenario for water supply, see section 4.4.3) to a suitable level to be considered safe for use in hot fire training. The method used for determining performance targets for microbial hazards in the QRMA and followed this report is adopted from that provided in Section 3 of the Australian Guidelines for Water Recycling (NHMC 2006). The method requires that a tolerable concentration be calculated and then used to determine the log reduction value (LRV) required by a treatment process to achieve a risk that complies with the tolerable level of 10–6

DALYs (DALY = Disability Adjusted Life Year) per person per year.



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4.4.1 Water categories considered

LRVs were calculated for different water bodies depending on the level of “protection” they are afforded. An assessment of any water that is used (including process water when reused) is required to determine an appropriate LRV to ensure water is fit-for-purpose. LRV have been determined for different water categories as each requires a different level of protection. The water categories are discussed below in Table 4-2 including source of water for each category and notes on the catchment area.

Table 4-2: Various water categories stored at CFA training GroundsWater category Water type Potential water sources Notes on the water catchment

area

1 Pretreated water

Includes potable water and/or reclaimed Class A water that are sourced from a Water Authority or other approved supplier. It caninclude groundwater and potentially rainwater if the catchment area is known to be pathogen free.

Potable water is typically source from protected waters (See water category 2) and treated prior to supply. Note that monitoring of chlorine levels may be required if these waters are stored prior to use.

2 Protected water

Water from various catchment areas including rainwater, environmental waters (surface water bodies and waterways), groundwater and stormwater. It may include process water if chemical and pathogen loads are known to be low

The catchment area used to collect water should be protected, i.e. sheep and cattle grazing shouldnot occur in the catchment area of the surface water body and there is no contribution to pathogen loads from upstream grey water systems.Pathogen loads are assumed from birds that frequent surface water bodies, building roofs and PAD areas where CFA Training Personnel engage in exercises.

3Partially protected water

The same as protected water except that water from a second unprotected water body (see Type 4 below) may be used as a top up once per year.

4a and 4b

Unprotected water Type A(4a) Environmental Water collected

from unprotected catchment areas and reclaimed Class B and Class C water. It may include process waters.

Water collected from an unprotected catchment area which includes pathogen loads from i) birds and mammals that frequent surface water body and PAD areasand ii) sheep and cattle that graze in the catchment area.

Unprotected Water Type B(4b)

Water from catchment areas with pathogen loads as discussed for unprotected surface water body, Type A (Water Category 4a) with additional pathogen loads from upstream grey water systems.

5 Other Grey water, sewage and other It may include process waters Not relevant.

The LRV calculations require an estimate of pathogen concentrations in the different water categories. Estimated pathogen concentrations for each water category that is untreated water (Categories 2 to 5) are shown below in Table 4-3.



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Table 4-3: Pathogen concentrations in surface waters and assumed log reductions

ParameterPathogen

Rotavirus Campylo Cryptoi. Irrigated Effluent from upstream sewage treatment systems

ia. Used as is, no dilutionRaw sewage concentration (Orgs/L, 95th percentile) 8,000 7,000 2,000Sewage Treatment Plant (LRV) 2 2 2Trickle irrigation (LRV) 1 1 1Dilution in surface water body (LRV) 1 1 1Inactivation in surface water body (LRV) 1 1 1Total log reductions (LRV) a 5 5 5Log reduced concentration (Org/L) 0.08 0.07 0.02ib. Diluted as water used for top up once per year onlyDilution as water used for top up once per year (LRV 2 2 2Log reduced concentration (Org/L) for water used as top up 0.0008 0.0007 0.0002

ii. Catchment runoff (grazing pasture)iia. Used as is, no dilutionBest justified concentration (Orgs/L) 0 50 1Inactivation in surface water body (LRV) 1 1 1Log reduced concentration (Org/L) 0 5 0.1iib. Diluted as water used for top up once per year onlyDilution as water used for top up once per year (LRV 2 2 2Log reduced concentration (Org/L) for water used as top up 0 0.05 0.001

iii. Water fowl in surface water body (including birds on PAD areas)Best justified concentration (Orgs/L) 0 5 0.1Inactivation in a surface water body (LRV) 1 1 1Log reduced concentration (Org/L) 0 0.5 0.01

iv. Concentration of enteric pathogen in various water types (CONCWater)2 Protected surface water body (iii) 0 0.5 0.013 Partially protected surface water body (ib+iib +iii) 0.0008 0.55 0.0114 Unprotected surface water body, Type B (iia+iii) 0 5.5 0.11

5 Unprotected surface water body, Type A (ia+iia+iii) 0.08 5.6 0.13

Campylo = campylobacter, crypto = cryptosporidium, Org/L = organisms per litrea The log reduction value (LRV) of 5 assumes that the sewage treatment system is upstream of the surface water body. A LRV of 7 was specified in the QRMA (ECOS 2012) which took into account dilution that occurs at Fiskville as water was pumped on limited occasions from Lake Fiskville up to Dam 2.

4.4.2 Equations used to calculate WQC for Enteric Pathogens

The tolerable concentration and log reduction values required to produce water suitable for fire-fighting purposes for various water bodies at CFA training grounds were calculated using Equation 4-1, Equation 4-2 and Equation 4-3 below.

