RAAF Base East Sale PFAS MANAGEMENT AREA …...The Defence Estate Strategy 2016-2036 and the Defence Environmental Strategy 2016-2036 each provide strategic direction for the management

RAAF Base East Sale PFAS MANAGEMENT AREA PLAN

August 2018

PFAS MANAGEMENT AREA PLAN – RAAF Base East Sale

Contents

GLOSSARY ............................................................................................................................................ 5

1 INTRODUCTION ............................................................................................................................. 6

1.1 Purpose ................................................................................................................................... 6

1.2 Application ............................................................................................................................... 6

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

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

1.3.2 The nature of PFAS ........................................................................................................ 7

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

1.4.1 PFAS National Environmental Management Plan .......................................................... 8

1.4.2 Defence estate and environmental management ........................................................... 8

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

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

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

1.7 Implementation process ........................................................................................................ 11

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

1.7.2 Procurement phase ....................................................................................................... 12

1.7.3 Implementation timelines .............................................................................................. 12

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

1.8 Roles and responsibilities ..................................................................................................... 13

1.9 Constraints and assumptions ................................................................................................ 14

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

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

2.2 Management Area setting ..................................................................................................... 17

2.2.1 Climate .......................................................................................................................... 17

2.2.2 Topography ................................................................................................................... 17

2.2.3 Surface Water ............................................................................................................... 17

2.2.4 Flora and Fauna ............................................................................................................ 20

2.2.5 Regional Geology .......................................................................................................... 20

2.2.6 Local Geology ............................................................................................................... 21

2.2.7 Regional Hydrogeology ................................................................................................. 24

2.2.8 Local Hydrogeology ...................................................................................................... 24

2.3 Management Area scale ....................................................................................................... 25

2.4 Extent of contamination ......................................................................................................... 26

2.4.1 Potential PFAS Source Areas ....................................................................................... 26

2.4.2 Potential PFAS Pathways and Receptors ..................................................................... 27


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2.4.3 Nature and Extent of PFAS Impacts ............................................................................. 27

2.5 Water use .............................................................................................................................. 30

2.6 Relevant legislation and government policy .......................................................................... 31

2.7 Stakeholders ......................................................................................................................... 32

3 PMAP METHODOLOGY AND APPROACH ................................................................................. 34

3.1 Overview of approach ........................................................................................................... 34

3.2 Identify risks and consequences (Chapter 4) ........................................................................ 34

3.3 Prepare Ongoing Monitoring Plan (Chapter 5) ..................................................................... 34

3.4 Develop risk management options (Section 6.1) .................................................................. 34

3.5 Detailed options analysis (Section 6.2) ................................................................................. 35

3.6 Integrated options analysis (Section 6.3) .............................................................................. 35

3.7 Recommendations Analysis .................................................................................................. 36

4 IDENTIFIED RISKS AND CONSEQUENCES .............................................................................. 37

4.1 Source / pathway / receptor analysis .................................................................................... 37

4.2 Risk listing and consequences .............................................................................................. 46

5 ONGOING MONITORING PLAN .................................................................................................. 54

5.1 Overview ............................................................................................................................... 54

5.1.1 Objective and purpose .................................................................................................. 54

5.1.2 Impacted decisions ....................................................................................................... 54

5.1.3 Related documentation ................................................................................................. 54

5.2 OMP communications ........................................................................................................... 55

5.3 OMP summary ...................................................................................................................... 55

5.4 OMP review ........................................................................................................................... 55

6 OPTIONS IDENTIFICATION AND ANALYSIS ............................................................................. 56

6.1 Options identification ............................................................................................................. 56

6.1.1 Method .......................................................................................................................... 56

6.2 Options analysis .................................................................................................................... 57

6.2.1 Screening Results ......................................................................................................... 57

6.3 Comparative analysis ............................................................................................................ 58

6.4 Integrated options analysis outcomes ................................................................................... 70

7 RECOMMENDED PMAP RESPONSE ACTIONS ........................................................................ 75

7.1 List of recommended PMAP response actions ..................................................................... 75

7.2 Comparative PMAP implementation timeframes .................................................................. 76

8 REVIEW AND UPDATE ................................................................................................................ 77

TABLES ................................................................................................................................................. 78

FIGURES .............................................................................................................................................. 79

APPENDIX A: Regulatory and policy analysis .................................................................................. 80

APPENDIX B: Interim response management analysis ................................................................... 84


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APPENDIX C Source – pathway – receptor analysis ...................................................................... 85

APPENDIX D Options analysis criteria ............................................................................................ 86

APPENDIX E Options listing and analysis ....................................................................................... 89

APPENDIX F Ongoing monitoring plan ........................................................................................... 90

APPENDIX G References ................................................................................................................ 91


5 August 2018

GLOSSARY

Base A defined physical locality or geographical area from which Defence-

related activities, operations, training or force preparations are managed, conducted, commanded or controlled.

DSI Detailed site investigation as identified in section 1.1.1

Extended implementation period

Period when PMAP response actions are required beyond the primary implementation period. These actions may include ongoing: • monitoring, leachate management, and maintenance of stockpiles • monitoring of Management Area for PFAS • assessment of developments and technologies for application to

stockpiled PFAS impacted soils and materials

HHERA Human Health and Ecological Risk Assessment

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

Monitoring Area The geographical area subject to Defence ongoing monitoring actions as described in Section 5 and Appendix F.

Off-site Off-Base

On-site On-Base

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

Primary implementation period

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

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

PWC Public works committee

Relative risk reduction benefit

Level of risk reduction likely to be achieved relative to implementation effort (based on technical, logistical and financial considerations).

Remediation Action Plan (RAP)

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

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

Response Management Strategy (RMS)

The Defence PFAS Response Management Strategy

Risk assessment(s) The HHERA described in section 1.1.1

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


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1 INTRODUCTION

1.1 Purpose

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

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

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

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

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

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

1.2 Application

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

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

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

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

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

1.3 Background

1.3.1 PFAS and its use

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


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

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

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

1.3.2 The nature of PFAS

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

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

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

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

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

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

1.4 Policy context

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

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


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1.4.1 PFAS National Environmental Management Plan

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

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

1.4.2 Defence estate and environmental management

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

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

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

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

risks.

1.4.3 PFAS Response Management Strategy

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

PFAS Management Area Plan (PMAP) template and guidance

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

PFAS Interim Response Management (IRM Guidelines)

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

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


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PFAS Construction and Maintenance Framework

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

Figure 1 below sets out a strategy and implementation map for Defence PFAS Response Management.

Figure 1: Defence PFAS response management and implementation map

Figure 2 at the end of this chapter presents the site-management process and the roles of the PMAP and related project documentation.

1.5 Scope

The PMAP relies on:

• the detailed site investigation (June 2017) conducted by Senversa, and

• Final Human Health and Ecological Risk Assessment (HHERA) (May 2018) conducted by Senversa.

to inform risk identification and weighting for the Management Area. The key parameters for the PMAP are set out below.

Management Area The Management Area incorporates the RAAF Base East Sale property (including an area to the east and southeast leased for livestock grazing). It also includes a Monitoring Area that incorporates private properties to the south and southeast of the RAAF Base, and The Heart Morass wetlands (including private and publicly managed land). The extent of the proposed Management Area and Monitoring Areas is shown in Figure 3 (attached). Further explanation of the establishment of the Management Area is provided in Section 2.1.


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Issue/risk identification Sourced from the Final HHERA and identified as ‘elevated’ risk or equivalent, which includes: • Home consumption of recreationally caught fish or ducks caught

from The Heart Morass, or public consumption of fish caught from within The Heart Morass in the vicinity of the Eastern Main Drain.

• Human consumption of meat, milk or offal (at high frequency home consumption scenario) from livestock raised on-Base into which PFAS has bioaccumulated. This is different to livestock raised off-Base where the risk was assessed to be a low and acceptable.

• Exposure of aquatic ecological receptors within on-site surface water, open drains and The Heart Morass, and to higher order predators consuming these biota.

Issue/risk range Unrestricted: incudes health, environmental and community issues

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

Remediation technology status

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

1.6 Guiding principles

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

• whether an option is proportional to risks

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

• views of the affected community and the jurisdictional regulator

• availability of best-practice management systems, treatments and technologies

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

• effectiveness and validation status of technology

• success measures for the treatment or remediation outcomes

• the need for ongoing operations, management, maintenance or monitoring

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

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

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

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

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

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

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


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

1.7 Implementation process

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

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

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

1.7.1 Approvals

a) Higher value public works

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

• urgency

• for defence purposes where that scrutiny could be contrary to the public interest, or

• for projects of a repetitive nature.

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

• approval to proceed

• approval to proceed, subject to specific conditions or requirements

• Committee deliberation postponed, pending further information, or

• Committee resolution to seek a referral.

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

b) Site Selection Board

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

4 Public Works Committee Act 1969, sections 18(8) and 18(8A)


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

1.7.2 Procurement phase

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

1.7.3 Implementation timelines

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

The PMAP is divided into two implementation periods:

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

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

monitoring, leachate management, and maintenance of stockpiles

monitoring of the Management Area for PFAS

ongoing operation of remediation technologies (e.g. a water treatment plant), as required

assessment of developments and technologies for application to stockpiled PFAS impacted soils and materials.

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

the primary implementation period

the extended implementation period, or

both the primary and extended implementation periods (e.g., monitoring of the Management Area for PFAS).

1.7.4 A living document

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

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

This document will be reviewed and updated every six months for the first year, then annually (or earlier if required). As implementation of the PMAP progresses, detailed plans supplementary to this

5 http://www.defence.gov.au/EstateManagement/lifecycle/SiteSelection/Task4.asp


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PMAP will be prepared (as required) to address the individual management actions that have been identified in this PMAP.

1.8 Roles and responsibilities

Roles PFAS Management Responsibilities

Capital Facilities Infrastructure (CFI)

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

Defence Environmental and Sustainability Officers including ADES, RESO, REO

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

• Review relevant Construction Environmental Management Plans.

• Approve Environmental Clearance Certificates & Remediation Action Plans.

Environment and Engineering Branch

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

• Approve construction and maintenance project specific documentation.

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

Lead Consultant • Contracted to Defence to prepare the PMAP

PFAS Investigations Management Branch (PFASIM)

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

• Provision of Defence and whole of government PFAS related policies.

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

Project Manager/Contract Administrator (PMCA)

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

• Holds pertinent project and contract documentation.

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

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


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Roles PFAS Management Responsibilities

Service Delivery Division and its contactors (SDD)

• Maintenance projects delivered by base service EMOS contractors.

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

• Deliver some medium works projects

State/Territory environmental regulator

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

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

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

1.9 Constraints and assumptions

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

• Current limited proven technologies for treatment and destruction of PFAS.

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

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

• Current regulatory management actions will remain in place (e.g. consumption advisory notice for fish, eels and ducks taken from The Heart Morass), and other off-site management actions that may also be implemented by Regulatory Agencies.


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Figure 2: Defence PFAS management process and indicative timeline


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2 PROFILE OF THE MANAGEMENT AREA

2.1 Management Area description

The RAAF Base East Sale is in the Gippsland region of Victoria, approximately 220 km southeast of Melbourne and approximately 5 km east of the centre of Sale (Figure 3).

The East Sale Base is an active major RAAF Base, airport and training centre and supports a capacity of approximately 700 personnel. The site is 8 km2 (800 ha) in area and includes a range of land uses that are ancillary to the aerodrome and aircraft support areas, such as accommodation, childcare facilities, recreation areas, cleared open space and leased grazing land. It will continue to be used as a RAAF Base, airport and training school for the foreseeable future. Significant upgrades to site facilities are currently underway to accommodate proposed growth of the training school.

The Base is commonwealth land located in a rural area east of Sale township, with all land surrounding the Base zoned ‘Farming (FZ)’ in the Wellington Shire Council municipality. The surrounding land is used principally for dairy farming (and associated pasture irrigation), but also cattle (beef) grazing and associated rural residential uses.

The Base is located in an environmentally sensitive area, close to wetlands of ecological significance, including The Heart Morass to the south, and the Gippsland Lakes RAMSAR site at Lake Wellington to the east (Figure 3). Drainage from the site leads to these areas (Figure 4).

The Heart Morass is also located between two areas of the Gippsland Lakes RAMSAR wetlands, which are wetlands considered to have significant ecological value. In addition, this area is used as a game reserve for duck hunting, fishing, and other recreational purposes and is highly valued by the community.

The region generally, and specifically the wetlands to the south and lakes systems to the east, are culturally significant for the local indigenous community.

The Management Area includes the Base, 13 private properties and The Heart Morass (which incorporates six of the private properties and public land). The boundary of the Management Area (Figure 3) was determined by the findings of the HHERA, the potential risks (with currently incomplete pathways) requiring monitoring or further investigation outlined in the DSI and analysis of both surface water discharge from site and groundwater flow direction (generally to the southeast) from likely source areas or impacted boundary monitoring wells.

The Management Area incorporating private properties to the east and southeast is defined as a Monitoring Area, as there is currently low and acceptable risks to off-site land based private properties, and may be revised with further investigations of the extent of shallow and deeper groundwater impacts in this area or based on results of ongoing monitoring. The outer extents have generally been aligned with property boundaries (i.e. straight line boundaries in some cases) where there is uncertainty of the nature and extent of groundwater impacts off-base in these areas and therefore includes a conservative consideration of the potential for future impacts from migration of PFAS from the base. Based on groundwater flow directions and flow velocity, PFAS impacts would not expect to currently be present beyond this area, if present at all on these properties.

Private properties incorporating the waters of The Heart Morass are included as a Monitoring Area due to the potentially elevated risks for human consumption of aquatic animals in this area and to the ecosystems.


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2.2 Management Area setting

The following sections provide a summary of the Management Area environmental setting. Further detail is provided within Section 3 of the DSI report (Senversa, 2017).

2.2.1 Climate

West Gippsland is classified as a Mediterranean climate, with highest temperatures and lowest rainfall during summer, however frequent coastal depressions create a milder climate and more evenly distributed annual rainfalls across the south of the region (DEDJTR, 2015).

The East Sale mean annual rainfall is approximately 600 mm, which falls relatively evenly throughout the year (ranging from a long-term average of 40 mm in July to 63 mm in November) (BoM, 2016). Significant rainfall events causing localised flooding are relatively common and can occur at any time of the year.

Annual average wind directions are predominately westerly in the morning, and either westerly or easterly to south-easterly in the afternoon. The afternoon winds are predominantly westerly during winter and spring (May-October) and easterly to south-easterly in summer (December-March) (BoM, 2016).

2.2.2 Topography

The site and surrounds are low lying and generally flat, with the elevation ranging from approximately 11 m AHD (metres Australian Height Datum) in the west and northwest of the site to 3 m AHD in the east and northeast.

The surrounding agricultural area is generally also flat, with a slight gradient towards Lake Wellington to the east of the site. To the south of the site there is an abrupt drop in elevation of approximately 3-4 m into the wetlands of The Heart Morass, providing a clearly defined boundary between the geomorphology of the agricultural lands and the wetlands.

2.2.3 Surface Water

Catchment Drainage

The site is located in the ‘Gippsland Lakes and Hinterland’ landscape priority area within the West Gippsland region (WGCMA, 2012). The major rivers across the broader West Gippsland catchment drain towards this low lying area, with the confluence of the Thomson and Latrobe Rivers to the south of Sale township at the Sale Common. The Latrobe River drains east from the Common into Lake Wellington and ultimately the Southern Ocean. Groundwater and surface water across the catchment generally drains from west to east, towards the Gippsland Lakes.

Environmentally Significant Surface Water Bodies

The Heart Morass wetlands are located approximately 500 m to the south of the site (see Figure 3). The Heart Morass includes 1,125 hectares of land covered by a protective covenant, with the eastern portion a State Game Reserve managed by Parks Victoria. The Latrobe River runs adjacent to the wetlands, with the river and wetlands draining into Lake Wellington approximately 4 km east of the site. The Dowd Morass wetlands are located directly south of the Latrobe River and the Sale Common wetlands are located to the east of the confluence of the Thompson and Latrobe Rivers.

The Heart Morass was historically significantly degraded due to widespread clearing, heavy grazing, poor water management, acid sulphate soils and salinity impacts, resulting in the wetland drying completely for the first time in 2006 (WGCMA, 2016). Rehabilitation of the area has occurred since 2006, with a subsequent improvement in the health and function of the local ecology. The Heart


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Morass is also located between two areas of the Gippsland Lakes RAMSAR wetlands, which are wetlands considered to have significant ecological value. In addition, this area is used as a game reserve for duck hunting, fishing, and other recreational purposes and is highly valued by the community.

Site Open Surface Drainage Network

There are a number of closed (concrete lined) stormwater drains in developed areas of the base which ultimately become open, unlined drainage channels that generally follow the topography of the site and divert surface runoff across and off the site to the south, north and east. The alignment of these drainage lines is shown on Figure 4. Generally, surface water diverts around the runways, discharging to the north and east from the northern boundary, and to the south from the southern site boundary. Stormwater captured across the majority of operational areas is generally diverted southwards along three engineered open drains and the principle drainage discharge point is at the south-eastern boundary to The Heart Morass (Figure 4). The three main drainage lines comprise:

• Eastern “main” Drain: This originates in the north of the site from the eastern end of the airfield where it is shallow and then deepens to 4-5 m as it runs north-south in the eastern portion of the site, where ultimately it discharges in the south-eastern corner of the site to The Heart Morass. The Eastern Drain aligns with a natural former unnamed creek that is evident on historical site geology maps.

• Western Drain: This originates in the northwest from the Base facilities and operational areas and is generally between 1-2 m deep and concrete lined at its base until approximately the golf course area (Figure 4). Drainage runs in an unlined channel to the southern boundary where water accumulates in a recently constructed stormwater retention pond as part of recent drainage upgrade works in this area (2016), which now divert all surface water east in a concrete lined culvert to converge with the Eastern Drain. It is noted from site observations and discussion with Base personnel that the Western Drain previously discharged at the intersection with the southern boundary off-site into an overflow drain and then through the adjacent agricultural land (now a dam is present), before draining to The Heart Morass.

• Central Drain: The Central Drain system is located south of the airfield and drains central areas towards the retention pond and Western Drain. The Central Drain system predominantly consists of an unlined open channel that ranges in depth from 0.5m to 2 m deep.

To the north of the runways, stormwater drainage flows north and discharges off-site into stormwater drains along Cobains Road, with the stormwater travelling towards the low lying areas east of the site, and ultimately to Lake Wellington beyond. There is also a number of shallow stormwater drainage lines present on the site that drain to the Western, Central or Eastern Drain. Shallow drainage alignments are present in the northeast corner and in the east that could act as pathway for off-site surface water migration in times of high flow.

The water within the drainage lines on-site is not known to be collected or used for any purposes such as irrigation or stock watering.

Site Closed Stormwater Network

A below ground formal network of stormwater drains is present across the operational areas in the west of the site (Figure 4). This network captures stormwater from sealed areas of the site, with drains observed to be present in a number of key legacy AFFF usage and storage areas. These include warehouses and maintenance areas, fire stations, chemical storage areas, roadways, and paved areas where fire trucks were parked, filled with AFFF and maintained.


19 August 2018

The below ground closed stormwater drainage network ultimately discharges off-site via the main open surface drains.

Surface Water Features

There are several areas of inundation in low lying areas in the southern and eastern portions of the site that likely collect surface water run-off during high rainfall events. The Eastern Drain, which is inferred to intersect shallow groundwater corresponds with the location of a former creek system identified as the only on-site surface water on the surface geology map for the site. There are also inundation features to the west of the site associated with a former creek system that flowed into The Heart Morass.

Irrigation Channel Network

The site is located within the Macalister Irrigation District (MID), the largest irrigation area south of the Great Dividing Range, which supplies water to central Gippsland via a large, formal network of irrigation channels and associated infrastructure. The MID comprises a gravity fed irrigation network that feeds water sourced from Lake Glenmaggie to the ‘farm gate’, where it is directed by individual properties into their on-farm irrigation systems (SRW, 2016). The MID district is dominated by dairy cattle but in some areas supports horticulture, beef cattle and cropping. The irrigation season in the Sale area runs from August to May, with the water used primarily for irrigation of dairy pasture and some other incidental uses such as stock watering.

The site is at the south-eastern edge of the MID, and the network does not extend to properties on the east or southeast of the site where bore water is relied on for irrigation.

Dams

No significant dams or surface water storage bodies are present on-site.

A number of private dams are present on properties surrounding the site, with the majority of these dams being unlikely to receive water from the site. A large off-site dam located to the south of the site previously received surface water draining from the site, however, drainage line upgrade works (as discussed above) have diverted this pathway, with site surface water now diverted to the Eastern Drain prior to off-site migration. This off-site dam to the south also appears to have been upgraded recently, and is filled with groundwater from an extraction bore on the property.

Artificial Lakes

Two small artificial ornamental lakes are located at the on-site golf course which do not permanently contain water. One larger ornamental lake directly north of the current fire training area (Source ID 13 on Figure 4) is located at the eastern end of the golf course and is fed by a fire hydrant. From information provided by the Base, water from this lake is not used for any purpose, however, has been used historically to irrigate the golf course.

Lake Edwards, located to the south of the site entrance, was formerly a quarry created when the Base was constructed which was subsequently filled with waste derived from on-site (SMEC, 2005). The lake was anecdotally reported as being used for swimming and recreational purposes prior to being drained over 10 years ago due to safety concerns, with the area remaining fenced off. The lake can fill during periods of high rainfall such as during the DSI groundwater sampling, but is dry for the majority of the year, indicating the invert level is too high to receive shallow groundwater in this area.


20 August 2018

2.2.4 Flora and Fauna

A flora and fauna survey of the Base (Kinhill Environmental Services, 1999) identified significant Gippsland red gums (Eucalyptus tereticornis) approximately 120 to 250 years of age at the site. The Gippsland Red Gum Grassy Woodland and associated Native Grassland ecological community is listed under the EPBC Act with a ‘Critically Endangered’ status (DoE, 2016). The trees provide habitat for a number of species, including possums, bats and various birds (including Barn Owls, Tawny Frogmouths, Southern Boobook Owl and sulphur crested cockatoo’s) (Kinhill Environmental Services, 1999). Grasses across the site were a mix of native and introduced species.