EDEventsIngEXP WaterYear Equation 4-1



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Where:EXPYear = Exposure from incidentally ingested water over 1 year (mL)IngWater = 0.001. Conversion factor, (10-3mL/L)Events = Number of exercises per dayED = Exposure duration (number of days per year exposed)

TDCFEXP

FC Year Equation 4-2

Where:FC = Final concentration (org/L)EXPYear = Exposure tor incidentally ingested water over 1 year (mL)CF = 0.001. Conversion factor, (10-3mL/L)TD = Tolerable dose equivalent to 10-6 DALY. (DALYd)

)1(10 WaterConcFC

LogLRV Equation 4-3

Where: final concentration = LRV = Log reduction valueFC = Final concentration (org/L)ConcWater = Concentration of pathogen in water (org/L)

A negative LRV is calculated where the predicted pathogen concentration is less than the maximum level that is considered acceptable. In these instances the LRV is set to zero (0).

4.4.3 Summary of Log Reduction Values EstimatedA summary of LRV estimated for the most sensitive user identified in the HHRA (Cardno Lane Piper 2014a) and QRMA (ECOS 2013) is shown below in Table 4-4 for each water category.LRV calculated for all the CFA personnel involved in hot fire training are shown in

Table 4-5 below. Note, LRV are not calculated for treated water (e.g. drinking water). The calculations were based on two data sets:

Best justified parameter set: this includes values that are based on typical parameters. These assumptions are adopted as they represent the most likely scenario. These values are used above calculating WQC for inorganic and organic chemical as exposure is well defined and chemical loads in water are well characterised.Worst case parameter set: This set reflects the values at higher end of exposure settings (e.g. maximums or 95th percentiles). Worst case assumptions are included as a guide in the HHRA and QRMA to address inherent uncertainties in those types of risk assessment. Although they most likely overestimate risk they are relied upon for microbial pathogens as pathogen loads in water at FTG is poorly defined.

Generic pathogen loads were used in calculations in this report and in the QRMA. This introduces a level of uncertainty that may not be appropriately accounted for if using the best justified parameter value set. Therefore it is considered prudent to use LRV estimated using the worst case parameter value set until microbial pathogen loads in water used in hot-fire training is better characterised.



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Table 4-4: Pathogen concentrations in surface waters and estimated LRV

Water Category Water Description Pathogen

Rotavirus Campylo CryptoPathogen concentrations (Org/L)

2 Protected water storages 0 0.5 0.013 Partially protected water storages, Type A 0.0008 0.55 0.0114 Partially protected water storages, Type B 0 5.5 0.115 Unprotected surface water body 0.08 5.6 0.13

Log reductions (LRV), best justified assumptions (Leading Fire-fighter)2 Protected water storages 0 0.02 03 Partially protected water storages, Type A 0 0.1 04 Partially protected water storages, Type B 0 0.5 05 Unprotected surface water body 0.4 1.1 0

Log reductions (LRV), conservative assumptions (PAD Instructor)2 Protected water storages 0 1.9 0.63 Partially protected water storages, Type A 0.3 1.9 0.64 Partially protected water storages, Type B 0 2.9 1.65 Unprotected surface water body 2.3 2.9 1.7

Campylo = campylobacter, crypto = cryptosporidium, Org/L = organisms per liter,

Table 4-5: Summary of LRV for CFA hot fire training

Scenario Water Type Water description Cadet Firefighter Leading

FirefighterPAD Instructor

Rotavirus

Best Justified

2 Protected Water 0 0 0 03 Partially Protected Water B 0 0 0 04 Partially protected Water A 0 0 0 05 Unprotected Water 0.1 0 0.4 0

Conservative

2 Protected Water 0 0 0 03 Partially Protected Water B 0 0 0 0.34 Partially protected Water A 0 0 0 05 Unprotected Water 1.5 1.3 1.8 2.3

Campylobacter

Best Justified

2 Protected Water 0 0 0.02 03 Partially Protected Water B 0 0 0.1 04 Partially protected Water A 0.8 0.6 1.1 0.55 Unprotected Water 0.8 0.6 1.1 0.5

Conservative

2 Protected Water 1.1 0.9 1.4 1.93 Partially Protected Water B 1.2 1.0 1.5 1.94 Partially protected Water A 2.2 2.0 2.5 2.95 Unprotected Water 2.2 2.0 2.5 2.9

Cryptosporidium

Best Justified

2 Protected Water 0 0 0 03 Partially Protected Water B 0 0 0 0



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Scenario Water Type Water description Cadet Firefighter Leading

FirefighterPAD Instructor

4 Partially protected Water A 0 0 0 05 Unprotected Water 0 0 0 0

Conservative

2 Protected Water 0 0 0.1 0.63 Partially Protected Water B 0 0 0.1 0.64 Partially protected Water A 0.8 0.6 1.1 1.65 Unprotected Water 0.9 0.7 1.2 1.7

5 CONCLUSIONA set of OHS Risk Based Criteria have been selected and/or derived in this Appendix in support of the main text of this report. These criteria are for:

Inorganic compounds;Organic compounds, i.e. perfluorinated chemicals (PFC) and petroleum hydrocarbon fractions (TPH); andMicrobial pathogens.

It should be noted that not all of these criteria will be appropriate in all circumstances and their adoption for any particular site will depend on a site-specific assessment of water source type, available treatments/controls and the mode of use, amongst other considerations.

Cardno Lane PiperMarch 2014



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Appendix C11 Pages

Literature Review of Ecological Criteria for Perfluorinated Compounds (PFC)

212163.8Report01.8 Appendix C


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APPENDIX C

LITERATURE REVIEW OF ECOLOGICAL CRITERIA FOR PERFLUORINATED COMPOUNDS (PFC).

1 INTRODUCTIONThe Compound of Potential Concern (CoPC) identified in water and sediment are Perfluorinated Compounds (PFC). Ecological guidelines for PFC have not been derived in Australia for these compounds. Therefore a review of available criteria for PFC from overseas agencies is conducted here.

The selection of a suitable ecological Guideline Trigger Values (i.e. Water Quality Criteria or WQC) is dependent on a number of factors including consideration of the management goal (e.g. protection of aquatic ecosystems), the type of water body being considered and whether all relevant ecotoxicological information was considered in their derivation. In order to ensure suitable consideration is given to selecting an appropriate WQC from overseas agencies this review is conducted in the following steps which is outlined in ANZECC (2000):

Define the Management Aims: This requires knowledge of an ecosystem, potential impacts to the ecosystem and an understanding of the approach used to select (and/or derive) appropriate criteria for use in Australia based on Australian and New Zealand Water Quality Guidelines (ANZECC 2000). WQC are used in Australia based on an appropriate level of protection afforded an aquatic ecosystem, i.e. selecting a percentage of species in an ecosystem that require protection. This steps used in the process are as follows:1) Describe the water body to be protected.2) Determine Environmental values to be protected.3) Determine the level of protection.4) Identify environmental concerns.5) Determine major natural and anthropogenic factors affecting the ecosystem:6) Determine management goals: Determine appropriate guideline trigger values: A review of available WQC is provided.

2 DEFINING THE MANAGEMENT AIMS FOR WATERWAYSDOWNSTREAM OF THE SITE

The six steps required for defining the management aims of downstream waterways are discussed below in the order provided by ANZECC (2000) and outlined above.

2.1 Describe the water body to be protected (Step 1)

The surface water bodies considered are Lake Fiskville (located on the Site) and waterways downstream of CFA Fiskville Training College which have previously been described (“Aquatic Ecology Assessment, Fiskville Training College”, Cardno 2014). A summary of these water bodies and the degree of modification is provided here:

Appendix C.docx Page 1


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Lake Fiskville: The Lake is a manmade feature created before CFA occupation of the site by damming the Beremboke Creek. It is occasional used by CFA as an emergency water source (perhaps once annually in drought.) It is a highly modified ecosystem which now supports an extensive growth of macrophytes (including emergent rushes and submerged/floating plants) and numerous water birds including black swans, cormorants, moorhens and black ducks. The lake also supports a population of introduced fish (redfin, mosquitofish) as well as eels and yabbies.The Beremboke Creek: A small, shallow, stream which leaves the Site at its southern boundary and runs through pasture land. A small number of farm dams are located on the creek within 3 km of the Site. These dams are believed to be used for stock water. Limited flora is evident in this section of the creek. This creek is considered a highly modified and ephemeral water body.The former marsh swamp area: The swamp (which starts approximately 6 km downstream of the site and extends to 9.5 km from the Site) has been drained for agricultural use and currently includes at least one drainage channel. This drained swamp is also considered a highly modified ecosystem.The Eclipse Creek: This creek is the continuation of Beremboke Creek downstream of the swamp and continues to runs through pasture and is also considered highly modified and ephemeral. A shallow water hole was evident near the site of inspection which was choked with emergent rushes.The Moorabool River: Eclipse Creek flows into the Moorabool River approximately 17 km (direct route) downstream of Lake Fiskville. It has extensive riparian habitat with minimal disturbance which supports native flora and fauna including various fish species. However, there are various barriers in place which prevent fish movements. Environmental releases from Lal Lal Reservoir were made to improve salinity, conductivity, and reduce impact on fish by allowing improved movement between ponds (CCMA 2009). This was considered necessary as an assessment of in-stream river health rated this river as being in poor to very poor condition due to competing demands which “has led to severe alteration of the river’s natural flow regime”, impact from farm dams, extraction of groundwater and possibly climate change (CCMA 2009). The Moorabool River is considered only moderately modified.

Note that the Beremboke Creek, the Swamp drainage channel and Eclipse creeks are ephemeral in nature. The Moorabool River is considered ephemeral in parts in extreme years.

2.2 Determine Environmental values to be protected (Step 2)

Relevant ecological receptors to be considered include biota supporting ecological processes (e.g. microorganisms), wildlife (e.g. secondary poisoning of birds) and flora (native and introduced).

Lake Fiskville and the Moorabool River both support fauna and flora therefore ecological considerations include potential undesirable impacts to aquatic life and secondary poisoning to wildlife (birds, mammals). The ephemeral nature of the Beremboke Creek, Drainage Channel and Eclipse Creek suggests there is limited opportunity for ecological receptors to be present in this ecosystem.