Off-site ecological communities of significance include the wetlands associated with the Heart Morass and Gippsland Lakes to the south and east, respectively. The Heart Morass to the south is a permanent, freshwater marsh, which supports significant breeding populations of waterbirds, including duck species targeted for hunting for human consumption.

Lake Wellington is a permanent, deep, saline wetland which is listed as a Wetland of International Importance under the EPBC Act (DoE, 2016). It supports populations of resident and migratory waterbirds, both common and threatened, with identified threatened species. The Lake is fringed by extensive strands of endangered Swamp Scrub, which provide fish habitat and are valued for commercial and recreational purposes (WGCMA, 2012).

2.2.5 Regional Geology

The regional geology at the site indicates that the site is situated on an outcrop of Tertiary aged fluvial sands, ferruginous sands, silts and gravels of the Pliocene aged Haunted Hills Formation. The stratigraphy generally comprises:

• Regional surface geology is predominated by Quaternary deposits made up of Pleistocene alluvial floodplain deposits of gravel, sand, silt and clay, moderately sorted and poorly consolidated.

• These ‘Alluvial Terrace Deposits’ are generally comprised of porous sand and gravel beds deposited along the river valley and flood plains of the nearby Thomson and Latrobe Rivers (SRW, 2012). The base of these River Terrace Deposits are generally gravels, with these coarse materials grading to sediment with decreasing grain size at the top of the deposit.

• The uppermost alluvial deposits are underlain by the Tertiary Haunted Hill Formation which is a thin, widespread mantle of Pliocene to Pleistocene fluvial and lacustrine sediments. The sediments comprise mottled and sometimes ferruginous clay, sandy clay, sand, gravel and clayey sand.

• The Boisdale Formation underlies the Haunted Hill Formation and comprises an upper clay unit (Nuntin Clay) and a lower sand unit (Wurruk Sand). The Nuntin Clay consists of pale brownish-grey to medium brown and medium grey clay, gravel, fine-grained to coarse-grained sands and minor ligneous clay. The Wurruk Sand consists of grey, medium-grained to coarse-grained sub-rounded to sub-angular quartzose sand.

• The Boisdale Formation and Haunted Hill Formation make up the Sale Group unit, which at Sale have a combined thickness of 260 m.

• More recent quaternary lagoon and swamp deposits in the form of silts and clays are associated with the wetlands and Latrobe River to the south of the site. These consist of grey to black carbonaceous mud, silt, clay and minor peat that is generally unconsolidated.


21 August 2018

Further to the shallow regional geology described above, the swamp deposits in the Heart Morass are also known to be acid sulphate soils. The coastal acid sulphate soil maps available from the Department of Economic Development, Jobs, Transport and Resources (DEDJTR) (2016) and CSIRO (2008) indicate that the Heart Morass has a high probability of acid sulphate soil presence while the site has a low probability. As there is evidence of alluvial floodplain deposits and Boisdale Formation sediments, if exposed and oxidised, the lithology present at the site may have potential acid sulphate soil properties.

2.2.6 Local Geology

The majority of the DSI intrusive locations, and the previous investigation at the site targeted the shallow Quaternary-aged flood plain and quaternary alluvial terrace deposits (0 – 6 m bgl - clays, silts and clayey sands). Several DSI locations targeted the quaternary Lower Alluvium (approximately 7-10 m bgl) and the Quaternary-aged sediments of the Haunted Hills Formation (10-15 m bgl - silty sands, sands and gravelly sands) as well, with one location advanced to the top of the Boisdale Formation (Nuntin Clay – 36 m bgl).

The Macalister Irrigation District Soil Permeability Map (SKM, 2001) indicates that a majority of the site is within a moderate to high permeability plain, with very low permeability units present on the eastern boundary portion of the site and in the southwestern portion of the site.

The following table summarises the general sub-surface soil conditions encountered across the site during the DSI.

Summary of Soil Conditions Encountered

Approximate Depth Range (m bgl)

Unit / Material Lithological Description

0.0 – 0.05/0.1 Grass/Topsoil/ Crushed Rock/ Concrete / Asphalt

Grass and topsoil were encountered at most grid based surface soil sample locations in the open space and grazing lease areas. Some areas were covered by a thin profile of crushed rock. Concrete surface slab or asphalt surface cover was present at three locations. Topsoil was observed as soil directly below the grass surface cover and generally consisted of: Fill (topsoil): Brown, sandy silt with fine grained sand, trace clay and roots. Uniformly graded, rounded sand.

0.0 – 1.0 Fill Fill: Brown/yellow brown/red brown, sand/ silty sand / sandy gravel / sandy silt with minor to trace angular gravel, silt and clay. Anthropogenic material observed at 25 of the 412 locations included trace fine brick fragments, concrete fragments, glass, plastic, wood, metal, material, ash, bitumen and terracotta.


22 August 2018



0.1 – 5.0 to 7.0 Upper Alluvium The Upper alluvium consists of interbedded silts, sand and clays. The following lithologies were present in this general order from shallow to deep. Clayey SILT/ Silty CLAY: Low to medium plasticity brown, yellow brown and red brown silty clay/clayey silt with trace fine grained sand. Uniformly graded, rounded sand. SILT: Non-plastic Orange-brown mottled brown and light grey, soft, silt with minor fine sand with trace clay. Uniformly graded, rounded sand. Clayey SAND/ Sandy CLAY: Low plasticity. Brown to light brown and grey, soft, clayey sand/ sandy clay. Uniformly graded, fine grained, well rounded sand. Sandy SILT/Silty SAND: Brown mottled light brown, orange, yellow and grey, fine grained silty sand/sandy silt with trace clay. Uniformly graded, rounded sand. CLAY: Low to high plasticity clay, brown mottled yellow and red brown, trace silty and fine grained sand.

5.5 – 10 to 12 m Lower Alluvium The unit was separated from the Upper alluvium by a 1-2 m thick clay or silty clay unit. The Lower alluvium consisted of the following lithologies. Silty CLAY/ Clayey SILT: Low plasticity to non-plastic. Light brown mottled blue-grey, yellow and orange stiff, silty clay with trace fine grained sand. Uniformly graded, rounded sand. Silty/Clayey SAND: Low plasticity. Brown mottled orange, yellow and grey, silty/clayey sand. Uniformly to gap graded, rounded sand. SAND: Brown, fine to medium grained sand with trace silt and clay. Uniform to gap graded, rounded sand.


23 August 2018



10 – 36+ m Haunted Hills Formation The Haunted Hills Formation was separated from the alluvium by a 2-5 m thick silty clay and clay layer (likely aquitard) and consisted of the following additional thickly interbedded lithologies. Clayey SAND/Sandy/Silty CLAY: Low to Medium plasticity, brown mottled grey, firm sandy clay/clayey sand with fine to medium grained sand. Uniformly to gap graded, rounded sand. Sandy GRAVEL: Non-plastic. Orange-brown to pale grey-brown, fine to coarse grained sandy gravel and cobbles with minor fine to coarse grained sand, trace silt and clay. Well graded, rounded sand and gravel. Silty CLAY: Medium plasticity, dark grey, firm. SAND: Dark grey, medium to coarse grained sand. Gap graded, sub-rounded sand. Silty SAND: Brown mottled grey-orange, fine grained silty sand with trace clay. Uniformly graded, rounded sand

+36 m Nuntin Clay (Boisdale Formation)

The Nuntin Clay Member of the Boisdale Formation was inferred to have been encountered at one location and consisted of medium to high plasticity silty clay, dark grey, firm, with trace fine grained uniformly graded, rounded sand. The Nuntin clay is known regionally as an aquitard between the Haunted Hills Formation and Wurruk Sands member.

The site lithology encountered confirms the presence of interbedded alluvial deposits (clays, silts and sands) likely associated with alluvial flood plains, palaeochannels and oxbow lakes.

Surface coverage varied across the site based on different site area uses. Leased grazing areas and open space exhibited grass surface coverage while populated areas had a combination of bitumen, concrete and crushed rock coverage.


24 August 2018

2.2.7 Regional Hydrogeology

The Gippsland hydrogeology is described in the Gippsland Groundwater Atlas (SRW, 2012), Hydrogeological Mapping of Southern Victoria (SRW, 2009) and the Geology of Victoria (Leonard, J, 2003); these reports indicate the following hydrostratigraphic sequence is likely to be present beneath the site, with an indication of hydrogeological properties:

• Alluvium Terrace Deposits & Haunted Hills Formation: Low productivity minor aquifer to aquitard.

• Nuntin Clay (upper Boisdale Formation): Aquitard.

• Wurruk Sand (lower Boisdale Formation): Important high productivity regional aquifer.

• Lake Wellington Formation: Aquitard to (very) minor aquifer.

• Gippsland Limestone Formation: Minor to poor aquifer.

• Lakes Entrance Formation: Basal sand and gravel sequence is an aquifer; the overlying mudstone and marl is an aquitard.

• Traralgon Formation: Interbedded coal sand and clay - confined to leaky confined aquifer system.

The hydrogeological units that are considered to be relevant to the PFAS investigations are the Alluvium and Haunted Hills Formation and the Boisdale Formation.

Regional groundwater is known to be used for domestic and agricultural purposes (principally irrigation for dairy pasture and stock watering), with the Sale township and site also supplied by water from production bores within the Boisdale Formation (Wurruk Sand Aquifer). The on-site water is partially supplied from an on-site groundwater bore installed to 115 m (Woodward Clyde, 2000) in the Wurruk Sand Aquifer of the Boisdale Formation.

2.2.8 Local Hydrogeology

The complexity of the geology and hydrogeology at the site controls the movement of groundwater in the area. There are three main shallower water bearing zones that were assessed as part of the DSI. A thick, impervious clay layer separates these three shallower units from the deep, regionally significant groundwater unit that supplies drinking water in the region.

The hydrogeological units encountered at the site during previous investigations and DSI works include the hydrogeological units in the following summary table.

Site Lithology Encountered Summary

Hydrogeological Unit Depth Range (m bgl)

Approximate Groundwater Level Range (m bgl)

Unit Description

Upper Alluvium Aquifer

0-6 1 – 5.5 (average: 2.8) Interbedded silt, sand and clay, with occasional gravels.


25 August 2018

Hydrogeological Unit Depth Range (m bgl)


Unit Description

Lower Alluvium Aquifer

5-12 0.8-4.5 (average: 2.9) The Lower alluvium aquifer was separated from the Upper alluvium by a 1-2 m thick clay or silty clay unit. The Lower alluvium aquifer consisted of mainly sand with varying components of silt and clay.

Haunted Hills Formation Aquifer

10-36 1.2 - 3.9 (average: 2.4) The Haunted Hills Formation aquifer was separated from the alluvium by a 2-5 m thick silty clay and clay layer aquitard, followed by bands of silty/clayey sands and characteristic alluvial sandy gravels.

Nuntin Clay (Boisdale Formation)

>36 (extent of investigation

Groundwater not encountered in this unit at the limit of investigation.

This unit, the upper aquitard unit of the Boisdale formation, consisted of silty clay with trace fine grained sand.

Groundwater flow direction in each of the three water bearing units encountered at the site is generally towards the southeast, consistent with the local topography.

2.3 Management Area scale

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

Characteristics Consequences

Very Large

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

Base and off-Base • hydrogeological profile facilitates rapid

migration of contamination • large impacted community

− PMAP complex − Development / implementation

timeframe: highly extended

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

Base and off-Base • Medium-sized impacted community

− PMAP moderately complex − Development / implementation

timeframe: extended

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

Base and off-Base

− PMAP simplified − Development / implementation

timeframe: medium


26 August 2018

Characteristics Consequences

Small • Small number of identified risks • Contamination currently confined to isolated

locations on-Base • Potential risk of contamination to a small

number of sensitive receptors

− Basic PMAP − Development / implementation

timeframe: medium

2.4 Extent of contamination

2.4.1 Potential PFAS Source Areas

From approximately 2004, Defence commenced phasing out of legacy AFFF (generally 3M lightwater AFFF formulation) across the Defence Estate, and therefore this primary source of impacts is no longer used at the site. However, the impacted environmental media at the site is providing an ongoing (secondary) source of PFAS impacts. Newer AFFF formulations (such as Ansulite) not containing PFOS, PFHxS and PFOA, but still containing PFAS, continue to be used on Defence Bases for emergency situations, however, their use is managed and less likely to enter the environment into the future.

A number of source areas where legacy AFFF was used and introduced into the environment were identified during the PSI (Senversa, 2016). Based on a review of previous environmental assessments and the site history, several key areas have been identified as the potential primary sources of PFAS resulting from the historical on-site storage, use and disposal of legacy AFFFs.

The key potential source areas identified on site are described as follows and presented on Figure 4:

Generally, the most significant source areas (‘Group 1 Source Areas’) that represent a high risk of impact to environmental media at the site and surrounds were locations where there was repeated application of foams and concentrate to the ground during the course of fire fighting training, and other supporting activities such as infrastructure maintenance and testing, or storage of AFFF. These include the following key areas:

• Northwest area – fire truck maintenance areas, AFFF storage, fuelling area (Source IDs 01, 02 and 03), former fire station (Source ID 04) and chemical storage area (Source ID 05).

• Central/eastern area –current fire station (Source ID 06).

• Southern area – former fire training grounds (Source ID 08 and 09) and waste burial areas (Source ID 07)

• Central area – AFFF foam and equipment testing (Source Area 11)

Other source areas identified that represent a high to medium risk of impact to environmental media at the site and surrounds, where legacy AFFF concentrate and/or foam was regularly used or stored, but with less frequent rates of application (‘Group 2 Source Areas’) than the above sources, or the site surface water bodies and drains where AFFF is likely to have migrated from source areas following use.

Other source areas that have a lower risk of potential impact to the environment (Group 3 and Group 4 Source Areas) were identified, however, were not established to be significant areas of potential risk within the DSI and HHERA.

Further to on-site sources of PFAS, a number of sources of PFAS were identified in the area given the Latrobe and Thomson river catchments are within an industrialised catchment. These included power stations up-gradient in the Latrobe Valley and a fire training facility in West sale. Other off-site sources with potential to act as a source of PFAS impacts to the Latrobe River, wetlands to the south


27 August 2018

of the Latrobe River and Lake Wellington potentially include (but are unlikely to be restricted to) Esso’s Longford Plant, the Dutson Downs Weapons Range and Dutson Downs Treatment Plant (and associated outfall drain, and discharge outlet to Lake Coleman). Low concentrations of PFAS were also recorded in soils on private properties surrounding the Base, with the presence of some PFAS compounds not seen on Base, which suggests a potential for agricultural products such as herbicides and fertilisers to be providing a diffuse source of PFAS in the area.

The DSI confirmed the coincident nature of identified impacts with the source area findings of the PSI, indicating legacy AFFF was widely used across many parts of the site, with higher PFAS concentrations recorded near the following sources:

• Maintenance and testing areas in the northwest.

• The former and current fire stations.

• The former fire training areas in the southeast.

• The former AFFF testing areas and sewage treatment plant/current fir training area.

The DSI also identified impacts surrounding the grassed areas near the runway (to the west of the control tower) to be a more significant source than assessed in the PSI. Further, groundwater quality immediately down gradient of the former refuelling area within the AIR5428 construction area reported elevated PFAS suggesting a further source nearby.

Further assessment of the source areas and their contribution to potentially elevated risks is provided in Section 4.1.

2.4.2 Potential PFAS Pathways and Receptors

The PSI and DSI included an assessment of pathways for PFAS migration and exposure, and receptors that may be exposed to PFAS. To further inform the assessment of human and ecological receptors and their potential for exposure to PFAS, a water use and land use survey was also conducted for available residents within the former Investigation Area, with this information used to support the assumptions made in this HHERA.

The pathways for PFAS migration and exposure identified were primarily surface water drainage and transport within groundwater, and consumption of agricultural products or wildlife/game into which PFAS may have bioaccumulated.

Identified receptors of potential PFAS exposure included people (on-base personnel, residents and adjoining land users, consumers of recreational game and fish, and consumers of agricultural products) and ecological receptors including animals and plants (terrestrial and aquatic) through direct exposure or through bioaccumulation of higher order predators (e.g. fish eating birds).

Appendix C outlines the exposure medium, the exposure pathways and the human and ecological receptors that have been considered throughout the investigation. Section 4 provides further details of the conceptual site model (CSM).

2.4.3 Nature and Extent of PFAS Impacts

The DSI (Senversa, 2017a) findings relevant to the assessment of risk and potential management responses are summarised below. Further assessment of the data collected during the DSI (Senversa, 2017a) and HHERA (Senversa 2017b) has been undertaken in Section 4.1 for the key source areas, pathways and receptors for which there are potentially elevated risks identified.


28 August 2018

Soil Results

• The principal PFAS of interest is PFOS, as PFOS was reported at highest concentrations and is the key risk driver at and surrounding the site. However, in some instances the sum of PFOS + PFHxS (concentration sum used in human health screening criteria adopted in the DSI) is elevated due to the presence of both PFHxS and PFOS (rather than predominantly PFOS). The generally consistent results indicate the AFFF (containing PFOS/PFOA) was likely of a reasonably uniform formulation.

• On-site, detectable concentrations of PFOS have been reported in soil samples collected across the site, however most concentrations are below screening criteria adopted in the DSI for protection of human health in a residential setting. Further to this:

Soil samples collected within more sensitive areas of the site (including the child care centre, kindergarten, and areas used for residential or accommodation purposes), were many times below the residential (consistent with child care use) human health screening criteria adopted in the DSI.

Locations with exceedences of residential human health screening levels adopted in the DSI were limited to the identified on-site source areas, but these areas are not used for residential purposes.

The reported PFAS concentrations in all samples (with one exception, in the northwest area that was subsequently removed as part of development works and is currently stockpiled in this area) in operational areas were below screening criteria adopted in the DSI for the protection of human health in a commercial/industrial setting.

• Off-site, at the site boundary and into surrounding areas, detectable but very low PFAS soil concentrations were recorded, at concentrations many more times lower than the residential human health screening criteria adopted in the DSI.

• Soil concentrations were compared to screening criteria in the DSI that were available at the time, however, were developed prior to the release of the FSANZ (2017) TDI. These were evaluated further in the HHERA to confirm the conclusions made in the DSI. Potential pathways from soil and sediment to human receptors were assessed for incidental direct contact with soil and sediment (dermal contact and incidental ingestion) and ingestion of home-grown produce (considering pathways of uptake from soil and irrigation water) (off-site properties only), with risks assessed to be low and acceptable.

• Limited assessment of contaminant mobility has been completed given PFAS is soluble and mobile in the environment. Initial screening of recorded leachable PFAS indicated that PFOS presented a much higher leachate concentration than other PFAS. A strong positive correlation of increasing leachability with increasing total concentration in soil was identified and corresponded to Group 1 and 2 source areas compared with other samples across the site. The data indicates that there may be a threshold at around 5 mg/kg PFOS, below which leachability decreases significantly at the site and is below the drinking water criteria of 0.07 ug/L (used as a guidance number for unlined landfill acceptance in the NEMP (2018)).

• Concrete sampling of demolition waste stockpiled in the southwest of the site identified low total and leachable PFAS concentrations indicating the potential for impacts to land or waters, should the material not be managed appropriately.

• Grass sampling identified either low, or not detected PFAS concentrations, except for one sample collected from a former fire training area in the southeast area (outside of the grazing lease area). Even at low concentrations, the consumption of grass by livestock that may end up in the food chain through bioaccumulation was identified, and required further assessment, which has been completed through the HHERA process.


29 August 2018

• Despite the low and acceptable risks established for humans and terrestrial ecosystem health from soil impacts for the current site use, given the nature and behaviour of PFAS in the broader environment there is a potential for secondary impacts. Even at low soil concentrations, the potential for leaching and migration into groundwater and surface water systems from infiltration or overland flow was identified as having the potential for risk to aquatic ecosystems off-site and biota that may be in the food chain through bioaccumulation, and required further assessment, which has been completed through the HHERA process.

Groundwater Results

• On-site, PFOS concentrations have been reported above the limit of reporting in the majority of on-site groundwater monitoring wells. The highest concentrations were reported in shallow groundwater in or near identified on-site source areas. Whilst the reported concentrations in some locations are well above the recreational screening criteria adopted in the DSI, shallow groundwater is not extracted or used at the site. Further to this:

Detectable PFAS has not been found in the deep aquifer Base supply groundwater extraction bore.

Exposure to impacted groundwater is unlikely other than for intrusive maintenance workers who may incidentally contact groundwater during intrusive works which encounter the shallow water table. This was assessed in the HHERA to represent a low and acceptable risk.

• Sampling of off-site private bores during the PSI and DSI indicates PFAS migration has not occurred in the water bearing zones where these private bores are located, with no detectable PFAS reported, except for one private irrigation bore (currently not used, and has not been used, for drinking water purposes) where a low concentration of PFAS was recorded below the drinking water screening criteria adopted in the DSI. Further sampling of bore water from stock troughs and outdoor domestic use taps connected to a source bore to the south of the site within the Investigation Area for the HHERA did not record PFOS levels above the recreational screening criteria adopted in the DSI. While a single reading from the bore did detect elevated PFOS levels, this result was not replicated in additional sampling of the bore.

• Two paired off-site publicly available monitoring wells recorded detectable PFAS, at concentrations exceeding the drinking water screening criteria adopted in the DSI. The two monitoring wells in which PFAS was detected are located adjacent to the southeast corner of the site, where elevated concentrations have been reported in both soil and groundwater on-site. These sampling results indicate that PFAS migration off-site has occurred in this area.

Surface Water and Sediment Results

• Drainage line sampling identified detectable concentrations of PFOS and other PFAS in almost all samples. The highest concentrations were reported close to source areas (including the fire station in the central area, the maintenance and operations area in the northwest corner and the former waste burial and former fire training areas in the southeast corner). Shallow groundwater is also indicated to be discharging into the Eastern Drain and contributing to PFAS impacts within this drain.

• Reported PFAS concentrations in drainage sediments were relatively low (below soil screening levels for protection of human health in a residential setting), however the presence of detectable PFAS in most samples indicates that these have the potential to act as an ongoing source of PFAS to surface water bodies and drainage lines.


30 August 2018

• On-site, reported PFAS concentrations in surface waters range up to approximately 100 times the primary contact recreation screening criteria adopted in the DSI to assess direct contact activities such as swimming, however the majority are less than 20-30 times this screening level. The drains are not used for recreational purposes.

• Off-site, detectable but low PFOS concentrations were reported in most surface water samples but were generally below the recreational use screening criteria adopted in the DSI to assess direct contact activities such as swimming. The detections off-site in sediment and surface water indicated the need for further evaluation of risk which was assessed in the HHERA and established a low and acceptable risk. As additional temporal data is collected during monitoring, depending on the results, this may require revision of this risk.

2.5 Water use

A local Water Use Survey completed for properties surrounding the site in the Senversa PSI (Senversa, 2016) provided the following additional information:

• Rainwater tanks provided the primary drinking water supply at all properties surveyed.

• Several registered bores were no longer in use.

• The upper groundwater aquifers are commonly extracted across properties to the north, southeast, south and west of the site for non-potable uses. Reported uses of the shallow groundwater included domestic non-potable supply (bathroom and laundry), outdoor domestic supply, dairy operations, irrigation of pasture, stock watering and abattoir operations.

• Groundwater from the deeper Boisdale Formation is extracted from multiple bores across the area investigated. Reported uses of the deep groundwater included drinking water (Supplements Base water supply), outdoor domestic supply, dairy operations, irrigation of pasture and stock watering.

• Groundwater is also regularly extracted and stored in above ground surface water bodies, termed ‘turkey’s nest’. The water is then accessed when needed for purposes such as irrigation or stock watering.

• The MID irrigation surface water channel network was widely used by dairy farms across the north and western areas off-site, with the water generally used for flood irrigation of pasture.

Within the Management Area, the following groundwater extraction bores (no bores are currently used for drinking purposes) are present on private properties:

• One installed within the Lower Alluvium, 10 considered to be installed in the Haunted Hills Formation, and 2 installed within the Boisdale Formation.

• Nine are used for stockwatering.

• Six are used for irrigation (pasture), with three not currently in use.

• Five are used for outdoor domestic uses (home grown produce/gardens).

During the DSI (Senversa, 2017) and to inform the HHERA (Senversa, 2017b), a number of water supply taps, tanks, bores and stock troughs were sampled, with the results indicating:

• The on-site drinking water supply is partially sourced from the deep groundwater site extraction bore and results from on-site and off-site groundwater bore sampling of this groundwater unit established that detectable PFAS were not present.

• Private property water tank samples were targeted to properties located near to the site boundary and results established that detectable PFAS are not present in the private drinking water supply on these properties.


31 August 2018

• Stock troughs located within the site leased grazing area are supplied by water from the on-site water supply and were sampled at four locations. The results established that PFAS does not exceed the adopted stock watering (drinking water) screening criteria adopted in the DSI.

• As indicated above, PFAS was generally not recorded in off-site private extraction bores, with the exception of bores present to the south of the Base, which recorded low concentrations (with one higher concentration not replicated in further sampling).

2.6 Relevant legislation and government policy

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

The PFAS NEMP, and any subsequent updates to this document, provides the guiding framework for the management of PFAS. For further information, see: http://www.epa.vic.gov.au/PFAS_NMP.

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

Other key drivers and constraints impacting upon response management include:

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

• The PFAS NEMP document outlines the preferred framework for PFAS management including containment, remediation, treatment and disposal. The document acknowledges that each site is unique, and any management response must consider site-specific conditions in determining the best approach to the management of PFAS. Overall the document presents the hierarchy of options for site clean-up, which is consistent with the policy intent of the Victorian waste management requirement and guidance provided within EPA Victoria’s interim position on PFAS (EPA Victoria, 2017), being any clean-up of land will reflect the order of preference set out in the waste hierarchy (i.e. treatment and reuse on–site is preferred to treatment and reuse off-site, while long-term containment off-site is least preferred).

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

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

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

http://www.epa.vic.gov.au/PFAS_NMP

http://www.epa.vic.gov.au/your-environment/land-and-groundwater/pfas-in-victoria/managing-pfas-impacted-wastes-in-victoria



32 August 2018

PFAS NEMP and EPA Victoria’s interim position on PFAS (EPA Victoria, 2017), and subsequent updates to these document, would be considered in such reviews.

2.7 Stakeholders

Government/Regulators:

• EPA Victoria

• Department of Health and Human Services (DHHS)

• Chief Vets Office – Department of Economic Development, Jobs Training and Resources (DEDJTR)

• Southern Rural Water

• Parks Victoria

• West Gippsland Catchment Management Authority

• Fisheries Victoria

• Wellington Shire Council

• Darren Chester (Federal Member for Gippsland)

• Daniel (Danny) O’Brien (State Member for Gippsland South)

Interest Groups:

• Gunaikurnai Land and Waters Aboriginal Corporation

• Field and Game Australia

• Bug Blitz

• WET Trust

• Defence Grazing Land Leasee

Community:

• Community members resident in the Management Area

• Commercial Fishers licenced for The Heart Morass

• General Public

Local Media

• ABC Gippsland

• WIN News

• The Gippsland Times

• The Weekly Times

Stakeholder and community engagement has occurred since the commencement of the PFAS Investigations in April 2016. Government stakeholders have been communicated the progress and findings of the PFAS investigations on a regular basis.


33 August 2018

Five community engagement sessions have been held to discuss the following items:

• May 2016 – Commencement of PFAS Investigations

• October 2016 – Preliminary Site Investigation findings

• December 2016 – Human Health and Ecological Risk Assessment methodology

• June 2017 – Detailed Site Investigation findings

• December 2017 – Interim Human Health and Ecological Risk Assessment findings

A further community engagement session is planned for August 2018 to discuss the findings of the Final Human Health and Ecological Risk Assessment. Further to these community sessions, stakeholder and community engagement has also included running a project hotline phone number and email, development of fact sheets, preparation of results letters for private property sampling with individual communications to discuss results, and face to face briefings with potentially impacted individuals or groups.


34 August 2018

3 PMAP METHODOLOGY AND APPROACH

3.1 Overview of approach

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

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

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

3.2 Identify risks and consequences (Chapter 4)

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

3.3 Prepare Ongoing Monitoring Plan (Chapter 5)

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

3.4 Develop risk management options (Section 6.1)

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

• Risk assessments, CSM and DSI;

• Relevant Commonwealth and State/Territory legislation

• Feedback from stakeholder consultation (impacted community and jurisdictional regulator)

• IRM actions undertaken or continuing in the Management Area

• IRM or PMAP actions undertaken or considered by Defence on other properties

The management options include:

• the ‘do-nothing’ option. It provides the ‘base case’ against which other options are assessed and may at times be the best available option when assessed against the criteria of ‘net environmental benefit’. It does not get assessed through this process but the potential impacts are described in the Chapter 4 analysis.

• Additional investigations required to address uncertainties and data gaps as identified through completion of the DSI.

• Community-level options for further assessment.

Identifying information for each option includes the objective and a description of how the objective contributes to managing the identified risk.


35 August 2018

3.5 Detailed options analysis (Section 6.2)

For each risk, the following analysis was undertaken:

A. Cost / effectiveness / impact analysis

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

B. Risk-based analysis

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

C. Defence implications

12 Defence capability 13 Project fit 14 Scalability

D. Stakeholder impacts, views and consents

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

E. Comparative analysis

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

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

3.6 Integrated options analysis (Section 6.3)

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

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

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

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


36 August 2018

3.7 Recommendations Analysis

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

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

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

• the comparative options analysis; and

• the integrated options analysis.


37 August 2018

4 IDENTIFIED RISKS AND CONSEQUENCES

4.1 Source / pathway / receptor analysis

Based on the discussion of nature and extent in Section 2.4, and further analysis of the data collected during the DSI and HHERA,

The on-site source areas are shown on Figure 4. Further detail on the magnitude of concentrations recorded for different environmental media sampled at the risk source areas is provided in Table 1 to aid in understanding which source areas are contributing to the risk, and where management response may focus in these areas. The relative contribution of PFAS impacts from each of these areas to the potentially elevated risks identified is discussed below.

Source Area (ID)

Risk Contribution Mechanisms Relative Contribution to Risk

The Heart Morass

The Heart Morass

Surface water concentrations present across extent. Higher sediment concentrations than recorded on-Base, within area of drain discharge outlet. Potential discharge of shallow groundwater PFAS impacts not known, but unlikely based on distance from base boundaries. Impacted aquatic biota (including biomagnification) - exposure to impacted sediment and surface water ongoing.

Significant

Stormwater Drains – Off-site

Surface water concentrations present higher than within The Heart Morass. Sediment concentrations consistent with on-Base – providing ongoing source of PFAS impact to waters. Impacted aquatic biota likely (including biomagnification)- exposure to impacted sediment and surface water ongoing.

Significant

Site Surface Water

Ornamental Pond

Lower surface water and sediment concentrations than drainage lines and Lake Edward. Impacted aquatic biota (including biomagnification)- exposure to impacted sediment and surface water ongoing.

Marginal to Moderate

Lake Edward (25)

High surface water concentration and sediment concentration consistent with drains. However, dry at times and does not support biota. Low shallow groundwater concentrations in vicinity, with significant distance to downgradient receptors or discharge points.

Marginal


38 August 2018

Source Area (ID)


Stormwater Drains (17) – Open

Direct pathway of sediment and dissolved impacts to The Heart Morass to the south. Intermittent potential in high flows for off-site migration to northwest and east. Highest concentrations recorded in Eastern Main Drain downgradient of closed system inputs. Unlined nature of majority of open drainage has potential to impact shallow groundwater in vicinity of stormwater drains along length, especially on southern and southeastern boundaries. Impacted aquatic biota (including biomagnification) - exposure to impacted sediment and surface water ongoing.

Significant

Stormwater Drains (17) – Closed

Contributes elevated concentrations to Eastern Main Drain, which is direct pathway of sediment and dissolved impacts to The Heart Morass. Highest concentrations in surface water recorded on-Base. Sediment (where present) consistent with magnitude recorded in open drainage lines.

Significant

Southeast Area

Former Fire Training Area – Southeast (08)

Soil impacts to >1m depth and highly leachable concentrations. Shallow depth to groundwater at 2-4 m depth. Very high concentrations recorded in shallow groundwater. Shallow groundwater discharge to Eastern Main Drain, which is direct pathway of sediment and dissolved impacts to The Heart Morass, and off-site migration of impacts. High concentrations in deeper groundwater, with potential to be migrating off-site, with downgradient extraction bores for stock watering and irrigation. 400m to surface water drains - not likely to contribute to surface water from overland flow.

Moderate to Significant

Waste Burial Area (07)

Generally surface impacts with low concentrations in soil, however, leachable concentrations recorded. Potential for overland flow of low soil concentrations and direct discharge into Eastern Main Drain, which is adjacent. Shallow groundwater concentrations in area are likely to be associated with plume migration of high concentrations from fire training grounds adjacent and upgradient.

Marginal to Moderate


39 August 2018

Source Area (ID)


Former Fire Training Area - Southeast near 4WD track (09)

Soil impacts to ~0.3m depth and highly leachable concentrations. Shallow depth to groundwater at 4 m depth. High concentrations recorded in shallow groundwater, but less than the contribution from downgradient fire training area (08). Contributing to shallow groundwater discharge to Eastern Main Drain, which is direct pathway of sediment and dissolved impacts to The Heart Morass, and off-site migration of impacts. Potential for overland flow of low soil concentrations to drainage connection into western main drain or areas of inundation in vicinity, with lower surface water concentrations recorded in this drainage branch than in eastern main drain in this area.


4WD Training Track (12)

Generally surface impacts with low concentrations in soil, however, leachable concentrations recorded. Potential for overland flow of low soil concentrations and direct discharge into Eastern Main Drain, which is adjacent. Shallow groundwater concentrations in area are likely to be associated with plume migration of high concentrations from fire training grounds adjacent and upgradient.

Marginal

Fire Station & Testing Area

Current Fire Station (06)

High concentration in soil to >1m depth and highly leachable concentrations. Shallow depth to groundwater at ~2m depth. Very high concentrations recorded in shallow groundwater at only monitoring well installed at source area, and therefore extent undelineated. Highest concentration in surface water recorded in closed drainage system, and high concentrations present downgradient in open system of the eastern main drain, which is direct pathway of sediment and dissolved impacts to The Heart Morass. At times of high flow, potential for off-site discharge to east. Potential for shallow groundwater discharge to eastern main drain, however, given distance to discharge point may not be likely.

Significant

Grassed area near runways used for AFFF testing (16)

Generally surface impacts with high concentrations and highly leachable. Shallow depth to groundwater at ~2m depth. Very high concentrations recorded in shallow groundwater at only monitoring well installed at source area, and therefore extent undelineated. Potential for shallow groundwater discharge to eastern main drain, however, given distance to discharge point may not be likely. Located approximately 100m from drainage point within closed drainage system on grassed area, and therefore not likely to present a direct impact to surface water.



40 August 2018

Source Area (ID)


Northwest Area

Grassed Area Near MEOMS (14)

High concentration in soil to ~0.2 m depth and highly leachable concentrations. Soil has been excavated to construct new tank farm in this area and managed by covered stockpile in northwest area of site. Extent of removal from in-situ unknown (works completed by others). Potential for overland flow to open unlined surface water drainage to the north and off-site private property irrigation holding pond to west. Capture into closed drainage system to the south. Highest sediment concentrations in area in northern open drain from this source area. Shallow depth to groundwater at ~1m depth. High concentrations in shallow groundwater, but delineated to lower concentrations downgradient in area and significant distance from receptors or discharge points.

Significant (but potentially largely managed through re-development works)

Former Fire Station (04)

High concentrations in soil to ~0.3m depth, with lower leachability. Low concentrations in surface water in closed drainage system in this area. Shallow depth to groundwater at ~2m depth. High concentrations in shallow groundwater, with low concentrations in downgradient well at Source ID 15, therefore extent likely to be small, and significant distance from receptors or discharge points.

Moderate

Grassed Area Near Former Fire Station (15)

Low concentrations in soil (no leachability data). Low concentrations in surface water in closed drainage system in this area. Shallow depth to groundwater at ~2m depth. Low concentrations in groundwater, and significant distance from receptors or discharge points.

Marginal

MEOMS - Waste Disposal (01 & 14 (Part)

High concentration in soil to >1m depth and highly leachable concentrations. Potential for overland flow to open unlined surface water drainage to the north and off-site private property irrigation holding pond to west. Capture into closed drainage system to the south. Low to moderate concentrations in surface water in closed drainage system in this area. Shallow depth to groundwater at ~1-2m depth. High concentrations in shallow groundwater, but delineated to lower concentrations downgradient in area and significant distance from receptors or discharge points. Non-detection in deeper groundwater.

Significant


41 August 2018

Source Area (ID)


MEOMS - Operational Areas (02)

Low concentrations in soils at surface and moderate leachability. High concentration in surface water in closed drainage system in area. Highest sediment concentration in area in closed drainage in this source area. Shallow depth to groundwater at ~1-2m depth. High concentrations in shallow groundwater, but delineated to lower concentrations downgradient in area and significant distance from receptors or discharge points.


Fire Truck Hose Testing (03)

Low concentrations in soils at surface (no leachability data). Low to moderate concentrations in surface water in closed drainage system in this area. Shallow depth to groundwater at ~4m depth. Low concentrations in shallow groundwater.

Marginal

Chemical Storage Area (05)

High concentration in soil to ~0.3m depth and highly leachable concentrations. Low to moderate concentrations in closed drainage system in this area. Shallow depth to groundwater at ~4-5m depth. Low-moderate concentrations in shallow groundwater at only monitoring well installed at source area, and therefore extent undelineated. However, significant distance from receptors or discharge points.

Moderate

Central Area

Current Fire Training - Former Sewage Treatment (13)

High concentrations in soil (no leachability data). Potential for overland flow to closed surface water drainage at the area, into the open drainage system to the east and into the artificial surface water pond to the north. Moderate surface water concentrations in open drain to east and artificial pond to the north. High concentration recorded in shallow groundwater at only monitoring well installed at source area, and therefore extent undelineated. However, significant distance from receptors or discharge points.



42 August 2018

Source Area (ID)


AFFF Testing Area (11)

Low concentrations in soils to ~0.3m depth, but highly leachable concentrations. Potential for overland flow to closed surface water drainage to the north and south, and into the open drainage system to the east. High concentrations in surface water in closed drainage system to the north in this area. High sediment concentrations in the closed drainage system at and to south of this source area. Shallow depth to groundwater at ~2m depth. High concentrations in shallow groundwater at only monitoring well installed at source area, and therefore extent undelineated. However, significant distance from receptors or discharge points. Non-detection in deeper groundwater.


AIR5428 Area Low to moderate soil concentrations (no leachability data) to ~0.2m depth. Soil has been excavated to construct new training centre in this area and managed by project. Extent of removal from in-situ and management works unknown (works completed by others). Shallow depth to groundwater at ~2m depth. Potential for overland flow to closed surface water drainage to the south, and into the open drainage system to the east. High concentrations in surface water in closed drainage system to the south in this area. High sediment concentration in the closed drainage system to south of this source area. High concentrations in shallow groundwater, but delineated to lower concentrations downgradient in area and significant distance from receptors or discharge points.

Moderate

Based on the information presented in Table 1, and summarised above, the key source areas that are considered to have a significant contribution to the potentially elevated risks and potential future risks identified in the DSI and HHERA, which require consideration of management response options comprise:

The Heart Morass: including The Heart Morass and off-site stormwater discharge drains.

Site Surface Water: on-site open and closed drainage system.

Southeast Area: predominantly the former fire training areas (Source ID 08 and 09).

Fire Station and Testing Area: current fire station (Source ID 06) and grassed area near runways used for AFFF testing (Source ID 16).


43 August 2018

Northwest Area: predominantly MEOMS and grassed area used for AFFF testing (Source ID 01, 02 and 14) and to a much lesser extent, Former Fire Station (Source ID 04) and Chemical Storage Area (Source ID 05).

Central Area: former AFFF Testing Area (Source ID 11) and the current fire training and former sewage treatment (Source Area ID 13).

Appendix C outlines the exposure medium, the exposure pathways and the human and ecological receptors that have been considered throughout the investigation, with a conceptual site model cross section also illustrated. The following flow chart outlines the conceptual site model source-pathway-receptor linkages for potentially elevated risks that were identified in the HHERA and potential risks that require monitoring or further investigation (where a current receptor may not be present).


44 August 2018

Figure 5 – PFAS Conceptual Site Model


45 August 2018

Summary of Elevated Risks

The Final HHERA (Senversa, 2017b) has identified potentially elevated risks associated with the following pathways from the CSM:

• Home-consumption of meat, offal and milk raised on-site. It is noted that the grazier does not currently consume beef raised on-site, and there are currently no dairy cows on-site, and so a pathway of home-consumption of cattle meat, offal and milk raised on-site is currently inactive. It is however noted that sheep until recently had been raised on-site for home consumption, and there are considered to be potentially elevated risks associated with home-consumption of lamb raised on-site.

• Home consumption of duck meat and duck liver recreationally hunted from The Heart Morass even at low consumption rates (i.e. 1 serve of duck/month).

• Home consumption or public consumption of fish caught from The Heart Morass

• Exposure to aquatic ecological receptors in surface waters in the Investigation Area, and to higher-order predators consuming biota from these areas as part of their diet.

The identification of potentially elevated risks does not necessarily indicate that there will be adverse effects, but instead that management of risks and/or further investigation/assessment may be warranted.

Summary of Potential Risk Sources Requiring Monitoring or Management

The DSI (Senversa, 2017a) identified potential risk sources associated with the following pathways from the CSM that require monitoring or management. These are generally associated with sources that have the potential to provide a risk in future should migration of impacts, or changes in off-site water use, occur. Implementation of the Ongoing Monitoring Plan (Section 5, and Appendix F) will provide data to assess the potential for these risks to be realised and allow Defence to respond with increased monitoring frequency or management measures to further assess or mitigate risks, where required, in a timely manner.

• Shallow groundwater (Upper Alluvium) impacts migrating on-site. Groundwater impacts from initial assessment of sources were not delineated during the DSI phase of investigation but recorded high concentrations of PFAS in shallow groundwater. Further, source areas present in the northwest corner and southeast corner also recorded high concentrations in shallow groundwater, where nature and extent is better understood, but not necessarily delineated.

• Shallow groundwater (Upper Alluvium) impacts migrating off-site onto private properties. PFAS presence above adopted screening criteria is potentially migrating off-site to the south, east and southeast at concentrations that may present a future risk to off-site users of shallow groundwater, should the nature or intensity of land use change and groundwater extraction occurs near to the site. There is also a potential that discharge of Upper Alluvium groundwater could occur to The Heart Morass to the south of the site at concentrations exceeding the adopted ecosystem screening criteria.

• Deeper groundwater (Lower Alluvial and Haunted Hills Formation) impacts migrating off-site. Lower Alluvium and Haunted Hills Formation groundwater results exceed adopted drinking water and recreational use screening criteria at monitoring wells adjacent to the former fire training area and on the boundary in the southeast of the site and have the potential to be migrating off-site in the southeastern area.


46 August 2018

• Migration pathways from soil sources on-site. Legacy AFFF was widely used across many parts of the site with higher concentrations recorded at four key source areas (described above). Given the reported PFAS concentrations in soil and grass, the nature and behaviour of PFAS in the broader environment, soil impacts are likely to present an ongoing source of impacts to groundwater and surface water from infiltration and overland flow, respectively.

4.2 Risk listing and consequences

The tables below provide details of the potentially elevated risks and potential risk sources requiring monitoring or management, including the potential consequences if the risks were to be realised.


47 August 2018

Table 2 – Risk Listing and Consequences: Potentially Elevated Risks

Risk Identification #

1 2 3 4

Title Human consumption of fish caught from The Heart Morass.

Human consumption of ducks recreationally hunted from The Heart Morass.

Exposure of aquatic ecological receptors in surface waters, and to higher order predators consuming these biota.

Human consumption of meat, milk or offal from livestock raised on-site into which PFAS has bioaccumulated.