2.3 Determine the level of protection (Step 3)

The ANZECC (2000) guidelines outline three different levels of protection depending on the state of the ecosystem. The levels of protection for the different surface water bodies considered are assessed as:



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Pristine and/or high conservation value ecosystems: These ecosystems are afforded 99% protection in Australian aquatic ecosystems. Surface water bodies downstream of the Site do not fit this description.Slightly to moderately disturbed ecosystems: The level of protection afforded these ecosystems is 95%. The Moorabool River is considered to be moderately modified. Should water flows in the River increase above levels in 2008 and the impacts from farming reduced then the river may return to a slightly modified state. There are other barriers that prevent this River from being considered pristine which includes barriers that prevent fish movement.Highly disturbed ecosystems: The default level of protection for these ecosystems is 90% or 80%. An emphasis should be placed on improving this water system therefore a higher level of protection might be applied in some circumstances (ANZECC 2000). Lake Fiskville, the Beremboke Creek, the Drainage Channel and the Eclipse Creek are considered highly disturbed surface water bodies. Flora and Fauna are abundant around Lake Fiskville, limited in the creeks and assumed to be limited in the drainage channel.

Note that the level of protection refers to the percentage of species that should be protected by a selected WQC. As an example, a protection level of 95% is meant to protect 95% of all aquatic species in a surface water body. For highly disturbed ecosystems a higher level of protection is ideal where the long-term aim is to improve water quality, particularly where a management goal is that there is no change in biodiversity in the impacted ecosystem. For highly disturbed ecosystems this means that “the same guidelines as for slight-moderate disturbed systems” might be applied (ANZECC 2000).

2.4 Identify environmental concerns (Step 4)

PFCs are fluorosurfactants that have been identified as a compound of environmental concern as they have been detected in water and sediment of Lake Fiskville, water and sediment in downstream creeks and in sediment (but not water) of the Moorabool River. Some PFCs have also been identified in samples from fish, crustaceans, rabbits and aquatic plants. No obvious toxic effects have been observed in the species. PFC of most interest are Perfluorooctane Sulfonic Acid (PFOS), Perfluorooctane Carboxylic Acid (PFOA) and 6:2 Fluorotelomer Sulphonic Acid (6:2 FTS). There is potential for PFC to bioaccumulate in the environmenttherefore it may be considered necessary to increase the level of protection (e.g. 98% instead of 95% and 85% instead of 80%).

PFCs are present in fire-fighting foams products currently used at Fiskville Training College. There is the option that these fluorosurfactants will be replaced by hydrocarbon surfactants in fire-fighting foam products. Therefore, consideration of hydrocarbon surfactants is also provided even though they have not been identified as a CoPC in water and sediments.

2.5 Determine major natural and anthropogenic factors affecting the ecosystem (Step 5)

PFCs have been used at CFA Fiskville Training College during hot-fire training during instruction of fire-fighters. FFC in the Lake and creeks are considered to be sourced from training activities at the Site. PFCs are becoming more widespread in the environment as a result of their use in various consumer products (carpets, pots, pan, paper, etc.). It is not clear what is the source of the PFC at very low levels (<2 μg/kg) in sediment samples from the Moorabool River.



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2.6 Determine management goals (Step 6)

The primary management goal is the protection of aquatic ecosystems downstream of the Site. Consideration is also given to protection of wildlife dependent on these ecosystems such as water birds (secondary poisoning) and primary industries (stock drinking water). Therefore consideration is given to identify WQC that protect the following:

Aquatic Ecosystems (including water and sediment)Mammalian SpeciesBirdsBiota and organisms (in the soil compartment)

A range of data has been collected to address these management goals which includes concentration of PFCs in water, sediment, aquatic plants, crustaceans, fish (whole, liver and muscle), rabbit (muscle). Therefore, where permitted, it is important to identify WQC that have been derived and can be applied to this data.

Ecological impacts that may affect human health such as primary contact recreation and consumption of fish or livestock are not considered here. These are considered separately in Human Health Risk Assessments being conducted for the Site and include people from the Fiskville Community and Downstream Users.

3 DETERMINE APPROPRIATE GUIDELINE TRIGGER VALUES

Appropriate WQCs for PFC and hydrocarbon surfactants are adopted in this assessment by using the following steps:

Summary of how WQC are derived in AustraliaSummary of the WQC adopted for protection of management goalsA brief discussion of relevant criteria identified in available literature.

3.1 Summary of How Guideline Trigger Values are Derived in Australia

This section only provides a short summary of how WQC should be applied/derived in Australia. ANZECC (2000) should be consulted for a detailed description. Three grades of WQC are outlined by ANZECC (2000) that are defined by the amount of ecotoxicological data available and hence the confidence that can be afforded them. They are called either a high, moderate or low reliability WQC and are broadly summarised as follow:

High reliability WQC: A statistical distribution approach is used based on chronic data from multiple species.Moderate reliability WQC: Similar to approach for the high reliability WQC above except that acute toxicity data is used in statistical distribution and then converted to a chronic value. Low reliability WQC: An assessment factor (AF) approach is utilised. These WQC are screening in nature and should be used in an interim nature due to uncertainties in their derivation. According to ANZECC (2000), “there is no reliable way to predict what changes in ecosystem protection are provided by an arbitrary reduction in the factor”.

The majority of criteria identified in the next section have been derived using this approach. Caution is required if management decisions are to be based on exceedence of low reliability



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WQC as they are considered screening values. Further assessment may be required if exceeded.

3.2 Summary of the Guideline Trigger Values Adopted for this Assessment

The WQC selected from the review of literature and applicable to the relevant management goals are shown below in Table 3-1. No WQC have been derived in Australia for PFC however there are values available for a common type of hydrocarbons surfactants, i.e. Alcohol Ethoxylated surfactants (AE). A short summary of the key studies used to derive criteria from various agencies is provided in the following section. In most cases the key toxicological studies referenced in the reviews by the agencies have not been consulted as part of this review exercise.