Description & Nature of Risk

Description Recreational fishing (The Heart Morass) Overall, it is concluded that potential risks associated with consumption of recreationally caught fish from The Heart Morass are potentially elevated, even at lower consumption rates, although it is noted that there are certain locations and fish types for which the risks are assessed (based on the measured concentrations at these locations) to be low and acceptable at lower consumption rates. Notably, in the far eastern extent of The Heart Morass, risks are assessed to be low and acceptable for consumption rates of 1 serve/week or less. In the western portion of the main body and the southern extent (the Latrobe River Outlets), risks are assessed to be low and acceptable for consumption rates of 1 serve/month or less. Commercial fisheries (The Heart Morass) Risks to public consumers are assessed as potentially elevated for fish caught in the vicinity of the Eastern Main Drain outlet, but are low and acceptable for fish caught from other locations. For eels caught in the vicinity of the Eastern Main Drain outlet, ranching (where smaller eels from The Heart Morass are transferred to freshwaters in other areas to increase weight before being harvested for consumption) would likely be effective in reducing risks to a low and acceptable level. Latrobe River Potentially elevated risks are identified for consumption of recreationally caught eel and carp (at high consumption rates) from the Latrobe River; risks were low and acceptable for other recreationally-caught fish, and for public consumption of commercially caught fish. However, such risks are considered most likely a wider catchment issue; management of these risks should be undertaken as part of a catchment-wide approach and are excluded from the management scope considered in this PMAP.

Based on the HHERA, there is concluded to be an elevated risk associated with the home consumption of duck meat and duck liver recreationally hunted from The Heart Morass even at low consumption rates (i.e. 1 serve of duck/month). The identification of potentially elevated risks does not necessarily indicate that there will be adverse effects, but instead that management of risks and/or further investigation/assessment may be warranted. The measured PFAS concentrations in ducks indicate risk from consumption; however, it is noted that these ducks themselves are migratory and are likely to source their diet widely (not just from The Heart Morass); as such, while the measured concentrations pose potentially elevated risks, there is a level of uncertainty around whether the measured PFAS concentrations in ducks relate solely to exposure in The Heart Morass, or to other potential sources in the area.

The ecological risk assessment made the following conclusions:

Reported surface water PFOS concentrations in The Heart Morass were above the screening level for assessment of adverse effects due to direct contact exposure by aquatic species and bioaccumulation within aquatic ecosystems (draft revised ANZECC/ARMCANZ water quality guidelines).

Reported PFOS concentrations in aquatic biota (including plants, invertebrates and fish/eels) and ducks exceeded relevant dietary screening concentrations for the protection of a range of relevant bird receptors (Environment Canada (EC) avian diet screening levels, and adjusted levels for different representative bird species). Overall, it is not considered possible to exclude potential adverse effects to ecological receptors within The Heart Morass, although it is emphasised that for species which source only a portion of their diet from within the Investigation Area, risks may be lower than indicated in this assessment, however more data is required. The identification of potentially elevated risks does not necessarily indicate that there will be adverse effects, but instead that management of risks and/or further investigation/assessment may be warranted. The measured PFAS concentrations in ducks exceed avian diet screening levels; however, it is noted that these ducks themselves are migratory and are likely to source their diet widely (not just from The Heart Morass); as such, while the measured concentrations pose elevated risks to predators eating these ducks as part of their diet, there is a level of uncertainty around whether the measured PFAS concentrations in ducks relate solely to exposure in The Heart Morass, or to other potential sources in the area. Overall, it is not considered possible to entirely exclude potential adverse effects to higher-order predators consuming biota from within the Latrobe River, although the risks were assessed a generally low and acceptable (marginal at worst), and it is emphasised that for species which source only a portion of their diet from within the Investigation Area, risks are likely to be lower than indicated in this assessment. The identification of

Home-consumption of meat, offal and milk raised on-site were assessed in the HHERA to provide a potentially elevated risk. It is noted that the grazier does not currently consume beef raised on-site, and there are currently no dairy cows on-site, and so a pathway of home-consumption of cattle meat, offal and milk raised on-site is currently inactive. It is however noted that sheep are raised on-site for home consumption, and there are considered to be potentially elevated risks associated with home-consumption of lamb raised on-site. The risk to public consumers (of meat, offal and milk raised on-site and entering the public food supply) were assessed to be low and acceptable based on a scenario where meat or offal enters a broad regional or national market.


48 August 2018


1 2 3 4

potentially elevated risks does not necessarily indicate that there will be adverse effects. Furthermore, the presence of PFAS impacts in the Latrobe River (and other up-gradient and down-gradient surface water bodies in the area) is considered most likely attributable to wider catchment issues. As such, while marginally potentially elevated ecological risks are identified for the Latrobe River, such risks are considered most likely a wider catchment issue; management of these risks should be undertaken as part of a catchment-wide approach and are excluded from the management scope considered in this PMAP.

Pathway/s Uptake into fish from surface water impacts via the food web, and subsequent human consumption

Uptake into ducks from surface water impacts via the food web, and subsequent human consumption.

Uptake into food web (ecological) from surface water impacts.

Uptake into livestock from soil and grass impacts, and subsequent human consumption.

Receptor/s Human consumers of fish from The Heart Morass, including recreational fishers and members of the public consuming commercially caught fish (caught from the vicinity of the Eastern Main Drain outlet).

Human consumers of ducks from The Heart Morass.

Bioaccumulation into higher order ecological receptors who may feed on aquatic flora/fauna within open drains or other surface water bodies and aquatic flora and fauna within The Heart Morass and, to a lesser extent, the Latrobe River.

Home consumers of meat from livestock raised on-site.

Primary Source/s

PFAS in surface water primarily migrating from the Eastern Main Drain, and contributions from Western Main Drain, off-site in the southeast corner and discharging directly to The Heart Morass. The highest concentrations were reported close to source areas (including the current fire station in the central area (Source ID 06), the maintenance and operations area in the northwest corner (Source ID01-03) and the former fire training areas (Source ID 08 and 09) in the southeast corner).

PFAS in soil and grass, predominantly within the former fire training area (Source ID 08).

Secondary Source/s

Sediment in The Heart Morass. Reported PFAS concentrations in drainage sediments were relatively low, however the presence of detectable PFAS in most samples indicates that these have the potential to act as an ongoing source of PFAS to surface water bodies and drainage lines.

Surface water drainage and areas of inundation accessible to livestock.

Contributing Source/s

Sediment in drainage lines. Overland flow from impacted soil areas (such as former fire training area) into on-site drainage lines. Shallow groundwater discharge directly into on-site drains (former fire training areas, potentially current fire station area and other non-delineated source areas on-site). Impacted infrastructure (closed drainage from current fire station) drainage into stormwater system. Potential for shallow groundwater impacts directly into The Heart Morass (not-delineated).

Overland flow from impacted soil areas (such as former fire training areas) into areas of inundation accessible by livestock.

Other off-site wider catchment PFAS sources due to potential mobility and migratory nature of fish and eels.

Other off-site wider catchment PFAS sources due to mobility and migratory nature of ducks.

Other off-site wider catchment PFAS sources due to potential mobility and migratory nature of aquatic species and higher order predators.

Consequence

Current Impacts Fisheries Victoria restrictions on commercial operator fishing for eels and carp from near the Eastern Main Drain outlet at The Heart Morass. Recreational users impacted from EPA consumption advice implemented for fishing.

Recreational users impacted from EPA consumption advice implemented for duck hunting.

Aquatic ecological receptors have PFAS concentrations above trigger levels for ecological health.

Potentially elevated risk from high rates of human consumption (home consumption scenario) of beef cattle and lambs raised on-site (it is noted that beef cattle is currently not consumed via a home consumption scenario).


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1 2 3 4

Potential Impacts

Risks from direct contact with water for recreation purposes require monitoring to assess temporal trends in concentrations and requirement for revision of risk.

Potential loss of revenue to private owners (Field and Game Australia) from memberships to enable maintenance of conservation area. Risks from direct contact with water for recreation purposes requires monitoring to assess temporal trends in concentrations and requirement for revision of risk.

Adverse effects to ecological health from higher order bioaccumulation within food web.

None

Temporal Risks Ongoing contribution of PFAS to primary and secondary source from discharge of surface water from site drainage lines to The Heart Morass.

Extent

Location The Heart Morass The Heart Morass On-site surface water bodies, drainage lines and The Heart Morass

On-site leased grazing area.

Approx. Spatial Extent

20,000,000 m2 (2,000 ha) 20,000,000 m2 (2,000 ha) 20,000,000 m2 (2,000 ha) 2,700,000 m2 (270 ha)

Existing Management Measures

Defence Discontinue use of legacy AFFF Discontinue use of legacy AFFF Discontinue use of legacy AFFF Discontinue use of legacy AFFF

Stakeholders EPA consumption advice for recreational fishing. Fisheries Victoria restrictions on commercial operators fishing for eels and carp from near the Eastern Main Drain outlet at The Heart Morass.

EPA consumption advice for ducks. None EPA/DHHS advice to leasee not to consume livestock raised on base for home consumption, including cattle and sheep.

Potential Additional Controls

Source Management

Source Management Ongoing monitoring of ecosystem health, with a view to future sampling in ongoing monitoring program for risk revision and removal of advisory.

Source Management Ongoing monitoring of ecosystem health, with a view to future ecological risk revision once ecosystem health is identified to be improving from contributing source management actions.

Source Management


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Table 2 – Risk Listing and Consequences: Potential Risk Sources Requiring Monitoring or Management

Risk Identification # 5 6 7 8

Title Shallow groundwater (Upper Alluvium) impacts migrating on-site.

Shallow groundwater (Upper Alluvium) impacts migrating off-site onto private properties.

Deeper groundwater (Lower Alluvial and Haunted Hills Formation) impacts migrating off-site.

Migration pathways from soil sources on-site.

Description & Nature of Risk

Description Groundwater impacts from initial assessment of sources such as current fire station and grassed area to west (Source ID 06 and 16), former AFFF testing area (Source ID 11), area of former re-fuelling location in the AIR5428 construction area (potential new identified source based on groundwater impacts) were not delineated during the DSI phase of investigation but recorded high concentrations of PFAS in shallow groundwater. Further, source areas present in the northwest corner and southeast corner also recorded high concentrations in shallow groundwater, where nature and extent is better understood but not necessarily delineated.

PFAS presence above adopted screening criteria is potentially migrating off-site at concentrations that may present a future risk to off-site users of shallow groundwater, should the nature or intensity of land use change and groundwater extraction occurs near to the site. Boundary monitoring wells at the former sewage treatment plant and AFFF testing area (Source ID 13), southern boundary, eastern boundary and northern boundary recorded groundwater PFAS concentrations above adopted screening criteria. In particular, impacts on the southern, eastern and southeastern boundaries have the greatest potential for off-site migration of PFAS. However, it is likely that the shallow Upper alluvium groundwater impacts are being intercepted by the Eastern Main Drain in the southeast. There is also a potential that discharge of Upper Alluvium groundwater could occur to The Heart Morass to the south of the site at concentrations exceeding the adopted ecosystem screening criteria.

Lower Alluvium and Haunted Hills Formation groundwater results exceed adopted drinking water and recreational use screening criteria at monitoring wells adjacent to the former fire training area (Source ID 08) and on the boundary in the southeast of the site. It is likely that the shallow Upper alluvium groundwater impacts are being intercepted by the Eastern Main Drain and the high concentrations within the Lower Alluvium aquifer have the potential to be migrating off-site in the southeastern area.

Legacy AFFF was widely used across many parts of the site (4 key source areas), with higher PFAS concentrations (using first pass screening of >5mg/kg and higher leachability) recorded near the following sources:

Northwest - Maintenance areas, former fire station and chemical store in the northwest (Source IDs 01, 02, 04, 05 and 14).

Fire Station and AFFF Testing Area - The current fire station and AFFF testing area (Source IDs 06 and 16).

Southeast - The former fire training areas in the southeast (Source IDs 08 and 09).

Central - Current fire training and former sewage treatment plant and AFFF testing area (Source ID 13 and 11). Given the reported PFAS concentrations in soil and grass, the nature and behaviour of PFAS in the broader environment, soil impacts are likely to present an ongoing source of impacts to groundwater and surface water from infiltration and overland flow, respectively.

Pathway/s Groundwater migration and discharge to surface waters.

Groundwater migration, extraction and uptake into food chain from stock watering or irrigation, or direct exposure to off-site residents via pathways of groundwater utilisation.

Infiltration of soil impacts into shallow groundwater and overland flow from impacted soil areas into on-site drainage lines.


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Receptor/s Discharge to surface waters in drains and The Heart Morass, with bioaccumulation into aquatic animals (fish and ducks) and subsequent consumption by ecological predators, or home consumption (by humans) of recreationally caught fish and ducks. Potentially elevated risks are also identified associated with the public consumption of fish caught in the vicinity of the Eastern Main Drain outlet; risks are low and acceptable for this pathway in other areas of The Heart Morass.

Discharge to surface waters in drains and The Heart Morass, with bioaccumulation into aquatic animals (fish and ducks) and subsequent consumption by ecological predators, or home consumption (by humans) of recreationally caught fish and ducks. Potentially elevated risks are also identified associated with the public consumption of fish caught in the vicinity of the Eastern Main Drain outlet; risks are low and acceptable for this pathway in other areas of The Heart Morass. Shallow groundwater used for irrigation and stock watering at off-site properties, and subsequent bioaccumulation into livestock or produce for home or commercial human consumption. Human consumption of groundwater (unlikely due to quality), or utilisation of shallow groundwater for other (non-potable) uses.

Deeper groundwater used for irrigation and stock watering at off-site properties, and subsequent bioaccumulation into livestock or produce for home or commercial human consumption. Human consumption of groundwater.

Discharge to surface waters in drains and The Heart Morass, with bioaccumulation into aquatic animals (fish and ducks) and subsequent consumption by ecological predators, or home consumption (by humans) of recreationally caught fish and ducks. Potentially elevated risks are also identified associated with the public consumption of fish caught in the vicinity of the Eastern Main Drain outlet; risks are low and acceptable for this pathway in other areas of The Heart Morass. Infiltration to shallow groundwater used for irrigation and stock watering at off-site properties, and subsequent bioaccumulation into livestock or produce for home or commercial human consumption. Human consumption of groundwater (unlikely due to quality), or utilisation of shallow groundwater for other (non-potable) uses.

Primary Source/s PFAS in shallow groundwater migrating in the direction of groundwater flow to the east, southeast and south.

PFAS in shallow groundwater migrating off-site in the direction of groundwater flow to the east, southeast and south.

PFAS in groundwater migrating vertically from shallow impacted groundwater and then migrating off-site in the direction of groundwater flow to the south, east and southeast.

PFAS in soils at impacted source areas.

Secondary Source/s Impacted soil sources infiltrating to shallow groundwater.

Vertical migration of PFAS impacts in shallow groundwater. Impacted soil sources infiltrating to shallow groundwater.

Low level soil concentrations recorded across the site. Impacted infrastructure in existing operational areas (such as PFAS impacted concrete), and demolition wastes stored on-site.

Contributing Source/s Diffuse PFAS low concentrations in soil across the entire site infiltrating to shallow groundwater.

Impacted soil sources infiltrating to shallow groundwater. Diffuse PFAS low concentrations in soils off-site, which may be sourced from agricultural products, infiltrating to shallow groundwater.

Consequence

Current Impacts In southeast of site, discharging to Eastern Main Drain and providing ongoing source of potential impacts to sensitive receptors off-site. Otherwise, no users of groundwater on-site identified and risk to maintenance workers assessed to be low and acceptable.

None – No users of shallow groundwater identified.

None – deeper groundwater currently unimpacted (see note below)

Not providing a direct risk to receptors currently (except Risk 4), but providing a secondary source of impacts to other environmental media and receptors. Ongoing impacts to sensitive receptors off-site.


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Potential Impacts Likely to be providing a secondary source of impacts to stormwater discharge in some areas, thereby providing an ongoing source of potential impact to sensitive receptors off-site. Potential discharge to The Heart Morass in future would provide ongoing source of impact, even if drainage management measures implemented.

Private property installs bore for extraction of shallow groundwater (drinking (unlikely due to quality), stockwatering or irrigation) or intersection of shallow groundwater into private dam occurs in future. Discharge to The Heart Morass providing ongoing source of impact, even if drainage management measures implemented.

Private property bores used for irrigation and stock watering become impacted from migration and risk revision for off-site consumption of livestock required. A potentially elevated risk may impact surrounding land owner’s agriculture use and livelihood.

None identified in Final HHERA, however, likely to be providing a secondary source of impacts to stormwater discharge and shallow groundwater in some areas. Ongoing source of impacts on-site and to sensitive receptors off-site.

Temporal Risks Migration of shallow groundwater into the Eastern Main Drain may provide an ongoing source of risk to The Heart Morass (See Risks 1, 2 and 3). Further, shallow groundwater risk to maintenance workers may change if concentrations in groundwater <2m deep increase. Requires monitoring to assess temporal trends in concentrations and requirement for revision of risk or management.

Migration of shallow groundwater into The Heart Morass may provide an ongoing source of risk to The Heart Morass (See Risks 1, 2 and 3). Requires monitoring to assess temporal trends in concentrations and requirement for revision of risk or management.

Concentrations in groundwater in one private stockwatering bore within lower alluvium/haunted hills recorded a concentration exceeding drinking water and recreational use criteria, which would represent a risk to off-site livestock and milk consumption. Subsequent re-sampling identified a lower concentration, however, temporal monitoring suggested to assess temporal trends in concentrations and requirement for revision of risk or management.

Extent

Location and Extent Generally across the site, coincident with and migration from key soil source areas. However, further assessment of the extent of Upper Alluvium impacts and potential for impacts of Lower Alluvium (where present) and Haunted Hills Formation aquifers in these source areas, within or down/up-gradient of the source zones, is required to understand the nature and extent of groundwater impacts. However, given the findings of the DSI and distance from the southern boundary (and therefore off-site receptors) and downgradient results this is not considered a priority as the risk to current receptors is considered to be low.

The lateral extent of Upper Alluvium impacts has not been delineated and require further investigation down-gradient of site boundaries to identify the extents of impact and potential management options such as groundwater restriction zones. The nature and extent of this impact requires delineation to provide supporting lines of evidence of whether Upper Alluvium groundwater is or isn't discharging into The Heart Morass and what impact this may have on the efficacy of implementation of potential management measures.

Off-site private properties to south and southeast. There is potential for deeper impacts to be present in the southeastern area and migrating from site. The lithological profile in this area (based on one borehole) indicates that downward migration to this aquifer should be limited by the presence of a silty clay, clayey silt layer that is acting as a low permeability aquitard. However, given the limited amount of lithological information in the area and the complex, heterogeneous and discontinuous nature of the interbedded clay and sand deposits, it is possible that there are pathways and vertical leakage to the Haunted Hills Formation from the Lower Alluvium aquifer, which are used on private properties down-gradient for irrigation and stock watering purposes. Extent of impact to deeper groundwater at current fire station is unknown, with high shallow groundwater concentrations recorded, and potential for off-site migration unknown.

The assessment of nature and extent in soil (including stockpiles present at the site and concrete waste) is not likely to provide adequate certainty and delineation of the nature and extent (in particular, vertical distribution) for development of management or remediation options should these be required in future.


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Existing Management Measures

Defence Discontinue use of legacy AFFF Discontinue use of legacy AFFF Discontinue use of legacy AFFF Discontinue use of legacy AFFF. Soils from Source ID 14 are being temporarily stored in covered stockpiles from construction of new fuel tank farm. Guidance for construction project PFAS management and stockpile requirements implemented.

Stakeholders None Southern Rural Water extraction bore construction licencing.

Southern Rural Water extraction bore construction licencing.

EPA/DHHS advice to grazier that home consumption of livestock not recommended. None

Potential Additional Controls Source Management Further investigation or monitoring down-gradient of source areas to identify the extents of impact or future migration of impacts.

Source Management Further investigation down-gradient of site boundaries to identify the extents of impact. Definition and implementation of a groundwater quality restricted use zone or a licencing restriction overlay/assessment protocol to be implemented by Southern Rural Water.

Further investigation or monitoring down-gradient of site boundaries to identify the extents of impact or migration of impacts. Definition and implementation of a groundwater quality restricted use zone or a licencing restriction overlay/assessment protocol to be implemented by Southern Rural Water.

Source Management


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5 ONGOING MONITORING PLAN

5.1 Overview

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

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

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

5.1.1 Objective and purpose

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

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

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

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

5.1.2 Impacted decisions

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

• additional investigations

• re-assessment of one or more remediation or containment actions

• additional remediation or containment actions

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

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

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

• changes or refinements to the monitoring network, frequency and parameters

5.1.3 Related documentation

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


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5.2 OMP communications

The following will be shared with relevant State/Territory authorities and made publicly available:

• OMP

• monitoring data collected during the implementation of the OMP

• decisions made in response to the data collected during implementation of the OMP

• changes to the OMP in response to incoming data over the implementation period

5.3 OMP summary

The OMP will include the following monitoring:

• On-site groundwater monitoring wells installed in both the alluvial and haunted hills formation aquifers.

• Off-site point of use groundwater bores within the Monitoring Area (Figure 1).

• On-site open and closed stormwater drainage network and surface water lakes/ponds.

• Off-site open drainage points and The Heart Morass.

The OMP also sets out uncertainties in investigations, monitoring and management that may require consideration of contingency measures and/or reassessment of risk with changes in conditions (higher concentrations of surface water, migration of groundwater), further investigations establishing a greater extent of groundwater than identified, or implementation of management measures.

The primary implementation period of the OMP will be 3 years during implementation of potential management options. After this time the extended implementation period of the OMP will be reviewed to assess the extent of the monitoring network and frequency required, based on the specific characteristics of the Management Area, the behaviour of the plume measured against specific data trends, and the revision of risk that may occur based on the assessment of results obtained from the monitoring.

5.4 OMP review

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


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6 OPTIONS IDENTIFICATION AND ANALYSIS

6.1 Options identification

The management options feasibility assessment approach broadly comprises:

1. Technology screening – identification and screening assessment of potential technologies that have the capability to manage soil/ sediment and groundwater impacted by PFAS. The preferred technologies are then developed into potential management options for further evaluation.

2. Detailed feasibility assessment: a. Detailed evaluation of each management option; and b. A comparative assessment of the management options.

This management option assessment approach is consistent with:

• Defence’s guiding principles presented in Section 1.6.

• United States (US) of America Federal Remediation Technologies Roundtable (US FRTR) technology screening matrix (http://www.frtr.gov/matrix2/section3/table3_2.pdf, accessed May 2018)

• ITRC Publication Remediation Technologies and Methods for Per- and Polyfluoroalkyl Substances (PFAS), ITRC March 2018.

• PFAS National Environment Management Plan, Australian and New Zealand Heads of EPA (HEPA).

6.1.1 Method

The identification of potentially feasible technologies was conducted and consistent with the US FRTR technology screening matrix, the principles of Hazard Control and Defence’s PMAP approach, whereby hazard elimination is most preferred and administrative controls and use of protective equipment is least preferred. This is presented diagrammatically below:

This approach is consistent with Defence prioritising source management as preferred to pathway management and pathway management as preferable to receptor management.

http://www.frtr.gov/matrix2/section3/table3_2.pdf


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6.2 Options analysis

Based on the summary screening, the following broad generic treatment technology categories apply to the treatment of land and water contamination:

Soil and Sediment Treatment Technology Categories

Surface Water and Groundwater Treatment Technologies Categories

In situ Biological treatment Biological treatment

Physical/chemical treatment Physical/chemical treatment

Thermal treatment Thermal treatment

Ex situ Excavation and off-site disposal Extraction and biological treatment

Excavation and biological treatment

Extraction and physical/chemical treatment

Excavation and physical/chemical treatment

N/A

Excavation and thermal treatment

N/A

Other On-site containment in an engineered facility

Hydraulic containment

In situ management Monitored natural attenuation

In-situ management

Based on the identified options, a summary screening assessment was applied to determine from the potentially available options, which could be retained based on whether the technology is technically capable of destroying or immobilising PFAS.

6.2.1 Screening Results

The summary screening assessment of soil/sediment and groundwater technologies is presented in Appendix E, separated in soil/sediment treatments (Table E1-A), and surface water and groundwater treatments (Table E1-B)).

Screening of potential technologies identified the following technologies for option development and further feasibility evaluation as outlined in Appendix E2:

• Soil/ Sediments:

Excavation and off-site disposal;

Excavation and thermal treatment (high temperature incineration) at an off-site facility;

Excavation or in-situ management of impacted materials using an stabilisation/immobilisation amendment;


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In-situ management of impacted materials via capping;

Excavation and on-site containment in an engineered facility (repository containment). • Surface Water and Groundwater:

Surface water capture and treatment;

Groundwater extraction, or excavation and dewatering, and treatment, in isolation or as part of an overall management option to support one of the above soil/sediment options; and

Drainage infrastructure improvements to the open unlined drainage system and the closed concrete drainage system.

Further to the summary screening of technologies, receptor management options comprising administrative controls (e.g. consumption advisories) have also been considered.

6.3 Comparative analysis

Subsequent to the technology screening, potential management options were developed for detailed feasibility evaluation and comparative analysis. The options were formulated to combine management and engineering controls (rather than just a specific technology) to meet the PMAP framework. This evaluation uses a ‘traffic light’ approach based on the analysis criteria presented in Section 3 and Appendix D, to allow relative comparison of management options.

The management options are conceptually described in Table E2 and comprise primary source control and secondary source control, pathway management and receptor administrative controls. The potential management options were evaluated against the assessment criteria presented in Appendix D. The detailed identification and analysis of an option or set of options for each risk is set out in Appendix E, Table E3-A through F.

The results of the comparative analysis were used to develop the following comparative assessment of management responses that could be considered for each of the sources and source areas contributing to the potentially elevated risks. They have been assessed on their relative risk reduction benefit - level of risk reduction likely to be achieved relative to implementation effort (based on technical, logistical and financial considerations). The assessment has been presented based on the risks identified in the Final HHERA and are subject to change upon finalisation of the HHERA.

Based on the comparative analysis and assessment, while acknowledging that the primary source has been eliminated (legacy AFFF is no longer in use at the site since 2004) and will require monitoring of measurable outcomes to assess improvements in the receiving environment, drainage improvement works and continued implementation of receptor controls are the preferred management options that are likely to provide the most significant environmental benefits to manage the potentially elevated risks identified for the Base.


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Table 3: Management Option Evaluation for Risk Areas

Risk Area / Management Option

Technical applicability Logistical, Defence and Stakeholder considerations

Financial considerations

Relative Risk Reduction Benefit

Principal receptor - The Heart Morass

Preferred Management Option – Administrative Control - Given the significant disturbance presented by soil treatment options and the scale and cost associated these options, it is not feasible to drain and treat sediment from The Heart Morass. The principal option that ranked highest is the current approach of the regulator implementing administrative controls and consumption advisory notices. Whilst surface water capture and treatment appears favourable, this option has a significant dependency on sediment treatment within THM, as without sediment treatment surface water within the THM would be re-contaminated by partitioning from sediment and further, biota would still be exposed to PFAS impacted sediments. Administrative controls will effectively manage potentially elevated risks to human receptors; while this approach will not reduce exposure to the ecosystem, other options will either be associated with marginal relative risk reduction benefit to only some elements of the ecosystem (water treatment) or are likely to be associated with greater harm to the ecosystem (sediment treatment).

Source Control – Soil/Sediment Management

Excavation and treatment and/or disposal is technically possible and ranks above other source control measures comprising capping and on-base repository. However, there is no licensed off-site disposal option and soil/sediment treatment is only just emerging with limited vendor capability.

The scale of this undertaking and the unacceptable disturbance to current and functional ecosystem and associated risks does not warrant such an approach. Capability likely to be affected if on-base repository constructed. Owners Field & Game, Parks Victoria and other THM users would be unlikely to accept the significant disturbance associated with soil disturbance works.

Given area of THM and likely depth of impacts, financially this is considered too costly and is not a viable option.

Given the destruction of the ecosystem required the overall initial impact would be negative. This option also has significant dependence on treatment of source areas on-base, to minimise ongoing impacts to THM from secondary sources.


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Pathway Management – water

Treating impacted water within THM is technical feasible using available water treatment technology. However, the presence of impacted sediment and the presence of ongoing impacted discharge from base to the THM means it is not feasible to treat water once only in THM.

Minimising interconnection with the Latrobe River means significant drainage control would be required during the works to minimise interaction with base discharge and interactions with the Latrobe River. Unlikely to affect Defence capability. Likely to be acceptable to all stakeholders.

Likely to be very costly capital and ongoing O&M expenditure (retreatment of waters once re-contaminated unless sediments managed).

Treating the water within THM would provide marginal relative risk reduction benefit without treating sediment within THM or treating on-base source areas contributing to this risk.

Exposure (receptor) Control

Consumption advisory advice is an applicable and proven approach to minimising human exposure by restricting an activity in a contaminated environment.

Administration of advice and monitoring enforcement is completed at other Victorian sites and regions (e.g. Hazelwood Pondage, Lower Reaches of Maribyrnong and Yarra Rivers). Unlikely to affect Defence capability. May not be acceptable to specific affected stakeholders.

Insignificant direct costs.

This option does not remove/isolate impacted media within this area, so no relative risk reduction benefit anticipated. The minimising of exposure via receptor control advisory notices and ongoing education would provide significant human exposure reduction benefits.


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Principal transport pathway - Site Surface Water (Drainage)

Preferred Management Option –Drainage Improvement - Drainage improvement was considered on its own merit given the size of the site and importance of managing drainage discharge as it is has historically been a key pathway for the off-site transport of PFAS in surface waters off-site. The improvements across the open unlined drainage network comprising sediment removal and lining drains would offer the greatest relative risk reduction benefit based on ease of implementation and cost. There would also be benefit in improving the closed (concrete) network in operational areas to reduce PFAS discharge from the base to THM. However, the improvement to the closed network would involve works that could significantly affect defence capability and would be at significant cost. These works may only be achievable as part of other scheduled infrastructure improvement works where PFAS impacted concrete drainage and pavements could be opportunistically replaced. Given the complexity of interactions and linkages to Defence capability, a necessary first step in considering drainage improvement is to complete discharge assessment works and assess ongoing monitoring data in order to review the feasibility of drainage improvement options and what their overall relative risk reduction benefit will be to the reduction of PFAS impacted water and sediments within THM. In the meantime, the current approach of regulators implementing administrative controls and consumption advisory notices ranks highest in terms of managing risk.


Drainage improvement by removing impacted sediment and impacted concrete infrastructure is technically feasible, and requires a sediment storage/treatment option once removed. Unless source areas are managed, then drainage infrastructure likely to be re-contaminated.

Significant logistical constraints on the timing and scale of the works involved. May require interim water treatment or temporary diversions, while upgrades and sediment removal are occurring. Capability likely to be significantly affected, in particular for works associated with the closed drainage network. Likely to be acceptable to all stakeholders.

Likely to be very costly capital for on-site repository or treatment of sediments.

This option is considered to provide moderate relative risk reduction benefit for the expenditure incurred, however, it is dependent on treating on-base source areas contributing to this risk that may continue to contribute to impacted waters in the drains, and therefore off-site risks.


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Treating impacted water within drainage lines is technical feasible at ‘end of pipe’ where water discharges to THM using available water treatment technology. However, the presence of impacted drainage infrastructure and sediments within/lining the open network, means there is limited value to treat water across the drainage network as it will be re-contaminated once in the drainage lines.

Success highly dependent on other measures (source management) and generally wouldn't be considered on its own. Requires ongoing implementation without other source controls/management. Unlikely to affect Defence capability. Likely to be acceptable to all stakeholders.

Likely to be very costly capital and in particular ongoing O&M expenditure (retreatment of waters once re-contaminated unless sediments managed or runoff from source areas, and/or shallow groundwater discharge managed).

This option is considered to provide marginal relative risk reduction benefit; however, it is highly dependent on treating on-base source areas and drainage line sediments contributing to this risk. Whilst it would reduce off-site discharge, and could be considered as an interim temporary measure, it is likely to only provide marginal risk reduction in THM whilst impacted sediment and water remains within THM.


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Engineering Control

It is technically feasible to sidecast the first flush leaving the site to an evaporation/detention basin for subsequent treatment, or lining open drains to remove pathway of sediment impacts re-contaminating water, and/or discharge of shallow groundwater into open drains.

For evaporation/detention basin - requires large parcel of land to detain captured water and subsequently evaporate/treat. May require acquisition of adjoining land or reduction in lease area. Increased risk of bird strike and creates additional aquatic environment with associated ecological risks. May affect Defence capability. Likely to be acceptable to all stakeholders.

Likely to be costly capital and ongoing O&M expenditure (treatment of detained waters unless drainage improvement sediments managed, or drains lined) for retention/detention option. Moderately high capital expenditure for lining open drains.

This option is considered to provide significant relative risk reduction benefit, however, it is likely to be highly dependent on treating on-base source areas contributing to this risk. Whilst it would reduce off-site discharge, it is likely to only provide marginal risk reduction in THM whilst impacted sediment and water remains within THM. Lining of drains would impact on existing ecosystems within these drains, however, it would reduce the pathway of ecological risk to higher order predators that may feed from biota within these open drains. Improvement or lining of open drains in southeast section of main drain may increase off-site migration potential of shallow groundwater in this area.

Source Area 1 - Southeast Area

Preferred Management Option – Source management (In-situ Capping or Repository) – Given the historical fire training and waste burial areas within this open unsealed area, identified a combination of source management (capping or containment) and the use of engineering or administrative controls to manage receptor exposure (cattle grazing) as more favourable options. These options also consider the smaller scale of the source areas (fire training areas) and proximity to the south eastern base boundary. These options could also potentially be integrated with shallow groundwater interception to reduce groundwater discharge to the Eastern main drain and manage ongoing impacts for potential off-site discharge of groundwater and surface water.


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Either excavation and treatment and/or disposal is technically feasible. However, there is no licensed off-site disposal option and soil/sediment treatment is only just emerging with limited vendor capability. Containment via either in-situ capping and/or ex-situ repository is more technically feasible.

Given the lack of infrastructure and the open unsealed nature of this area excavation and treatment/disposal or containment does not represent significant logistical constraints. Unlikely to affect Defence capability. Likely to be acceptable to all stakeholders.

Moderately high capital expenditure and low O&M costs.

This option is considered to provide moderate relative risk reduction benefit for the expenditure incurred as it will effectively isolate impacted material from stormwater interactions and reduce infiltration and resultant migration to shallow groundwater.


Shallow groundwater capture and/or interception and treatment is technically feasible. However, unless source areas managed then capture and treatment will be required in perpetuity.

Success highly dependent on other measures (source management) and generally wouldn't be considered on its own. Unlikely to affect Defence capability. Likely to be acceptable to all stakeholders.

Likely to be costly capital and in particular ongoing O&M expenditure (permanent water treatment unless sources managed).

This option is considered to provide marginal relative risk reduction benefit for the expenditure incurred as it will require ongoing implementation of energy intensive interception and treatment. Further, this option does not manage source areas from stormwater interactions. As such, this option could not be completed in isolation to reduce the risks identified.


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Restricting grazing access to source areas by fencing or an advisory regarding home consumption is an applicable and proven approach to minimising exposure by restricting an activity in a contaminated environment. While risks are assessed to be low and acceptable for a public consumption pathway, pragmatic steps to minimise livestock exposure in source areas would reduce potential exposure via all consumption pathways.

Administration of advice and monitoring enforcement is routinely undertaken. Unlikely to affect Defence capability. May not be acceptable to specific affected stakeholders.


This option does not remove/isolate impacted media within this area, so no relative risk reduction benefit anticipated. The minimising of exposure via receptor control advisory notices (regarding home consumption) and ongoing education would provide significant exposure reduction benefits.

Source Area 2 - Fire station and Testing Area

Preferred Management Option – Source management (In-situ Capping) – The operational and airside nature of this critical infrastructure resulted in in-situ management (capping) as the highest ranking option. This option may be tailored and is scalable to incorporate existing apron drainage. This approach, whilst principally involves isolating impacted soils from surface water runoff and drainage, also reduces local recharge and infiltration and offers secondary benefit by reducing ongoing shallow groundwater impact from vadose zone soils. Given the area presents a source of impact to the surface water base drainage system, in-situ management and associated infiltration reduction is more beneficial than managing shallow groundwater interception alone or in combination with other options.


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Either excavation and treatment and/or disposal is technically feasible. However, there is no licensed off-site disposal option and soil/sediment treatment is only just emerging with limited vendor capability. Containment in-situ capping is more technically feasible, while ex-situ containment (i.e. repository) is not as technically feasible given disruption associated with excavation works in areas of critical infrastructure.

Significant logistical constraints due to current fire station location (airside) and critical nature of this infrastructure. Highly likely to affect Defence capability. Unlikely to be acceptable to all stakeholders.

Likely to be very costly capital expenditure.

This option is considered to provide moderate relative risk reduction benefit for the expenditure incurred as it will effectively isolate impacted material from stormwater interactions and reduce infiltration and resultant migration from vadose zone impacts to shallow groundwater. However, logistical constraints will limit installability and therefore reduce effectiveness compared with if full access was otherwise available. These works may only be achievable as part of other scheduled infrastructure improvement works where additional pavement and drainage could be opportunistically upgraded.





This option is considered to provide marginal relative risk reduction benefit for the expenditure incurred as it will require ongoing implementation of energy intensive interception and treatment. Shallow groundwater is also located a significant distance from receptors or discharge points, and the migration to, or interaction with the open drains on-site is unknown. Further, this option does not manage source areas from stormwater interactions. As such, this option could not be completed in isolation to reduce the contribution to risks identified.


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Source Area 3 - Northwest Area

Preferred Management Option – Source management (In-situ Capping) – The restricted access and operational nature of this area indicated localised in-situ management (capping) being the more favourable option. However, operational infrastructure means the work could be incorporated into infrastructure upgrade works whereby capping is replaced by engineered pavement improvements (i.e. concreting open grassy areas where operational activities may take place) to reduce infiltration. It is noted that in this area, a large covered PFAS-containing soil stockpile is present from soil removal works for a recent tank farm upgrade (Source ID 14).


Either excavation and treatment and/or disposal is technically feasible. However, there is no licensed off-site disposal option and soil/sediment treatment is only just emerging with limited vendor capability. Containment in-situ capping is more technically feasible, while ex-situ containment (i.e. repository) is not as technically feasible given disruption associated with excavation works in areas of critical infrastructure.

Significant logistical constraints due to current critical nature of operational infrastructure. In-situ capping and pavement improvement (i.e. paving unpaved areas) could be incorporated into infrastructure. Highly likely to affect Defence capability. Unlikely to be acceptable to all stakeholders.

Likely to be very costly capital expenditure.

This option is considered to provide moderate relative risk reduction benefit for the expenditure incurred as it will effectively isolate impacted material from stormwater interactions and reduce infiltration and resultant migration from vadose zone impacts to shallow groundwater. However, logistical constraints will limit installability and therefore reduce effectiveness compared with if full access was otherwise available. These works may only be achievable as part of other scheduled infrastructure improvement works where additional pavement and drainage could be opportunistically upgraded.


68 August 2018







Success highly dependent on other measures (source management) and generally wouldn't be considered on its own. May be more feasible than implementing in-situ containment (capping)/pavement improvements. Unlikely to affect Defence capability. Likely to be acceptable to all stakeholders.


This option is considered to provide marginal relative risk reduction benefit for the expenditure incurred as it will require ongoing implementation of energy intensive interception and treatment. Further, given the upgradient location of these sources, discontinuous and heterogenous aquifer characteristics, and significant distances to site boundaries or drainage discharge points to surface water receptors, it is unlikely that this option will provide any additional benefit to reducing contribution to the risks identified compared with natural attenuation processes. Finally, this option does not manage source areas from stormwater interactions. As such, this option could not be completed in isolation to reduce the contribution to risks identified.

Source Area 4 - Central Area

Preferred Management Option – Source management (In-situ Capping or Repository) – The open nature of this area identified localised in-situ management (capping) or repository as being the more favourable options. However, operational infrastructure means the improvements could be incorporated into infrastructure upgrade works whereby engineered capping is replaced by pavement improvements.


69 August 2018






Either excavation and treatment and/or disposal is technically feasible. However, there is no licensed off-site disposal option and soil/sediment treatment is only just emerging with limited vendor capability. Containment via either in-situ capping and/or ex-situ repository is more technically feasible.

Given the lack of infrastructure and the open unsealed nature of this area, excavation and treatment/disposal or containment does not represent significant logistical constraints. May affect Defence capability in area of runways (Source ID 11). Likely to be acceptable to all stakeholders.

Moderately high capital expenditure and low O&M costs.

This option is considered to provide moderate relative risk reduction benefit for the expenditure incurred as it will effectively isolate impacted material from stormwater interactions and reduce infiltration and resultant migration to shallow groundwater.





This option is considered to provide marginal relative risk reduction benefit for the expenditure incurred as it will require ongoing implementation of energy intensive interception and treatment. Further, given the central location of these sources, local groundwater direction, discontinuous and heterogenous aquifer characteristics, and significant distances to site boundaries or discharge points to surface water receptors, it is unlikely that this option will provide any additional benefit to reducing contribution to the risks identified than attenuation processes. Finally, this option does not manage source areas from stormwater interactions. As such, this option could not be completed in isolation to reduce the contribution to risks identified.


70 August 2018

6.4 Integrated options analysis outcomes

Using the comparative assessment, an integrated options assessment has been undertaken and is presented below. The assessment has been presented based on the risks identified in the Final HHERA. The integration of options for each risk area has considered overall benefit and the guiding principles in Section 1.6, in particular source management in preference to pathway management, which are both preferable to receptor management.


71 August 2018

Table 4: Management Option Evaluation for Management Area





Integrated Overall Management Area Option

Preferred Overall Management Option – The principal PFAS off-site transport pathway has historically been, and continues to be contaminated surface water from the source areas entering the stormwater drainage network, and drainage itself, discharging across the site boundary, principally via the Eastern (Main) Drain. To reduce the PFAS contribution to the drainage lines, drainage improvement and source area management could be integrated. Effective source area management comprising hydraulic isolation of surface soils (in accessible areas) via in-situ capping or repository containment has been identified. Integrating these activities with the following would provide a moderate environmental improvement:

Multiple source area management by in-situ management (capping) or repository, and Drainage line improvements to reduce discharge of PFAS impacted water off-site to The Heart Morass, supplemented by Administrative controls (Defence and Government Agencies) remaining in place to address receptor management in the near-term.

Consideration could also be given to shallow groundwater management in the southeastern area where there is potential for ongoing discharge of PFAS impacts to surface water in the Eastern Main Drain and migration of groundwater off-site. However, where drainage line improvement works are implemented and eliminate the discharge of shallow groundwater into the drainage system, then this option may not be necessary given shallow groundwater is not used in the surrounding area. It has been identified that the extent of migration of groundwater off-site and its contribution to current potentially elevated risks associated with consumption and ecological pathways in The Heart Morass is unknown, with limited shallow groundwater data off-site, but it is a significant distance in a discontinuous and heterogenous geology where attenuation and dispersion are also likely to occur. However, the relative risk reduction benefit of the integration of these options may only be marginal to moderate, where ongoing monitoring may indicate a similar improvement as a result of ceasing the use of the legacy AFFF (the primary source of impacts) in 2004. Given this, the overall focus of works in the first instance should be the implementation a drainage improvement strategy with associated discharge assessment works (including inputs into the system on base and the outputs from base), monitoring data to support identification of priority areas and review of the technical feasibility of drainage improvement options and what their overall relative risk reduction benefit will be to the reduction of PFAS impacted water and sediments within THM. In the meantime, the current approach of regulators implementing administrative controls and consumption advisory notices ranks highest in terms of managing the potentially elevated risks.


72 August 2018






Containment in-situ capping is more technically feasible, while ex-situ containment (i.e. repository) is not as technically feasible given disruption associated with excavation works in areas of critical infrastructure associated with two of the soil source areas (current fire station, MEOMS in northwest and end of runway in central). Drainage improvement by removing impacted sediment and impacted concrete infrastructure is technically feasible, and requires a sediment storage/treatment option once removed. Therefore, when addressing all source areas as integrated response, a repository provides more benefit having feasibility for both soil and drainage line sediment, while impacted materials can be managed longer term all in one location with the associated benefits of: reduced containment costs as a whole across the base; the potential that in the future more cost effective treatment options may be available for large volumes of PFAS impacted wastes in one area.

Significant logistical constraints on the timing and scale of the works involved from current fire station, MEOMs and airside locations and critical nature of some of this infrastructure. May require interim water treatment or temporary diversions, while upgrades and sediment removal are occurring. Base has room in non-operational areas for siting of a repository. Highly likely to affect Defence capability. Unlikely to be acceptable to all stakeholders.