Table 3-1 Summary of WQC adopted for Various Management Goals

CoPC Criteria Name

Criterion Value Source Measured

MediaProtection for

Management GoalLevel of

ProtectionHigh Reliability Guideline Trigger ValueAE FTV 140 μg/L ANZECC (2000) Water Aquatic Ecosystems 95%Medium Reliability Guideline Trigger ValuePFOS (6:2FTS) CCC 5.1 μg/L Giesy (2009) Water Aquatic Ecosystems 95%Low Reliability Guideline Trigger Value (Screening Values)PFOA CC 1,700 μg/L MPCA (2007a) Water Aquatic Ecosystems

Screening Values

only

PFOS MPCOral 37 μg/kg RIVM (2010) Diet (food)Mammalian species

PFOS ENEV 408 ng/g EC (2006) LiverPFOS MPCOral 330 μg/kg RIVM (2010) Diet (food) BirdsPFOS CCC 0.047 μg/L Giesy (2009 Water Piscatorial birdsPFOS SQG 67 μg/kg EA (2004) Sediment Aquatic EcosystemsPFOS PNECSoil 373 μg/kg EA (2004) Soil Soil compartmentNotes: FTV = Freshwater Trigger Value, PNEC = Practical No Effect Concentration, CCC = Criteria Continuous Concentration, CC = Chronic Criteria, MPCEco = Maximum Permissible Concentration Ecological, ACR = Acute to Chronic Ratio, ENEV = Estimated No Effect Value, SQC = Sediment Quality Guideline.

4 GUIDELINE TRIGGER VALUES FOR VARIOUS ENVIRNMENTAL COMPARTMENTS

4.1 Guideline Trigger Values for Aquatic Ecosystems

WQC are available for AE (ANZECC 2000); they are 50 μg/L, 140 μg/L and 360 μg/L for 99%, 95% and 80% levels of protection respectively. These WQCs are only suitable for AE and do not apply to other types of hydrocarbon surfactants or fluorosurfactants. WQC for other hydrocarbon surfactants are not discussed further.

Ecological criteria have been derived by various agencies overseas1 for a limited number of PFC including PFOS, PFOA and Perfluorobutane Sulfonic Acid (PFBS). The criteria derived span multiple orders of magnitude as shown in Table 4-1 below. This range is evident as a

1 Regulatory agencies include United States Environment Protection Agency (USEPA), Dutch Environment Agency (RIVM) and Environment Canada (EC).



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result of the methodology that was used by regulatory agencies to derive their criteria, the departure point selected (e.g. LC50, NOEC etc.) and/or the assessment factor (AF) that was applied. Ecological criteria shown in Table 4-1 were derived using either:

Acute and Chronic Toxicity Studies: A departure point is selected based on an acute effect (e.g. LC50 data), i.e. a Final Acute Value (FAV). An acute to chronic ratio (ACR) is then derived by making a comparison of effects from acute and chronic studies in the same species. If studies are insufficient to derive an ACR then a default value of 18 may be applied. The final chronic criteria is derived by multiplying the FAV by the ACR, i.e. Chronic Criteria = FAV × ACR. Note that the criteria derived by Giesy (2009) used statistical methods to determine a FAV and is considered a moderate reliability WQC.Chronic Toxicity Studies Only: A departure point is selected based on effects that impact a global population (e.g. 10d-NOEC for growth and survivability). An assessment factor is applied which is dependent on the number of studies available. These are considered low-reliability WQC and are suitable as screening criteria.

Table 4-1 Summary of WQC derived for Aquatic Ecosystems

Criteria Name Species Critical Effect Departure

PointAssessment Factor Value Source

PFOS

PNEC Pimephales promelas(Fathead minnow)

Growth (42-d NOEC) 300 (250) 10 30 EA

(2004)

CC Chironomus tentans(Midge)

FAV based on L(E) C50 (GMAV) 170 9.1 (ACR) 19 MPCA

(2007a)

CCC Various species FAVa based on L(E)C50 (GMAV)

42 8.3 (ACR) 5.1 Giesy (2009)

ENEV Chironomus tentans(Midge)

Growth and Survival(10-d NOEC) 49.1 100 0.49 EC

(2006)

MPCEcoChironomus tentans

(Midge)Total Emergence

(36d- LOEC) 2.3 100 0.023 RIVM (2010)

PFOA

CCC Daphnia magna(Water flea) 48-hour EC50 297,000 6.1 (Dataset)

17 (ACR) 2,900 Giesy (2009)

CC Daphnia magna(Water flea)

FAV based on L(E) C50 (GMAV) 31,000 18b (ACR) 1,700 MPCA

(2007b)

PNEC Gobiocypris rarus(Rare minnows)

Hormonal changes(28-d NOEC) 3,000 100 30 EC

(2010)PFBS

CCC Pimephales promelas (Fathead minnow) 96-hr LC50 1,938,000 8 (Dataset)

10 (ACR) 24,000 Giesy (2009)

Notes: PNEC = Practical No Effect Concentration, CCC = Criteria Continuous Concentration, CC = Chronic Criteron, MPCEco = Maximum Permissible Concentration Ecological, ACR = Acute to Chronic Ratio, ENEV = Estimated No Effect Value, FAV = Final Acute Value, SAV = Secondary Acute Value.a. FAV and SAV modelled using 5th percentile from four lowest acute values to give a 95th percentile value.b. Default value as no chronic data identified

The majority of criteria shown in Table 4-1 are predominantly screening criteria that have been derived to protect the most sensitive species identified. As discussed earlier, the relevant criterion for the protection of waterways in Victoria is dependent on the level of protection afforded a waterway, the location of the waterway and the amount of modification that has occurred to the waterway. This is ultimately a judgement for EPA.

The Criteria Continuous Concentration (CCC) derived by Giesy (2009) was derived to protect 95% of aquatic species, i.e. it was derived to “provide reasonable protection to ecologically and commercially important species under most circumstances such that overprotection or under-protection of aquatic species is avoided”. The CCC of 5.1μg/L was derived using FAV of 42μg/L



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(Geisy 2009) and by using an ACR of 8.3 determined from studies in 3 different species. The FAV was derived using statistical analysis (5th percentile) considering acute toxicity data from multiple studies and species and selecting the four lowest values for statistical analysis. This included data from a study (Macdonald 2004) which has identified the most sensitive species (Chironomus tentans). It was noted by Giesy (2009) that C. tentans is uniquely sensitive to PFOS by approximately 40 times compared to the next most sensitive species. Also, other midges were unaffected at much higher concentrations. The CCC derived is considered to be skewed low due to the reliance of the statistical method on the four lowest toxicity values rather than the whole dataset which was available. It is noted that the LOEC of 2.3μg/L determined by Macdonald (2004) and used by RIVM 2010 to derive the MPCEco was not selected as a departure point by Giesy (2009) for use in the statistical analysis. This is not specifically addressed by the author however EC (2006) have commented on the lack of confidence in longer exposures from the study by Macdonald (2004), i.e. “there is high confidence in the 10-day exposure values while the 60-day exposures should be treated with caution”. It is noted that the 10-day NOEC was selected by EC (2006) for derivation of their Estimated No Effect Value (ENEV) instead of the 36-day LOEC. The CCC derived by Giesy (2009) for PFOS is suitable for use as a WQC that offers a suitable level of protection for slightly to highly modified ecosystems, i.e. the waterways downstream of CFA Fiskville Training College.

A criterion derived by Giesy (2009) for PFOA (CCC = 2,900 μg/L) is three orders of magnitude higher than derived for PFOS (CCC = 5.1 μg/L). The CCC for PFOA is considered a low reliability WQC due to a lack of data. The CCC for PFOA included consideration of data from a study by Macdonald (2004) discussed above for PFOS including the most sensitive species, C. tentans. This species was not sensitive to PFOA as was seen for PFOS. This suggests that the functional group present impacts on the sensitivity seen for C. tentans to PFC. An assessment factor (AF) of 6.1 was applied to the lowest acute value (EC50 of 297,000μg/L in Daphnia magna). A much lower criterion for PFOA (PNEC = 30 μg/L) was derived by the EC (2010) from a chronic study in the Rare minnow. It is not clear whether the effects noted (e.g. liver hypertrophy) are indicative of a toxicological relevant endpoint for population dynamics and may not be predictive of population level effects required for deriving a PNEC. The PNEC is adopted here as a screening value WQC for PFOA as ecosystems downstream of Fiskville Training College are highly modified and PFOA has not been detected in water or sediment in the Moorabool River.

No criterion was identified for 6:2 FTS. A single criterion of 24,000 μg/L was identified for one other PFC with a sulfonic acid functional group, i.e. PFBS. This is also a low reliability criterion derived by Giesy (2009) in a similar manner to PFOA due to a lack of data. An AF of 8 (database deficiencies) and 10 (ACR) were applied to the lowest acute value (LC50 of 1,938,000 μg/L in Fathead Minnow). PFBS appears to have much lower toxicity than PFOS spanning multiple orders of magnitude. This suggests toxicity may be also related to chain length. The only publically available ecotoxicological information identified for 6:2FTS is from the supplier (Dupont 2012) and reproduced below in Table 4-2. This data was compared with information for PFOS which included a 90-d fish NOEC of 290 μg/L. It appears as though 6:2FTS is not as toxic to aquatic species as PFOS however the data source is considered low reliability as no information on how these ecotoxicological values were determined was provided. A criteria similar to a PNEC of 2.9μg/L could be calculated using an AF approach (AF = 100). This is lower than the WQC adopted for PFOS to protect 95% of species in a water body. The WQC selected for PFOS of 5.1 μg/L is adopted in this case for 6:2FTS to protect 95% of species. There is low confidence in adopting this value based on the information provided.



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Table 4-2 Summary of Ecotoxicological Data for 6:2FTSProperty 6:2 FTS PFOSAcidity 2 to 3 <1Fish LD50 >107 mg/L 78 mg/LInvertebrate LC50 > 109 mg/L 58 mg/LAlgae EC50 > 96 mg/L 48 mg/LFish 90-day NOEC 2.62 mg/L 0.29 mg/LBioaccumulative No Yes

Bioaccumulation and toxicity of PFC may increase with chain length for compounds with both sulfonic acid and carboxylic acid functional groups. Further review is required for selecting WQC for PFC other than those considered here (PFOS, PFOA, PFBS and 6:2FTS).