Likely to be very costly capital expenditure for on-site repository and removal of sediments from drains, or removing drainage infrastructure from operational areas

This option is considered to provide moderate relative risk reduction benefit for the expenditure incurred as it will effectively isolate impacted material from stormwater interactions and reduce infiltration and resultant migration to shallow groundwater, which will reduce the contribution to impacted waters in the drains, and therefore off-site risks. An on-site repository provides more relative risk reduction benefit having impacted soils managed all in one location for future potential cost effective treatment options that may become available.


73 August 2018





Pathway Management – Groundwater


Success highly dependent on other measures (source management) and generally wouldn't be considered on its own. Requires ongoing implementation without other source controls/management. Unlikely to affect Defence capability. Likely to be acceptable to all stakeholders.


Overall likely to be marginal relative risk reduction benefit for shallow groundwater treatment for the expenditure incurred as it will require ongoing implementation of energy intensive interception and treatment. Could be considered in the southeastern area, and possibly the current fire station (however, the net contribution from this source to groundwater and discharge interactions with surface water drainage lines has not been characterised), where managing discharge to drains may provide some added benefit to reducing the contribution of surface water impacts to the risks identified. Further, this option does not manage source areas from stormwater interactions. As such, this option could not be completed in isolation to reduce the risks identified.


74 August 2018





Engineering Control – Site Surface Water (Drainage)

It is technically feasible to sidecast the first flush leaving the site to an evaporation/detention basin for subsequent treatment, or lining open drains to remove pathway of sediment impacts re-contaminating water, and/or discharge of shallow groundwater into open drains.

For evaporation/detention basin - requires large parcel of land to detain captured water and subsequently evaporate/treat. May require acquisition of adjoining land or reduction in lease area. Increased risk of bird strike and creates additional aquatic environment with associated ecological risks. May require interim water treatment or temporary diversions, while upgrades are occurring. May affect Defence capability. Likely to be acceptable to all stakeholders.

Likely to be costly capital and ongoing O&M expenditure (treatment of detained waters unless drainage improvement sediments managed).

This option is considered to provide significant relative risk reduction benefit; however, it is likely to be highly dependent on treating on-base source areas contributing to this risk. Whilst it would reduce off-site discharge, it is likely to only provide marginal risk reduction in THM whilst impacted sediment and water remains within THM. Lining of drains would impact on existing ecosystems within these drains, however, it would reduce the pathway of ecological risk to higher order predators that may feed from biota within these open drains. Improvement or lining of open drains in southeast section of main drain may increase off-site migration potential of shallow groundwater in this area.


Consumption advisory advice is an applicable and proven approach to minimising exposure by restricting an activity in a contaminated environment.

Administration of advice and monitoring enforcement is completed at other Victorian sites and regions (e.g. Hazelwood Pondage, Lower Reaches of Maribyrnong and Yarra Rivers). Unlikely to affect Defence capability. May not be acceptable to specific affected stakeholders.


This option does not remove/isolate impacted media within this area, so no relative risk reduction benefit anticipated. The minimising of exposure via receptor control advisory notices (for home consumption of livestock raised on-Base, and for consumption of fish and ducks from The Heart Morass) and ongoing education would provide significant exposure reduction benefits.


75 August 2018

7 RECOMMENDED PMAP RESPONSE ACTIONS

7.1 List of recommended PMAP response actions

Based on the comparative analysis and the integrated analysis, the recommended response actions for the identified potentially elevated risks are set out below:

1. Discontinue use of legacy AFFF containing PFAS (3M lightwater formulation) at the site (Eliminate Primary Source) – Currently implemented.

2. Manage use of AFFF containing other PFAS (such as Ansulite formulation) for emergency response (Engineering Controls).

3. On-site drainage improvement works (Engineering Controls), which may include the following process:

a) Implement ongoing monitoring plan to assess the effectiveness of ceasing the use of AFFF. The monitoring works will provide trend data for surface water and sediment concentrations both on- and off-site. In addition to providing a measure of the effectiveness of ceasing the use of AFFF, these trends will provide information to supplement a drainage improvement feasibility study.

b) Discharge and drainage improvement feasibility study to inform scale and extent of preferred method of drainage improvement works. The study will also aim to establish achievable and measurable outcomes for improvement in the receiving environment – The Heart Morass (i.e. the success measures which would be used to assess the effectiveness of drainage improvement works). Requires data collection to inform drainage and PFAS inputs and outputs for design and feasibility purposes, including: flow conditions; partitioning rate of PFAS from sediments to water; modelling of flux of PFAS from Base into The Heart Morass and from various source areas on the Base into surface water; characterise the mass, distribution and partitioning of PFAS within The Heart Morass to allow comparison with the flux through site drainage inputs; and, modelling of shallow groundwater discharge into the drains and contributions of shallow groundwater from source areas with significant potential for discharge of PFAS impacts to surface water drains.

c) Review of PMAP for additional management controls to be considered once discharge study is completed and understanding of significant contributions from source areas and various media is known.

d) Implementation of preferred management option identified in management feasibility, where cost-benefit can be demonstrated for the implementation and risk mitigation to be achieved.

4. Continue to publicise regulator advisories (administration controls):

a) Consumption advisory for home consumption of livestock raised on the base.

b) Consumption advisory for ducks and recreationally caught fish.

c) Restriction on commercial fishing in The Heart Morass. 5. Continue to implement construction management procedures (administration controls) such as

site specific environmental management plans, Defence PFAS framework for construction and maintenance projects, and the Defence PFAS engineered stockpile facility performance specification.


76 August 2018

7.2 Comparative PMAP implementation timeframes

Primary implementation period:

• Short term:

Consumption advisories publicised

Ongoing monitoring plan implemented

Plan and procure discharge and drainage improvement feasibility study • Medium term:

Conduct discharge and drainage improvement feasibility study.

Ongoing monitoring.

Extended implementation period:

• Long term:

Implement recommendations of drainage improvement feasibility study.

Ongoing monitoring (if required).

Review PMAP for additional management controls to be considered based on monitoring data or new technologies as they become available.

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

• the outcomes of earlier PMAP response actions

• the development of relevant legislation, policy and guidelines

• changes in land use surrounding the site

• feedback received from the local community and stakeholders

• the availability of new relevant science and technology

• timeframes for Federal Government approvals and procurement processes.


77 August 2018

8 REVIEW AND UPDATE

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

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

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

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

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

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

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

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

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

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

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

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

• changes to shallow groundwater use in the area surrounding the site.

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

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

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

Changes to this PMAP will continue to be communicated and discussed with the key stakeholders including Federal and State/Territory government agencies and the local Council.

.


August 2018

TABLES

Table 1: Source Area Summary

Table 1 - Source Area Summary

PFAS Management Area PlanRAAF Base East SaleDepartment of Defence

Sediment(PFOS+PFHxS - mg/kg)

Source ID Source Location / Area Source

Group

Approx. Spatial Area

(m2)

Development Status

Surface Treatments

Drainage Type

Distance to Drainage/SW (m)

Drainage Direction

# Sample Locations

# Above 0.071

# Above 0.72 Max (ug/L) Max (mg/kg)

The Heart Morass- The Heart Morass - 20,300,000 Open N/A Open N/A South 28 25 3 0.74 1.93

17 Stormwater Drains - Off-site Drainage Line & The Heart Morass Discharge 2 N/A Open N/A Open N/A South 4 4 3 2.49 0.32

Site Surface WaterOrnamental Pond 2 N/A Open N/A N/A N/A N/A 2 2 1 2.59 0.0244

25 Lake Edward 4 N/A Open N/A N/A N/A N/A 1 1 1 84.4 0.41

17 Stormwater Drains 2 N/A Open N/A Open N/AMajor - SouthMinor - North

and East32 32 28 23.54 0.8765

17 Stormwater Drains 2 N/A Open & Operational

Grass/soil & concrete/buildings Closed N/A Major - South

Minor - East 13 12 9 283 0.4885

Southeast Area

08 Former Fire Training Area - Southeast 1 3,300 Open Grass/soil & concrete Open 400 South 4 4 4 14.44 N/A

07 Waste Burial Area 1 213,000 Open Grass/soil Open <50 South 4 4 4 14.44 N/A

09 Former Fire Training Area - Southeast near 4WD track 1 1,500 Open Grass/soil &

concrete Open <50 South 3 3 2 3.39 N/A

12 4WD Training Track 2 14,000 Open Grass/soil Open 100 South 3 3 2 3.39 N/A17 Stormwater Drains 2 Open N/A Open N/A South 7 7 6 14.44 0.338


06 Current Fire Station 1 18,000 Operational Grass/soil & concrete/buildings Closed 0 Major - South

Minor - East 9 9 8 283 N/A

16 Grassed area near runways used for AFFF testing 2 9,000 Open Grass/soil Closed 100 Major - South

Minor - East N/A N/A N/A N/A N/A

17 Stormwater Drains 2 N/A Operational Grass/soil & concrete/buildings Closed N/A Major - South

Minor - East 9 9 8 283 0.0185

Central Area

13 Current Fire Training - Former Sewage Treatment 2 4,000 Operational &

OpenGrass/soil &

concrete/buildings Closed <50-100 South 2 2 2 2.84 N/A

11 AFFF Testing Area 1 8,500 Operational Grass/soil and bitumen Closed <50 South 4 4 3 17.11 N/A

- AIR5428 Area - 100,000 Operational Concrete/buildings Closed <50 South 4 4 3 17.11 N/A

17 Stormwater Drains 2 N/A Operational Grass/soil Open & Closed N/A South 7 7 5 17.11 0.8765

Source Area Details Surface Water (PFOS+PFHxS - ug/L)



Sediment(PFOS+PFHxS - mg/kg)


Group

Approx. Spatial Area

(m2)

Development Status

Surface Treatments

Drainage Type

Distance to Drainage/SW (m)

Drainage Direction

# Sample Locations

# Above 0.071

# Above 0.72 Max (ug/L) Max (mg/kg)

Source Area Details Surface Water (PFOS+PFHxS - ug/L)

Northwest Area

14 Grassed Area Near MEOMS 2 46,000 Operational & Open

Stockpiled soil, tank farm & grass/soil

Open & Closed <50 North & South 1 1 1 2.91 N/A

04 Former Fire Station 1 500 Open Grass/soil Closed <50 South 1 1 0 0.49 N/A

15 Grassed Area Near Former Fire Station 2 2,000 Open Grass/soil Closed 100 South 1 1 0 0.49 N/A

01 & 14 (Part) MEOMS - Waste Disposal 1 & 2 10,000 Operational &

OpenTank farm &

grass/soilOpen & Closed 100 North & South 1 1 1 2.91 N/A

02 MEOMS - Operational Areas 1 5,000 Operational Concrete/buildings Closed 0 South 1 1 1 25.96 N/A

03 Fire Truck Hose Testing 1 3,000 Operational Tank farm & grass/soil Closed <50 South 1 1 1 2.91 N/A

05 Chemical Storage Area 1 700 Operational Concrete/buildings Closed <50 South 1 1 1 2.91 N/A

17 Stormwater Drains 2 N/A Operational Grass/soil Open N/A North 1 1 0 0.361 0.419917 Stormwater Drains 2 Operational Concrete/buildings Closed N/A South 5 5 4 25.96 0.2108

Off-Site Potential GW Impacts- Southern Boundary - N/A Open Grass/soil Open N/A N/A N/A N/A N/A N/A N/A- Eastern Boundary - N/A Open Grass/soil Open N/A N/A N/A N/A N/A N/A N/A- Southeast Boundary - N/A Open Grass/soil Open N/A N/A N/A N/A N/A N/A N/A

NOTES:1 PFOS+PFHxS Health Based Guidance Value (DOH) - Drinking Water2 PFOS+PFHxS Health Based Guidance Value (DOH) - Recreational Water3 Defence - Category 2 Soil Management (based on Indirect soil trigger levels , Ecological Screening Criteria Table 2 (OEH 2017), and Interim Ecological for indirect exposure (PFOS only) - Industrial/Commercial (PFAS NEMP, 2018))4 Senversa identified concentration that relates to elevated leachability at East Sale. 5 Defence - Category 1 Soil Management (based on Soil Human Health Screening Values - Industrial/Commercial (PFAS NEMP, 2018)6 Aquatic ecosystem 90% species protection for highly disturbed systems (for PFOS Only) - Indication of an elevated guideline value only for magnitude purposes, not relevant at site.7 Aquatic ecosystem 80% species protection for highly disturbed systems (for PFOS only) - Indication of an elevated guideline value only for magnitude purposes, not relevant at site.




Group

The Heart Morass- The Heart Morass -

17 Stormwater Drains - Off-site Drainage Line & The Heart Morass Discharge 2

Site Surface WaterOrnamental Pond 2

25 Lake Edward 4

17 Stormwater Drains 2


Southeast Area

08 Former Fire Training Area - Southeast 1

07 Waste Burial Area 1

09 Former Fire Training Area - Southeast near 4WD track 1

12 4WD Training Track 217 Stormwater Drains 2


06 Current Fire Station 1

16 Grassed area near runways used for AFFF testing 2


Central Area

13 Current Fire Training - Former Sewage Treatment 2

11 AFFF Testing Area 1

- AIR5428 Area -


Source Area Details

Depth of Soil Impacts Above 5 mg/kg, or highest

concentration

Restriction to access of surface

Preferential Pathway to

site drainage

# Sample Locations # Samples

# Above 0.143 # Above 54 # Above

205Max

(mg/kg)Leachability Max (ug/L)

N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A


N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AN/A N/A N/A N/A N/A N/A N/A N/A N/A N/A



>1m (undelineated) None - Concrete Pad in place Unlikely 11 20 12 2 0 16.95 742.5

Surface None Possible 44 56 6 0 0 3.616 6.82

~0.3m None - Concrete Pad in place Possible 6 11 7 1 0 7.456 227.73

Surface None Possible 7 12 1 0 0 0.2602 -N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

>1m (undelineated) Concrete apron and buildings Likely 10 15 15 5 1 23.44 1114

Surface None Unlikely 7 10 7 1 1 42 360.3


~0.5m Part - Treatment Plan Infrastructure Possible 22 29 13 5 2 83.7 -

~0.3m Part - Bitumen runways Possible 9 15 8 0 0 0.8811 26.91

~0.2m - Soil being managed by Project. Extent of removal

/management unknown (works completed by others)

Re-Developed - Buildings and

bitumen/concrete aprons.

Unlikely 28 51 4 0 0 3.2 -


Soil (PFOS+PFHxS - mg/kg)




Group

The Heart Morass

Source Area Details

Northwest Area

14 Grassed Area Near MEOMS 2

04 Former Fire Station 1

15 Grassed Area Near Former Fire Station 2

01 & 14 (Part) MEOMS - Waste Disposal 1 & 2

02 MEOMS - Operational Areas 1

03 Fire Truck Hose Testing 1

05 Chemical Storage Area 1

17 Stormwater Drains 217 Stormwater Drains 2

Off-Site Potential GW Impacts- Southern Boundary -- Eastern Boundary -- Southeast Boundary -


Depth of Soil Impacts Above 5 mg/kg, or highest

concentration

Restriction to access of surface

Preferential Pathway to

site drainage

# Sample Locations # Samples

# Above 0.143 # Above 54 # Above

205Max

(mg/kg)Leachability Max (ug/L)

Soil (PFOS+PFHxS - mg/kg)

~0.2m - Currently stockpiled in northwest area of site.

Extent of removal unknown (works completed by others)

Part - New Fuel Tank Farm Likely 49 61 51 8 2 440 16.36

~0.3m None Possible 4 8 1 1 0 14.54 1.13

~0.3m None Possible 6 13 0 0 0 0.1283 -

>1m (undelineated) Part - New and Old Tank Farms Likely 6 12 6 2 0 7.07 87.5

Surface Bitumen/ concrete apron and buildings Likely 5 7 0 0 0 0.1331 4.07

Surface Part - New Fuel Tank Farm Possible 5 9 6 0 0 0.702 -

~0.3m Concrete apron and buildings Possible 3 6 2 1 0 13.11 516.4

N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AN/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AN/A N/A N/A N/A N/A N/A N/A N/A N/A N/AN/A N/A N/A N/A N/A N/A N/A N/A N/A N/A




Group

The Heart Morass- The Heart Morass -

17 Stormwater Drains - Off-site Drainage Line & The Heart Morass Discharge 2

Site Surface WaterOrnamental Pond 2

25 Lake Edward 4



Southeast Area

08 Former Fire Training Area - Southeast 1

07 Waste Burial Area 1

09 Former Fire Training Area - Southeast near 4WD track 1

12 4WD Training Track 217 Stormwater Drains 2


06 Current Fire Station 1

16 Grassed area near runways used for AFFF testing 2


Central Area

13 Current Fire Training - Former Sewage Treatment 2

11 AFFF Testing Area 1

- AIR5428 Area -


Source Area Details

Pathway to site drainage

Migrating from Site

Depth (m bgl)

# Sample Locations

# Above 0.071

# Above 0.72

# Above 26

# Above 317 Max (ug/L) Scale of Areal

ImpactMigrating from Site

# Sample Locations

# Above 0.071

# Above 0.72

# Above 26

# Above 317 Max (ug/L)

N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A


N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AUnlikely Likely 2.5-3.1 10 1 0 0 0 0.63 N/A N/A N/A N/A N/A N/A N/A N/A



Likely Likely 2.5-4.0 7 5 5 5 3 8874 Moderate Likely 5 6 6 3 2 523

Likely Likely 2.1-4.1 9 7 6 5 1 287 - - - - - - - -

Unlikely Unlikely 4.2-4.5 2 2 1 1 1 315 - - - - - - - -

Unlikely Unlikely 4.0 1 1 1 0 0 1.95 - - - - - - - -N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

Possible Unlikely 2.3 1 1 1 1 1 8530 - - - - - - - -

Unlikely Unlikely 2.3 1 1 1 1 1 2380 - - - - - - - -


Unlikely Unlikely 3.2 1 1 1 1 0 28.84 - - - - - - - -

Unlikely Unlikely 2.2 1 1 1 1 1 636 Undelineated Unlikely 1 0 0 0 0 <0.03

Unlikely Unlikely 2.3-2.4 2 2 2 2 1 33.99 - - - - - - - -


Deeper Groundwater (PFOS+PFHxS - ug/L)

Shallow Groundwater (PFOS+PFHxS - ug/L)




Group

The Heart Morass

Source Area Details

Northwest Area

14 Grassed Area Near MEOMS 2

04 Former Fire Station 1

15 Grassed Area Near Former Fire Station 2

01 & 14 (Part) MEOMS - Waste Disposal 1 & 2

02 MEOMS - Operational Areas 1

03 Fire Truck Hose Testing 1

05 Chemical Storage Area 1

17 Stormwater Drains 217 Stormwater Drains 2

Off-Site Potential GW Impacts- Southern Boundary -- Eastern Boundary -- Southeast Boundary -


Pathway to site drainage

Migrating from Site

Depth (m bgl)

# Sample Locations

# Above 0.071

# Above 0.72

# Above 26

# Above 317 Max (ug/L) Scale of Areal

ImpactMigrating from Site

# Sample Locations

# Above 0.071

# Above 0.72

# Above 26

# Above 317 Max (ug/L)

Deeper Groundwater (PFOS+PFHxS - ug/L)

Shallow Groundwater (PFOS+PFHxS - ug/L)

Unlikely Unlikely 1.0-1.2 6 6 5 4 3 253 - - - - - - - -



Unlikely Unlikely 1.0-2.0 3 3 3 3 1 46.2 Moderate Unlikely 1 0 0 0 0 <0.03

Unlikely Unlikely 1.5-2.0 6 6 5 5 1 69.83 - - - - - - - -



N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/AN/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

Likely 4.1-4.7 3 3 2 1 0 7.53 Undelineated Likely 2 0 0 0 0 0.01Likely 1.1-1.3 2 2 2 1 0 10.66 - - - - - - - -Yes 2.0-4.1 4 4 3 3 0 15.94 Undelineated Yes 2 2 2 2 0 6.94


August 2018

FIGURES

Figure 3: Management Areas

Figure 4: Site Layout and Source Areas

Level 6, 15 William StreetMelbourne VIC 3000(03) 9606 0070 www.senversa.com.au

Address: Phone:Website:

Date: Revision: Scale:

Designed:

Drawn:

Checked:

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PFAS Management Area Plan

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Farming Land With Residences





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Source Area

Number Name of Area

1 MEOMS - Waste disposal2 MEOMS - Operational Areas3 MEOMS - Fire Truck Hose Testing4 Former Fire Station5 Chemical Storage Area6 Current Fire Station7 Former Waste Burial Area (south)89

11 AFFF Testing Area

12 4WD Training TrackCurrent Fire TrainingFormer Sewage Treatment

14 Grassed Area near MEOMS15 Grassed Area near Fire Station16 Grassed area near runways17 Stormwater drains

GROUP 1 POTENTIAL SOURCES


Former Fire Training Areas

13


August 2018

APPENDIX A: Regulatory and policy analysis

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

A1 Commonwealth legislation, policy and standards

A1.1 Outline

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

Commonwealth legislation

• Environment Protection and Biodiversity Conservation Act 1999 – Relevant to the consideration of Commonwealth environment and biodiversity conservation and must be considered, including the requirement for referrals in the development of any management measures involving disturbance works (including in RAMSAR listed wetlands).

• Water Act 2007 – Is principally an act to make provision for the management of the water resources of the Murray-Darling Basin, and to make provision for other matters of national interest in relation to water and water information.

• National Environment Protection (Assessment of Site Contamination) Measure 1999, as amended in 2013. (NEPM 2013) – Guides the investigation and risk assessment process for potentially contaminated land.

Commonwealth policy, standards and guidance

Defence policy, standards and guidance

• Defence Environmental Policy

• Defence Estate Strategy 2016-2036

• Defence Environmental Strategy 2016-2036

• Defence Construction and Maintenance Framework 2018

• Defence PFAS Response Management Strategy 2018

• Defence Interim Response Management Guidelines 2018

• Defence PMAP Template and Guidance 2018

Commonwealth whole-of-government policy, standards and guidance

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

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

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


August 2018

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

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

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

A2 State/Territory Legislation and Policy

A2.1 Outline

The following State legislation and policy is relevant to the risk management of the Management Area: • Environment Protection Act 1970 – The Act was established to provide a regulatory framework

for the protection of the environment in Victoria having regard to the principles of environment protection. Under the EP Act discharges to the environment must be managed so that they do not adversely affect the receiving environment.

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

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

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

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

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

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


August 2018

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

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

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

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

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

• Interim position statement on PFAS (November 2017) – Outlines EPA Victoria’ current state of knowledge regarding PFAS and their approach to the assessment and management of PFAS. The position statement will be updated as new information and data on PFAS becomes available and has been indicated by EPA to possibly include state based guidance into the future.

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

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

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

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

A3 Planning Instruments or environmental permitting/licence controls

A3.1 Outline

Any option to manage PFAS impacted solids in an off-site facility (treatment or disposal) requires consideration under local government planning controls and referral to the EPA to consider the Environment Protection (Scheduled Premises) Regulations. Typically, this involves Works Approval, planning permit and associated community consultation. The requirements of the PFAS NEMP, and any subsequent updates to this document, would be considered in such reviews.

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




August 2018

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

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

It is understood for example that RENEX in Altona is completing proof of performance trials for high temperature thermal PFAS destruction, but is not licensed by the EPA to receive PFAS wastes.

Small quantities of PFAS-impacted liquid wastes can be transported for storage and ultimately disposal at a limited number of providers. For example, it is understood that Veolia is licensed to receive liquid wastes to transport to their Brooklyn facility.


August 2018

APPENDIX B: Interim response management analysis

This Appendix is a placeholder where Interim Response Management (IRM) actions relevant to the Management Area are detailed.

No IRM have been identified for RAAF East Sale.


August 2018

APPENDIX C Source – pathway – receptor analysis

This Appendix sets out the current status of the source – pathway – receptor analysis completed following the Final HHERA and includes the CSM diagram.

Appendix C: CSM refined following the HHERA showing current pathways associated with potentially elevated risks

Exposure Medium Exposure Pathway

Human Receptors Livestock Ecological Receptors

On-site Off-site On-site

Off-site On-site Off-site

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Soil

Inhalation - Dust and airborne particulates NA NA NA NA NA NA NA Incidental Ingestion NA NA NA NA NA NA NA

Dermal Contact NA NA NA NA NA NA NA Direct Contact / Uptake NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA

Bioaccumulation / Secondary Poisoning NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA Groundwater - Shallow Ingestion (potable Use) NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA

Incidental Ingestion (during non-potable use) NA NA NA NA NA NA NA NA NA NA NA NA NA NA Dermal Contact (potable or non-potable use) NA NA NA NA NA NA NA NA NA NA NA NA NA NA

Direct Contact / Uptake NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA Groundwater use for irrigation and stockwatering,

and subsequent uptake into produce for human consumption

NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA

Groundwater - Deep Boisdale Formation

Ingestion (potable and other uses) NA NA NA NA NA NA NA NA NA Dermal Contact (potable and other uses) NA NA NA NA NA NA NA NA NA NA

Direct Contact / Uptake NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA Surface Water - Open Drains Incidental Ingestion NA NA NA NA NA + + + NA NA NA NA

Dermal Contact NA NA NA NA NA NA NA NA NA NA NA NA Direct Contact / Uptake NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA** NA NA**

Bioaccumulation / Secondary Poisoning NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA ** NA **

Surface Water - Irrigation Channels and/or Holding Areas/Dams for Stock or Irrigation water (Includes on-site stock troughs)

Ingestion NA NA NA NA NA NA NA NA NA NA NA NA Dermal Contact NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA

Direct Contact / Uptake NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA Bioaccumulation / Secondary Poisoning NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA

Surface Water - Small Ornamental Ponds

Incidental Ingestion NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA Dermal Contact NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA

Direct Contact / Uptake NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA Bioaccumulation / Secondary Poisoning NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA






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Surface Water - Heart Morass Incidental Ingestion NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA

Dermal Contact NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA Direct Contact / Uptake NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA

Bioaccumulation / Secondary Poisoning NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA Surface Water - Lake Wellington*** Incidental Ingestion NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA


Bioaccumulation / Secondary Poisoning NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA Surface Water - Latrobe River Incidental Ingestion NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA


Bioaccumulation / Secondary Poisoning NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA Sediment - Open Drains Incidental Ingestion NA NA NA NA NA NA NA NA NA NA NA NA

Dermal Contact NA NA NA NA NA NA NA NA NA NA NA NA Direct Contact / Uptake NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA

Bioaccumulation / Secondary Poisoning NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA Sediment - Irrigation Channels and/or Holding Areas/Dams for Stock or Irrigation Water

Ingestion NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA Dermal Contact NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA

Direct Contact / Uptake NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA^ Bioaccumulation / Secondary Poisoning NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA^

Sediment - Small Ornamental Ponds Incidental Ingestion NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA

Dermal Contact NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA Direct Contact / Uptake NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA^ NA NA

Bioaccumulation / Secondary Poisoning NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA^ NA NA Sediment - Heart Morass Incidental Ingestion NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA

Dermal Contact NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA Direct Contact / Uptake NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA^

Bioaccumulation / Secondary Poisoning NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA^






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Sediment - Latrobe River Incidental Ingestion NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA Dermal Contact NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA

Direct Contact / Uptake NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA^ Bioaccumulation / Secondary Poisoning NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA^

Produce raised off-site

Beef# Ingestion NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA Milk or other dairy products# Ingestion NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA Meat from sheep, lamb and/or pigs# Ingestion NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA Homegrown fruit or vegetables#

Ingestion NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA Home raised chickens or eggs# Ingestion NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA

Produce raised on-site Beef# Ingestion NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA Milk or other dairy products# Ingestion NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA Meat from sheep, lamb and/or pigs# Ingestion NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA Homegrown fruit or vegetables#

Ingestion NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA Home raised chickens or eggs# Ingestion NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA

Fish and game Duck (from Heart Morass)# Ingestion NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA Carp/eels/other fish (Heart Morass)# Ingestion NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA Carp/eels/other fish (La Trobe River)# Ingestion NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA Legend:

NA Not applicable; pathway is not relevant and/or complete for this receptor.

Low and acceptable risk Pathway is potentially complete, however risks are assessed to be low and acceptable (either at Tier 1, or in the HHERA)

Potentially elevated risk Pathway is potentially complete. Risks assessed to be potentially elevated in the HHERA.

NA - Potentially elevated risk but currently inactive

These pathways are not currently active and have not been currently assessed in detail in the HHERA. Either management controls are required to limit these potentially feasible uses in the future, or further assessment would be required to assess potential risks.[KR1][BH2]

Notes:

* Off-site groundwater bores are not reported to be used as a source of drinking water, however results were compared to potable use criteria for screening purposes.

** While concentrations in some drainage channels exceed relevant screening criteria for direct toxicity, these drains are not protected under the SEPP WoV thus aquatic ecosystems protection within the drain itself is not considered a relevant beneficial use. However, the SEPP WoV does require that these waterways be managed to ensure no adverse impacts to health or the surrounding environment. Based on the results of the HHERA, potentially elevated risks cannot be excluded for this pathway (based on concentrations in the drain water and in biota sampled from the drain).

*** Based on results of samples collected from irrigation channel prior to discharge to Lake Wellington and Latrobe River.

+ Concentrations in main drain from site are elevated; but those in drains accessible to stock are assessed to be low risk.

# Following bioaccumulation from multiple media (groundwater, surface water, soil and/or grass)




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August 2018

APPENDIX D Options analysis criteria

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

Cost / effectiveness / impact analysis

1 Cost range estimate

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

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

Category 1 PWC approval required above $15 million.6

> $13,000,000

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

> $1,500,000 < $15,000,00

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

Category 4 Community level actions7 < $500,000

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

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

2 Effectiveness rating

Assign an effectiveness rating in accordance with the following criteria:

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

High with supplementary option

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

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

Medium with supplementary option

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

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

6 http://www.defence.gov.au/estatemanagement/governance/Committees/pwc/Default.asp 7 Accommodates a range of community level response actions such as arranging alternative grazing for impacted agricultural businesses or providing fencing. The value of community-level actions may also exceed $500,000.


August 2018

3 Implementation period / timeframe

Designate an indicative timeframe for implementation:

Primary implementation period

− Short term: 1-12 months from the date of the PMAP − Medium term: 1-3 years

Extended implementation period

− Long term: beyond 3 years.

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

4 Potential impacts

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

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

5 Estimated net environmental benefit

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

Risk-based analysis

6 Proportion of action to risk

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

7 Best-practice status

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

8 Verification status

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

9 Technology assessment

Where an option involves a remediation technology: − infrastructure and energy requirements − ability to construct and operating technology − reliability of technology − ability to monitor effectiveness − ability to obtain any necessary approvals


August 2018

− availability of services and materials

10 Risks and mitigation

List primary, secondary8 and residual9 risks of implementation and associated mitigation options, such as:

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

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

− impact on existing infrastructure (including bores) − potential social and economic impacts (e.g. land use or

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

11 Key Dependencies

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

Defence implications

12 Defence capability

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

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

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

Stakeholder impacts, views and consents

15 Jurisdictional regulator/s

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

16 Owner / occupier consents and views

List any owner / occupier consents required to implement the option. Note the views of any relevant landowner or occupier.

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

8 Secondary risks are risks that emerge from implementation of a risk management response 9 Residual risks comprise that component of the identified risk that is not addressed by the option.


August 2018

APPENDIX E Options listing and analysis

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

Table E1-A and E1-B: Screening of Potential PFAS Treatment/Management Options

Table E2: Management Options Listing – Conceptual Description and Identifying Information

Table E3-A through E3-F: Options Analysis

Appendix E: Treatment and Management Technology Screening

Page 1 of 15

Table E1-A: Screening of Potential PFAS Treatment/Management Options – Solids (Soil/Sediment)1

Technology Description Technical applicability and risk reduction analysis (effectiveness), Technology status

Logistics (wastes generated, power requirements, access, etc)

Cost effectiveness (relative cost)

Timeframe Social and environmental values

Defence Implications

Retained for further evaluation?

In-Situ Treatment

Bioremediation The activity of naturally occurring microbes is stimulated by circulating water-based amendment solutions in-situ through contaminated soils to enhance biological degradation of organic contaminants. Amendments may be used to enhance contaminant desorption from the soils. Most applicable to saturated media.

Not applicable to PFAS. - - - - - No

Chemical Oxidation or Reduction

Oxidation/reduction chemically converts the hazardous contaminants to non-hazardous or less toxic compounds that are more stable, and/or inert. Oxidising/reducing agents most commonly used are Fentons reagent, permanganate, hydrogen peroxide and other propriety destruction formulations. Chemical commonly delivered by vertical well pressure injection. Delivery issues with contact of reagent with affected media. Most applicable to saturated media.

Emerging technology (laboratory scale only). However, no proven PFAS destruction technology currently available.

Chemical injection is commonly conducted in-situ in Australia (last 10 years). Significant chemical volumes and multiple applications would be required.

High (largely due to high chemical costs and large area of application)

12 to 24 months for application

- - No

1 Technology sources obtained from ITRC Publication Remediation Technologies and Methods for Per- and Polyfluoroalkyl Substances (PFAS), ITRC March 2018; and PFAS National Environment Management Plan, Australian and New Zealand Heads of EPA (HEPA), January 2018 and Federal Remediation Technology Roundtable (FRTR) screening matrix (https://frtr.gov/matrix2/top_page.html).

https://frtr.gov/matrix2/top_page.html


Page 2 of 15







Soil Flushing Water or amendments (base, surfactant or chelating agent) are added to increase hydraulic gradients and ‘flush’ contaminants via advective pore flushing, desorption and diffusion gradients from impacted materials. Hydraulic control is required to capture the fluids, with ex situ treatment. PFAS compounds are soluble and have low soil partitioning coefficients, and are potentially amenable to this approach. However, low level concentrations are expected to be persistent due to desorption and matrix diffusion.

Full scale in situ application has not been identified in Australia.

Hydraulic control would be required but would be difficult to achieve – there is a risk of increasing hazards via groundwater migration exposure pathways where shallow groundwater is present.

- - - - No

Soil Vapour Extraction

Soil vapour is extracted and treated, thereby reducing volatile contaminant mass in unsaturated media. Can be combined with air sparging.

Not applicable to PFAS – non- or low volatility.

- - - - - No


Page 3 of 15







Adsorption - In-situ Stabilisation/ Immobilisation

Contaminants are physically bound or enclosed within a stabilised mass (solidification), or chemical reactions are induced between the stabilising agent and contaminants to reduce their mobility (stabilisation). Potential additives (stabilisation/binding) include carbon, RemBind or MatCARE. Cement solidification not applicable due to PFAS leachability under alkaline conditions.

Full scale in situ application has not been identified in Australia. Solidification is not applicable to PFAS.

Chemical injection and soil mixing is commonly conducted in-situ in Australia (last 10 years). Full scale in situ application has not been identified in Australia. Can require up to 25% v/v amendment addition to achieve stabilisation. Implementation would not be practicable given the wide lateral distribution and difficulty in achieving even distribution within materials.

Moderate to high (largely due to high amendment costs and large area of application)

- - Affects asset access.

No


Page 4 of 15







Ex-Situ Treatment

Excavation and Off-site Disposal

Commonly available soil treatment approach for categorised materials. Materials are excavated and transported to an appropriate facility for disposal. On site pre-treatment may be required to dewater and/or dry the materials prior to offsite transport and disposal.

Excavation and dewatering/drying of materials is technically feasible. There are no current disposal facilities in Victoria available - EPA has not categorised PFAS soil for off-site disposal. There are metropolitan landfills in Melbourne that could potentially be licensed to receive PFAS impacted soil. Potentially the opportunity to transport the material interstate to Queensland for destruction.

EPA has not categorised PFAS impacted soils for off-site disposal. No landfills licensed to receive PFAS impacted soils in Victoria.

High (Largely due to disposal costs and transport)

6+ months to complete works, contingent upon EPA waste categorisation.

Off-site disposal is considered the least desirable approach to managing contaminated soils on the PFAS NEMP and EPA’s waste hierarchy. Intra-state transport to an off-site facility would be very energy intensive and have undue risk of accidental spill/leak during transport.

Significantly disruptive to operations

Yes – provided EPA categorisation of PFAS impacted materials occurs.


Page 5 of 15







Bioremediation Materials are excavated and treated via biodegradation at an on-site or off-site facility. Dewatering of excavated materials may be required prior to treatment. The activity of naturally occurring microbes is stimulated by circulating water-based solutions through contaminated soils to enhance biological degradation of organic contaminants. Nutrients, oxygen and other amendments may be used to enhance biodegradation and contaminant desorption from the soils. Can be done through either open land-farming or in engineered ‘bio-piles’.

Not applicable for PFAS - - - - - No


Page 6 of 15







Adsorption - Solidification/ Stabilisation/ Immobilisation

Materials are excavated and treated at an on-site or off-site facility. Dewatering/drying of excavated materials may be required prior to treatment. Additives are added to excavated soils in a mixing plant. Contaminants are physically bound or enclosed within a stabilised mass (solidification), or chemical reactions are induced between the stabilising agent and contaminants to reduce their mobility (stabilisation). A combination of soil mixing with selective additives (stabilisation/binding) has been applied to PFAS impacted soils/sediments on a relatively small scale successfully in Australia. Potential additives (stabilisation/binding) include activated carbon, modified clay or combined clay and activated carbon (e.g. RemBind or MatCARE). Cement stabilisation not applicable due to PFAS leachability under alkaline conditions. Treated materials would be reused at site. However, the potential for very low levels of leachability mean siting and cover of the material must still be considered.

Applicable Applicable. Soil mixing required to ensure adequate contact with impacted media. Can require up to 25% v/v amendment addition to achieve stabilisation

Moderate 12+ months. Validation of stabilisation may take 6 months.

Treatment and reuse of contaminated soil is considered high on the PFAS NEMP and EPA’s waste hierarchy. Significant chemical use would be required.

Significant disruption to operations

Yes – not likely as a stand-alone solution but potential to be coupled with off-site disposal, on-site retention or as part of in-situ management options.


Page 7 of 15







Chemical Oxidation or Reduction

Materials are excavated and treated at an on-site or off-site facility. Chemicals are added to excavated soils via mixing in a batching plant or stockpiles. Oxidation/reduction chemically converts the hazardous contaminants to non-hazardous or less toxic compounds that are more stable, and/or inert. Oxidising/reducing agents most commonly used are Fentons reagent, permanganate, hydrogen peroxide and other propriety destruction formulations.


Applicable. Soil mixing requirements to consider to ensure adequate contact with affected media. Geotechnical suitability of treated material (i.e. a slurry) for site retention needs consideration.

Moderate to high (largely due to high chemical costs)

12+ months with material handling on-site

Treatment and reuse of contaminated soil is considered high on EPA’s waste hierarchy. Significant chemical use would be required.

Some disruption to operations

No

Soil Washing / Chemical Extraction

Materials are excavated and treated at an on-site or off-site facility. Contaminants sorbed onto soil particles are separated from the soil in an aqueous based system. The wash water may be augmented with a basic leaching agent, surfactant, pH adjustment or chelating agent to help remove both organics and metals. PFAS compounds are soluble and have low soil partitioning coefficients, and are potentially amenable to this approach. However, low level concentrations in leachate are expected to be persistent, requiring significant treatment effort to achieve management goals.

Full scale application has not been identified in Australia, with pilot studies underway. Likely to have limited capability for clay rich soils.

Treatment of multiple waste streams (water, sludge concentrate) required. Geotechnical suitability of treated material (i.e. graded materials) for site retention needs consideration.

Moderate to high (potentially due to waste stream management and processing time)

12+ months with material handling on-site

Treatment and reuse of contaminated soil is considered high on the PFAS NEMP and EPA’s waste hierarchy.


No


Page 8 of 15







Low-temperature Thermal Desorption (on or off-site)

Materials are excavated and treated at an on-site or off-site facility. Dewatering of excavated materials may be required prior to treatment. Wastes are heated to 93oC to 315oC to volatilise water and organic contaminants. A carrier gas or vacuum system transports volatilised water and organics to the gas treatment system for scrubbing/polishing.

Not proven for PFAS (+1,100oC required for destruction and/or long residence time, with vapour stream treatment required).

- - - - - No

High-Temperature Thermal Desorption (on or off-site)

Materials are excavated and treated at an on-site or off-site facility. Dewatering of excavated materials may be required prior to treatment. Wastes are heated to 315oC to 538oC to volatilise water and organic contaminants. A carrier gas or vacuum system transports volatilised water and organics to the gas treatment system for scrubbing/polishing.

Not proven for PFAS (+1,100oC required for destruction and/or long residence time, with vapour stream treatment required)

- - - - - No


Page 9 of 15







Pyrolysis and oxidative thermal destruction (on or off-site)

Materials are excavated and treated at an on-site or off-site facility. Dewatering of excavated materials may be required prior to treatment. High temperatures 870oC to 1,200oC used to volatilise water and PFAS, then combust (in the presence of oxygen) organic constituents in hazardous wastes. Treatment of off gas and PFAS destruction by-products is required. These may include hydrofluorine and sulphuric acids. Incomplete combustion products may include carbon monoxide, carbonyl difluoride, sulphur oxides and fluorinated dioxins and furans.

Applicable Only feasible for PFAS at high temperatures. Off gas treatment required. Most feasible if transported to an existing off-site facility.

Very high (due to treatment costs)

4 to 5 years. High energy use and consideration for potential destruction by-products and incomplete combustion products is required.


Yes

Other

In-situ management

Impacted materials managed via reduction in contaminant mobility by reducing infiltration to the extent practicable, and isolating impacted material. This would be achieved via a low permeability cover and sub-drainage as a contingency to control seepage (if any).

Applicable This approach has been used in Victoria. In-situ management is acceptable where conducted in an environmental audit and risks are demonstrated to be low and acceptable.

Applicable Low Depends on project staging and auditor.

In-situ management of soil is considered to be high on the PFAS NEMP and EPA’s waste hierarchy and avoids transport of materials off-site so is therefore considered more sustainable than placement in an off-site facility. Manages issue while technologies are developing. Ability to review treatment practicability in future with known location of wastes.

Depending upon source area, low to some disruption to operations

Yes


Page 10 of 15







On-site containment in an engineered facility

This approach has been used in Victoria. On-site containment is acceptable. Involves excavation and placement in an engineered repository or containment cell that would be lined and capped.

Applicable This approach has been used in Victoria waste management, including PFAS. In-situ management is acceptable where conducted in an environmental audit and risks are demonstrated to be low and acceptable.

Applicable Low to moderate Depends on project staging and auditor.

On-site containment is lower on EPA’s waste hierarchy as the process involves construction of an engineered facility. However, this avoids transport of materials off-site so is therefore considered more sustainable than placement in an off-site facility.

Depending upon source area, low to significant disruption to operations

Yes


Page 11 of 15

Table E1-B: Screening of Potential PFAS Treatment/Management Options – Waters (Surface Water and Groundwater)2

Technology Description Technical applicability and risk reduction analysis (effectiveness)






In-Situ Treatment

Bioremediation As described in Table 1 (1A) for in situ biodegradation of soil/sediments.

Not applicable to PFAS.

- - - - - No

Chemical Injection

Chemicals are injected into the aquifer at pre-determined dosage rate. May include oxidation/reduction to chemically convert the hazardous contaminants to non-hazardous or less toxic compounds that are more stable, and/or inert. Other options may include novel additives such as slurried activated carbon which is a binding technology.


Chemical injection (oxidant) is commonly conducted in-situ in Australia (last 10 years). Significant chemical volumes would be required.

High (largely due to chemical costs and application)

12 to 24 months In-situ treatment is considered high on EPA’s waste hierarchy.

Some disruption to operations

No

Air Sparging Air is injected into the subsurface to add oxygen and volatilise contaminants. Soil vapour is extracted and treated, thereby reducing volatile contaminant mass.

Not applicable to PFAS – non- or low volatility.

- - - - - No

Thermal Treatment

As described in Table 1 (1A) for in situ thermal treatment of soil/sediments.

Not applicable to PFAS.