Conclusion on relevant WQC for aquatic ecosystems: The WQC adopted for various compounds to protect aquatic ecosystems are:

PFOS: The CCC of 5.1 μg/L is adopted as a 95% protection level for PFOS.6:2 FTS: The CCC for PFOS (5.1 μg/L) is adopted as a screening value for 6:2FTS.PFOA: The CCC of 1,700 μg/L is adopted as a screening value for PFOAAE: The FTV of 140 μg/L is adopted as a 95% protection level for AE.

4.2 Guideline Trigger Values for Mammalian Wildlife

Toxicity data from different 2 year studies in rat exposed to PFOS were used to derive criteria of 17 μg/kg ) in food (PNECOral, EA 2004) and 408 ng/g in liver of mammalian species (ENEV, EC 2006)2. An assessment factor approach was used to determine both these criteria. The PNECOral of 17 μg/kg in food derived by EA (2004) was based on the lowest NOEL identified in various mammalian studies of 500 μg/kg. This NOEL is based on liver hypertrophy and an AF of 30 was applied (note that the makeup of this AF used was not defined). A review by Exponent (2005) indicates that this PNECOral was not calculated appropriately as:

Liver Hypertrophy is not indicative of population based effects as required for deriving PNEC. Instead a NOAEL of 400 μg/kg/day from a reproductive rat study was selected as an appropriate departure point and converted to a NOEC of 8,000 μg/kg.The AF included a factor of 10 (assumed to be applied to account for apparent differences in body weight to daily food ingestion ratio) however this ratio was incorrectly calculated by EC (2004) and should not have been applied.

This PNECOral was recalculated to be 270 μg/kg based on a NOEC of 8,000 μg/kg and AF of 30. The AF of 30 was used as it represented a policy decision (Exponent 2005). RIVM (2010) derived a PFOS criterion (MPCOral) of 37 μg/kgbiota w/w for rabbit. The MPCOral is based on a NOAEL of 100 μg/kg/d (maternal weight gain) identified in a teratogenic study in New Zealand White Rabbit. It was converted to a NOEC by applying a ratio of 33.3 for body weight to daily food intake and an AF of 90 applied. Note that this is the lowest MPCOralderived by RIVM (2010) from multiple studies, multiple endpoints, 7 species and 26 different departure points (NOAEL range from 100 μg/kg/d to 5,000 μg/kg/d).

The ENEV of 408 ng/g (ENEV) in liver was based on histopathological effects in the liver at the lowest exposure concentrations (ranged from 0.06 to 0.023 mg/kg/day) which corresponded to an LOEL of 41,000 ng/g in the liver. An AF of 100 was applied to the LOEL

2 The toxicological studies referred to by EA (2004) and EC (2006) have not been consulted.



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(10x for laboratory to field extrapolation and 10x for intraspecies variability). Both these criteria are considered screening criteria only.

Conclusion on relevant WQC for mammalian wildlife: The ENEV of 408 ng/g in liver (EC 2006) and the MPCOral of 37 μg/kg in biota (food) (RIVM 2010) are adopted as screening level WQC for mammalian species.

4.3 Guideline Trigger Values for Birds

Criteria have been derived based on toxicity studies available for two bird species exposed to PFOS in their diet; the mallard (Anas platyrhynchos) and the bobwhite quail (Colinus virginianus). The criteria include values for PFOS levels in water, biota, bird serum and bird liver and are considered screening values as they were derived using the AF approach.

An MPCOral of 330 μg/kgBiota was derived for both the mallard and the bobwhite quail using a NOEC (1,490 μg/kg and 770 μg/kg respectively), converted using a body weight to dry food intake ratio (6.7 and13 respectively) and an AF of 30 (See Appendix 3, Table A3.1 of RIVM 2010). A Wildlife Value (WV) of 0.047 μg/L was derived for PFOS based on the LOAEL of 770 μg/kg in the quail, an uncertainty factor of 24 and bioaccumulation factor of 9,970 for level IV avian predator (Giesy 2009). Note that these criteria are based on the same study however the departure point is identified as a NOEC by RIVM (2010) and a LOAEL by Giesy (2009).

ENEVs were derived based on PFOS concentrations in serum and liver of birds by EC (2006) using the same species, the mallard and the bobwhite quail. Effects were noted at the lowest exposure concentration of 10ppm in male birds (increased testes size) and female Quails (increased liver weight). Survivability of hatchlings was also reduced but not statistically relevant for Quails exposed to 10ppm. Both the mallards and quail exhibited overt signs of toxicity at higher concentrations (50 ppm and 150ppm) and were euthanized early. An AF of 100 was applied (10x for laboratory to field extrapolation and 10x for intraspecies variability) was applied to level of PFOS in serum (87,000 μg/L) and liver (6,100 ng/g) of quails in the 10ppm exposure group to give an ENEV of 870 μg/L for serum and 610ng/g for liver. It was noted that PFOS levels in liver and serum of piscatorial water birds are amongst the highest reported values (EC 2006). A Screening Tissue Threshold of 885 ng/g was derived by Exponent (2005) using the same studies and AF approach. No data is available in this study for PFOS levels in liver or serum of birds.

Conclusion on relevant WQC for birds: The CCC of 0.047 μg/L in water derived for piscatorial birds (Geisy 2009) and the MPCOral of 330 μg/kg in biota (food) derived for bird (RIVM 2010) are adopted as screening level WQC for birds.

4.4 Guideline Trigger Values for Sediment

A criterion for sediment of 67 μg/kg (PNECSediment)was identified in EC (2004). This criterion is a Sediment Quality Guideline (SQG) that was calculated using the equilibrium partitioning method. Such a method is outlined in ANZECC (2000) to calculate SQG for non-ionic organic compounds. This method requires that a partitioning coefficient for PFOS from water to sediment (Kd) be calculated. A Kd cannot be calculated for ionic compounds such as PFOS however a measured value of 8.71L/kg is available (EC 2004). A SQG is calculated by multiplying a Water Quality Guideline (WQG) by the partitioning coefficient for PFOS (SQG = WQG × Kd). It is not clear how the PNECSediment of 67 μg/kg was calculated as PNEC for water is 25 μg/L therefore a SQC = 25 × 8.7 = 217 μg/Kg.

Using this same approach a SQG can be calculated using the 95% WQC of 5.1 μg/L (aquatic ecosystem) for PFOS in water derived by Geisy (2009). A SQG of 44 μg/kg (SQG = 5.1 μg/L ×



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8.7) was calculated which is similar to the value derived by EA (2004). It should be noted that Kd for ionic compounds such as PFOS is most likely related to surface chemistry of sediments (rather than organic content). The Kd for clays for example is closer to 33 L/kg (EA 2004). A SQG of 170 μg/kg would be calculated using the Kd for clay.

Conclusion on relevant WQC for sediment: The SQG of 67 μg/kg (EA 2004) is adopted as a screening level WQC for PFOS.

4.5 Guideline Trigger Values for the Soil Compartment

A PNECSoil of 373 μg/kg was calculated (EA 2004) based on a short term toxicity result in an earthworm. This criteria was derived by applying an AF of 1000 to the LC50 value of 373,000 μg/kg. A lower PNECSoil was calculated for lettuce of <39 μg/kg however lettuce is not likely to be grown in the Fiskville region. It is noted that this criterion could be up to 16 times higher based on a complete set of toxicity data that is available for biota (Exponent 2005). Conclusion on relevant WQC for soil compartment: The PNECSoil of 373 μg/kg for PFOS in soil (EA 2004) is adopted as the screening level WQC for the soil compartment.

5 CONCLUSIONA variety of WQC have been adopted for PFC and AE. The majority of WQC adopted are considered screening values, however two WQC were identified (PFOS and AE) that are considered protective of aquatic ecosystems with a 95% level of protection for water bodies downstream of CFA Fiskville Training College.

Cardno Lane PiperMarch 2014



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6 REFERENCES1. ANZECC (2000) Australian and New Zealand Guidelines for Fresh and Marine Water

Quality. National Water Quality Management Strategy. Australian & New Zealand Environment & Conservation Council and Agriculture & Resource Management Council of Australia and New Zealand.

2. Cardno (2014). Aquatic Ecology Assessment, Fiskville Training College. Cardno Ecology Lab, March 2014.

3. Ecos (2013). Quantitative Microbial Risk Assessment (QMRA) for Occupational Exposure to Recycled Water during Fire fighter Training. Ecos Environmental Consulting Pty Ltd, February 2013.

4. CCMA (2009). Evaluation of the 80ML Environmental Flow Release from Lal Lal Reservoir to the Moorabool River. January 2009. Corangamite Catchment Management Authority.

5. Dupont (2012). Dupont Surface Protection Solutions. DupontTM Capstone® Repellant Surfactants, Product Stewardship Detail. Dupont. Last accessed on 25 June 2013 at; http://www2.dupont.com/Capstone/en_US/assets/downloads/K-20614-3_Capstone_Stewardship_Detail_Brochure.pdf

6. EA (2004). Environmental Risk Evaluation Report for Perfluorooctanesulphonate (PFOS). Environment Agency, United Kingdom.

7. EC (2006). Ecological Screening Assessment Report on Perfluorooctane Sulfonate, Its Salts and Its Precursors that Contain the C8F17SO2 or C8F17SO3, or C8F17SO2N Moiety. June 2006. Environment Canada.

8. 1. EC (2010). Draft Screening Assessment Perfluorooctanoic Acid, its salt, and its Precursors. October 2010. Environment Canada.

9. Exponent (2005). Technical Review oand Reassessment of the Environmental Risk Evaluation Report for Perfluorooctanesulphonate (PFOS). Prepared by Exponent for 3M company.

10. Giesy, J.P., Naile, J.E., Khim, J.S., jones, P.D. and Newsted, J.L. (2010). Aquatic Toxicology of Perfluorinated Chemicals. Reviews of Environmental Contamination and Toxicology. Volume 202, Pages 1 to 52.

11. MacDonald, M.M., Warne, A.L., Stock, N.L., Mabury, S.A., Soloman, K.R., Sibley, P.K. 2004. Toxicity of perfluorooctane sulfonic acid and perfluorooctanoic acid to Chironomus tentans. Environmental Toxicology and Chemistry. Volume 23, Issue 9, Pages 2116 to 2123.

12. MCPA (2007a). Surface Water Quality Criterion for Perfluorooctane Sulfonic Acid. STSProject 200604796. August 2007. Minnesota Pollution Control Agency.

13. MCPA (2007b). Surface Water Quality Criterion for Perfluorooctanoic Acid. STS Project 200604796. August 2007. Minnesota Pollution Control Agency.

14. RIVM (2010). Environmental Risk Limits for PFOS. A Proposal for Water Quality Standards in Accordance with the Water Framework Directive. report 601714013/2010. National Institute for Public Health and The Environment. RIVM, the Netherlands.


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