- - - - - No

2 Technology sources obtained from ITRC Publication Remediation Technologies and Methods for Per- and Polyfluoroalkyl Substances (PFAS), ITRC March 2018; and PFAS National Environment Management Plan, Australian and New Zealand Heads of EPA (HEPA), January 2018 and Federal Remediation Technology Roundtable (FRTR) screening matrix (https://frtr.gov/matrix2/top_page.html).

https://frtr.gov/matrix2/top_page.html


Page 12 of 15







Monitored Natural Attenuation

A variety of physical, chemical, or biological processes that, under favourable conditions, act without human intervention to reduce the mass, toxicity, mobility, volume, or concentration of contaminants in soil or groundwater. This typically is only applicable if the primary source has been controlled, and risks are demonstrated to be, or can be controlled to be, low and acceptable.

Not applicable to PFAS – there is limited natural attenuation in the environment.

- - - - - No

Permeable Reactive Barriers

A permeable reactive barrier (PRB) is installed across the flow path of the groundwater contaminant plume, allowing the plume to passively pass through the wall, but the reactive media either sorbs, degrades or transforms contaminants. Common reactive media include zero valent iron, natural zeolites and organic substrates. Recent research has assessed use of PRBs to promote effective enzyme-catalysed humification reactions to treat PFAS. PRBs can either be configured as a continuous wall to intersect the plume, or as a funnel-and-gate system with low permeability walls that direct groundwater flow through reactive media in a ‘gate’.

Potentially applicable as a component of an overall strategy. However, no full scale application for PFAS identified in Australia or globally. Expected to be applicable in short term for some hydrogeological settings.

Reactive media can require replacement (depending on sorptive capacity and concentrations being treated) and disposal/treatment.

Moderate to High (Depends on size, reactive media to be used, replacement of media)

Long term operation

In-situ treatment is considered high on the PFAS NEMP and EPA’s waste hierarchy.

Depending upon source area, low to significant disruption to operations

Yes, but only as part of an overall management alternative


Page 13 of 15







Ex-Situ Treatment

Groundwater extraction

Commonly available treatment approach. Dissolved phase impacts are extracted via a series of wells or trenches (‘French drains’), with ex situ treatment of effluent at a water treatment plant. Treated water could be managed via reinjection or discharge. Extraction system can be designed to maximise mass removal of dissolved phase contaminants, though this approach is typically more suited for hydraulic control purposes (see below).

Not applicable as a stand-alone option – is not likely to be practicable to address secondary sources (e.g. PFAS sorbed to soils). Desorption and back diffusion of contaminants from the formation can limit the ability to reach low-level management goals and cause extended treatment timeframes.

Requires water treatment (See below). Applicable as a component of an overall management strategy.

Moderate capital cost, but high lifecycle cost due to long duration

1+ years, long term operation

Considered low on hierarchy when used in isolation but can be a component of overall site strategy

Low to some disruption to operations

Yes, but only as part of an overall management alternative.

Excavation and/or dewatering

For shallow groundwater, bulk excavation and dewatering, or just dewatering, of these materials will remove the groundwater migration pathway. Pore water would be captured and treated ex situ at a water treatment plant. Treated water could be managed via reinjection or discharge. Excavated soil (where bulk excavation and dewatering) would be subject to disposal to an off-site landfill or on-site containment cell or in situ management (see Table 1 (1A)). If materials are left in situ, cover would be required to minimise recharge of the fill materials.

Applicable Requires water treatment (See below). Applicable as a component of an overall management strategy.

Low to moderate 6 to 12 months. Disposal considered energy intensive and low on EPA’s waste hierarchy.

Significant disruption (excavation) and increased risk of subsidence if dewatering alone

Yes, but only as part of an overall management alternative.


Page 14 of 15







Extracted groundwater treatment

For the above groundwater extraction options, ex situ treatment at a water treatment plant is required. A treatment train would be required, generally requiring: • Pre-treatment to remove sediments

and co-contaminants. This may include sand filtration, flocculation, sorption.

• PFAS removal via sorption, ultrafiltration (nanofiltration), foam fractionation, or reverse osmosis.

The most common PFAS treatment is sorption using granular activated carbon (GAC) and/or ultrafiltration (e.g. reverse osmosis). Other media sorptive media include modified clays (e.g. sand MatCARE). Ion exchange resins have also been utilised in a treatment train approach. Emerging technologies being studied include sonochemical treatment, photochemical oxidation and thermally-induced reduction. Treated water could be managed via reinjection or discharge. Waste media must be treated (e.g. incineration) to destroy PFAS, or disposed of at landfill.

Applicable Treatment technologies are commercially available and have been used for PFAS water treatment in Australia (in particular GAC, and to a lesser extent ultrafiltration and ion exchange).

Applicable A pilot trial and treatment train approach may be required depending on water quality and co-contaminants. A method to manage waste media is required (see Table 1 (1A) options for disposal, on site containment or in situ management)

Moderate

See for above options

See for above options Little disruption to operations

See for above options


Page 15 of 15







Other

Hydraulic Containment

Sub-surface hydraulic barriers consist of a series of vertically installed walls, or excavated trenches near the perimeter of shallow water impacts, to: • Affect hydraulic gradients or direct

flow within the shallow system so that flow occurs laterally to drains/sumps/wells for extraction; and/or

• Reduce and retard lateral shallow groundwater flow.

If no measures are implemented to reduce infiltration, will require ongoing water extraction and treatment, and does not reduce management requirements. If combined with a low permeability cover to reduce infiltration to the shallow aquifer, there would be limited ongoing treatment of water required.

Applicable

Applicable Requires water treatment (See above). Would only be feasible if combined with a strategy to reduce infiltration to the perched aquifer (e.g. a low permeability cover).

Low to moderate Ongoing Considered energy intensive and low on EPA’s waste hierarchy, but system can be optimised to reduce O&M costs.

Little disruption to operations, but combined with a low permeability cover system would result in significant disruption to operations

No

Appendix E: Management Options Listing – Conceptual Description and Identifying Information

Page 1 of 7

Table E2: Management Options Listing – Conceptual Description and Identifying Information

Option ID and Title

Description Objective and Contribution to Risk Reduction

Main Components and Supplementary Requirements

1. Excavation and off-site disposal (landfill) – source management

Excavation of impacted fill and natural soils and sediments in secondary sources such as drainage lines to the extent practicable, and off-site disposal (at facility licensed to receive the waste). All impacted materials would require excavation and removal from site. However, there is the potential that some materials containing residual low level contamination may remain (whether identified materials that are not practicable to excavate or unidentified impacts). Ongoing management or cover of these materials may be required. It is noted there is currently no disposal facility licensed to receive PFAS impacted waste in Victoria.

To remove impacted materials at the site that have the potential to represent unacceptable risks to offsite receptors via surface water exposure pathways. The impacted materials include impacted shallow fill and natural materials and sediments of surface water drainage lines.

1. Planning and approvals, this would include identification of a facility licensed to receive the waste and establishing the waste category.

2. Site establishment, including required occupational health and safety, and environmental controls, is required prior to dewatering and excavation works.

3. For some source areas, demolition of infrastructure (e.g. buildings and structures overlying impacted soils, concrete drainage line infrastructure). Excavation may not be practicable for critical infrastructure (e.g. current fire station within airside area).

4. Drainage/dewatering of materials to be excavated. This would include control of surface runoff and evapotranspiration, and/or conventional dewatering via extraction from spearpoints/trenches prior to excavation. Extracted water would require capture and treatment at a temporary water treatment plant.

5. Excavation and consolidation of impacted materials. 6. Drying of sediments and other materials that are not ‘spadeable’ or in a physical condition not suitable for

disposal. This may include drying pads, mechanical means or amendments. 7. Transport to a facility licensed to receive the waste materials and disposal. 8. Remediation validation. 9. Reinstatement of excavations. This may require importation of clean materials or site regrading. 10. Rebuilding/reinstatement of buildings and structures.


Page 2 of 7

Option ID and Title



2. Excavation and off site pyrolysis (thermal destruction) – source management

Excavation of impacted fill and natural soils and sediments in secondary sources such as drainage lines to the extent practicable, and transport to thermal destruction at an off-site facility (if available). All impacted materials would require excavation and removal from site. However, there is the potential that some materials containing residual low level contamination may remain (whether identified materials that are not practicable to excavate or unidentified impacts). Ongoing management or cover of these materials may be required. It is noted there is currently no suitable thermal treatment facility licensed to receive PFAS impacted waste in Victoria. However, there may be the opportunity to transport material interstate for destruction in Queensland.

To remove impacted materials at the site that have the potential to represent unacceptable risks to offsite receptors via surface water exposure pathways. The impacted materials include impacted shallow fill and natural materials and sediments of surface water drainage lines.

1. Planning and approvals. 2. Identification of a facility licensed to receive the waste. Senversa understand that a facility in Victoria is currently

undertaking proof of performance trials for PFAS impacted materials. 3. Site establishment, including required occupational health and safety, and environmental controls, is required

prior to dewatering/excavation works. 4. For some source areas, demolition of infrastructure (e.g. buildings and structures overlying impacted soils,

concrete drainage line infrastructure). Excavation may not be practicable for critical infrastructure (e.g. current fire station within airside area).



transport. This may include drying pads, mechanical means or amendments. 8. Transport to the off-site thermal treatment facility licensed to receive the waste materials. 9. Remediation validation. 10. Reinstatement of excavations. This may require importation of clean materials, validated treated materials, or

site regrading. 11. Rebuilding/reinstatement of buildings and structures. As a suitable off site facility in Victoria is not yet available, if an on-site facility is required then additional components include: 12. Additional planning and approvals. 13. Procurement and installation of a temporary thermal treatment plant. 14. Commissioning and proof of performance. 15. On-site thermal treatment of pre-treated impacted materials. 16. Compliance monitoring. 17. On-site reuse of treated and validated materials. 18. Plant decommissioning.


Page 3 of 7

Option ID and Title



3. Adsorption – Excavation and Stabilisation/ Immobilisation – source management

Excavation of impacted fill and natural soils and sediments in secondary sources such as drainage lines to the extent practicable and treated at an on-site facility. Dewatering/drying of excavated materials may be required prior to treatment. For complete site treatment, all impacted materials would require in-situ mixing or excavation treatment at the site. Otherwise, spot treatment of the more significant source areas would be prioritised. Additives are added to excavated soils in a mixing plant. Contaminants are physically bound or enclosed within a stabilised mass (solidification), or chemical reactions are induced between the stabilising agent and contaminants to reduce their mobility (stabilisation). Treated materials would be reused at site. However, the potential for very low levels of leachability mean siting and cover of the material must still be considered. There is the potential that some materials containing residual low level contamination may remain (whether identified materials that are not practicable to excavate or unidentified impacts). Ongoing management or cover of these materials may be required.

To treat impacted materials at the site that have the potential to represent unacceptable risks to offsite receptors via surface water exposure pathways, and to a lesser extent groundwater. The impacted materials include impacted shallow fill and natural materials and sediments of surface water drainage lines.

1. Planning and approvals to treat on-site. 2. Site establishment, including required occupational health and safety, and environmental controls, is required

prior to dewatering and excavation works. 3. For some source areas, demolition of infrastructure (e.g. buildings and structures overlying impacted soils,



5. Excavation and pug mill or equivalent mixing of impacted materials with suitable amendment at specified ratio. Drying of sediments and other materials that are not ‘spadeable’ or in a physical condition not suitable for mixing. This may include drying pads, mechanical means or amendments.

6. Validation of treatment success on a batch basis and staged reinstatement of excavations. Where amendment ratio increases reinstatement volume, then establish suitable stockpile locations.

7. Rebuilding/reinstatement of buildings and structures. 8. Ongoing monitoring of treatment effectiveness through surface water and groundwater monitoring program.


Page 4 of 7

Option ID and Title



4. In-situ management via low permeability cover and drainage controls – source management

In-situ management of impacted materials to minimise infiltration and seepage/drainage to adjacent surface water bodies to the extent practicable. This would be achieved via discreet excavations to consolidate some materials and the construction of a low permeability cover and contingency drainage controls in an identified area for in-situ soil management and can be managed into the future if required (i.e preferably not an operational area that would require an ongoing management plan). Assumes no basal lining (see option 5 below). Consolidation of impacted materials from other ‘hot spots’ and relocation within the identified in-situ management area would be required to achieve surface drainage grading.

To remove or manage impacted materials at the site that have the potential to represent unacceptable risks to offsite receptors via surface water exposure pathways, and to a lesser extent groundwater. This is achieved by providing physical separation between impacted materials and surface water runoff, and minimisation of mobilisation via seepage from impacted materials to the surrounding environment (e.g. seepage to underlying groundwater). The impacted materials may include impacted waste burial areas, impacted fill and natural materials in source areas and drainage line sediments.

1. Site planning and approvals. 2. Site establishment, including required occupational health and safety, and environmental controls, is required



4. Preparation of the in-situ management soil area to establish suitable surface drainage grading. 5. Consolidate identified impacted soil and sediment from other ‘hot spots’ and relocation to within the in-situ

management soil area. 6. Drying of sediments and other materials that are not ‘spadeable’ or in a physical condition not suitable for

capping. This may include drying pads, mechanical means or amendments. 7. Construction of the in-situ management soil area. This would comprise:

a. Retention of dewatering trenches/drains as a contingency to capture seepage from infiltration (if any). A temporary water treatment plant or off-site tankering of seepage infiltration would be required to treat captured seepage water (if any).

b. Low permeability cover. The cover would comprise a cap that reduces infiltration and surface water run off to the extent practicable. This would require a seepage infiltration review to determine the most suitable cover profile (e.g. clay cap or a Geosynthetic Clay Liner (GCL) overlain by geomembrane, overlain by subsoil and topsoil layers). Grading would be sufficient to minimise infiltration and encourage surface water runoff.

8. Construction quality assurance and remediation validation. 9. Implementation of an ongoing environment management plan would be necessary.

5. Excavation and on-site containment in an engineered facility – source management

Excavation of impacted fill and natural soils and sediments in secondary sources such as drainage lines to the extent practicable, And consolidation within an on-site engineered repository. Dewatering/drying of excavated materials may be required prior to treatment. The engineered repository would comprise a low permeability cap, double liner and drainage controls.

To remove or manage impacted materials at the site that have the potential to represent unacceptable risks to offsite receptors via surface water exposure pathways. This is achieved by providing physical separation between impacted materials and surface water runoff, and minimisation of mobilisation via seepage from impacted materials to the surrounding environment (e.g. seepage to underlying groundwater). The impacted materials include impacted waste burial areas, impacted fill and natural materials in source areas and drainage line sediments.

1. Planning and approvals. 2. Site establishment, including required occupational health and safety, and environmental controls, is required



4. Dewatering of materials to be excavated. Extracted water would require capture and treatment at a temporary water treatment plant.

5. Preparation of the engineered facility lining. This would include drainage controls and a double liner to minimise potential for seepage to infiltrate the underlying formation. Captured seepage would require collection and disposal or treatment at on on-site water treatment plant (where sufficient volumes generated).


treatment. This may include drying pads, mechanical means or amendments. 8. Construction of the engineered repository basal lining and cover system. The cover would comprise materials

that reduce infiltration to the extent practicable. This is considered to comprise a Geosynthetic Clay Liner (GCL) overlain by geomembrane (basal liner and cap systems), overlain by subsoil and topsoil layers. Grading would be sufficient to minimise infiltration and encourage surface water runoff.



Page 5 of 7

Option ID and Title



6. Surface water capture and treatment - pathway management

Side cast or block first flush stormwater from site-wide drainage or specific areas to a surface water detention basin to capture and minimise discharge off-site to The Heart Morass, and allow enhanced evaporation and/or water treatment (variable water treatment technology available). This is achieved by directing first flush from the Main Drains to an evaporation pond. Subsequent and baseline surface water flow be allowed to discharge off-site (no capture or treatment). Would require hydraulic diversion gate and engineered first flush capture system. Evaporation basin would require engineered lining to reduce seepage from impacted materials to the surrounding environment (e.g. seepage to underlying shallow groundwater).

To capture impacted ‘first flush’ stormwater from the site that has the potential to represent potentially unacceptable risks to off-site aquatic receptors via surface water exposure pathways.

1. Planning and approvals. 2. Surface water hydraulics study to determine volumetric first flush capture and land area requirements. 3. Consider need to reduce operational or lease areas, to meet storage needs. 4. Site establishment, including required occupational health and safety, and environmental controls, is required

prior to excavation works. 5. Preparation of the engineered diversion/blocking channel and side cast evaporation pond. This would include

basal clay liner to ensure limited infiltration. Captured surface water would require evaporation or treatment at on on-site water treatment plant. Periodic evaporation pond scraping and removal of concentrated sediments and reinstatement of pond thickness reductions as a result of scraping.


7. Shallow Groundwater Capture – dewatering as part of excavation and dewatering, or hydraulic containment Pump & treat (various treatment) – pathway management

For shallow groundwater, bulk excavation and dewatering, or just dewatering, of these materials will remove the groundwater migration pathway. Pore water would be captured and treated ex situ at a water treatment plant. Alternatively groundwater migration pathway can be intercepted by hydraulic containment via transect(s) of extraction bores across the groundwater flow path. Impacted water is removed and treated and groundwater is reinjected into the aquifer or discharge to surface waters (with consideration of salinity). Excavated soil (where bulk excavation and dewatering) would be subject to options above.

To limit groundwater flow and contaminant transport that has the potential to represent unacceptable risks to offsite receptors via groundwater flow in areas adjacent and immediately downgradient of source (‘hot spot’) areas. This effectively reduces migration and provides separation between impacted groundwater and the receiving environment (either a groundwater user or surface water discharge).

1. Site planning and approvals. 2. Site establishment, including required occupational health and safety, and environmental controls, prior to

setting up groundwater extraction arrays. 3. Install groundwater extraction array(s) and groundwater reinjection array(s). 4. Set up groundwater treatment system infrastructure and piping system to and from extraction arrays. 5. Implementation of an ongoing environment management plan would be necessary to monitor treatment plant

and capture performance.


Page 6 of 7

Option ID and Title



8. Shallow groundwater interception - PRB – pathway management

A permeable reactive barrier (PRB) is installed across the flow path of the groundwater contaminant plume, allowing the plume to passively pass through the wall, but the reactive media either sorbs, degrades or transforms contaminants. Reactive media variable. PRBs can either be configured as a continuous wall to intersect the plume, or as a funnel-and-gate system with low permeability walls that direct groundwater flow through reactive media in a ‘gate’. It is noted that no full scale PRB for PFAS application has been identified in Australia.

To passively intercept impacted groundwater that has the potential to represent unacceptable risks to offsite receptors via groundwater flow in areas adjacent and immediately downgradient of source (‘hot spot’) areas. This effectively reduces migration and provides separation between impacted groundwater and the receiving environment (either a groundwater user or surface water discharge).

1. Site planning and approvals. 2. Site establishment, including required occupational health and safety, and environmental controls, prior to

setting up PRB trench. 3. For some source areas, demolition of infrastructure (e.g. buildings and structures overlying impacted soils,

concrete drainage line infrastructure) to allow access to install trench to be backfilled with treatment media. Excavation may not be practicable for critical infrastructure (e.g. current fire station within airside area).

4. Excavate trench and manage spoil as per soil options above. Reinstate excavation with treatment media and cover system to reduce local infiltration in the vicinity of the trench.

5. Establish monitoring network to monitor PRB performance and to determine frequency of replacement/replenishment of treatment media.

6. Implementation of an ongoing environment management plan would be necessary.

9. Drainage Improvement – pathway management

Site drainage infrastructure improvements comprising removing impacted sediments within drainage lines, jet cleaning closed drainage network, expanding closed concrete drainage network or lining unlined drains.

To limit ongoing secondary source within drainage line sediments and to reduce groundwater/surface water interactions between impacted sediment or groundwater and the receiving environment (surface water discharge).

1. Site planning and approvals. 2. Surface water hydraulics study to determine drainage volumetric requirements. 3. Site establishment, including required occupational health and safety, and environmental controls, prior to

opening up drainage network for works. Likely to require staging to ensure storm and drainage flow events can be managed whilst the works are underway.

4. For some source areas, demolition of infrastructure (e.g. buildings and structures overlying impacted soils, concrete drainage line infrastructure) to allow access to install new drainage network. Excavation may not be practicable for critical infrastructure (e.g. current fire station within airside area).

5. Excavate impacted drainage line sediments and manage spoil as per soil options above. 6. Complete drainage improvement works. 7. Establish on-site and off-site discharge monitoring network to monitor environmental improvement.


Page 7 of 7

Option ID and Title



10. Administrative Control – receptor management

Administrative control(s) to limit or prevent people’s exposure to affected media (e.g. use of shallow groundwater) or consumption of affected terrestrial or aquatic animals (e.g. cattle, duck, fish and eels). On-site - Requires consideration of modification to the extent and type of on-site grazing. Off-site - Requires State government to generate advice, restrictions and educational material and monitoring and enforcement program to make receptors (fishers (commercial and recreational), hunters and groundwater users) aware of advice/restrictions and to minimise exposure.

To limit/remove receptor exposure pathway by restricting use of a segment of the environment. Usually involves providing a combination of general user signage, access restrictions, and advice to specific stakeholders to limit use of an area.

Off-site 1. Establish restriction area(s). 2. Liaise with State Government to provide information necessary to allow Government to develop implementation

program with associated education, signage and monitoring program. Enforcement program may also be required.

On-site 1. Establish restriction area(s). 2. Prepare relevant lease requirement. May include fencing to demarcate go/no go areas.

Table E3-A: The Heart Morass Options Analysis

Risk Source AreaContributing Sources

Risk ID and Description

Source, Pathway or Exposure (Receptor) Control measure

Engineering Control Exposure (receptor) Control

Management Option (Functional) TitleExcavation & Off-site Disposal of sediments

Excavation & Treatment of sediments

Stabilisation/ Immobilisation of sediments

In-situ Containment (capping) of sediments

Ex-situ Containment (repository) of sediments

Surface water capture and treatment (Drain The Heart Morass)

Shallow groundwater capture and treatment

In-situ Interception (e.g. PRB, Hydraulic Control)

Drainage improvement

Consumption advisory; management controls

Nature of Hazard Control Elimination Elimination Substitution Engineering Control Engineering Control Engineering Control Engineering Control Engineering Control Engineering Control Administrative ControlOption Applicable No No No No

1 Cost Range estimate Category 1 Category 1 Category 1 Category 1 Category 2 Category 4

2 Effectiveness rating High High Medium High Medium Medium

3 Implementation period / timeframe Short term Medium term Medium term Medium term Medium term Long term

4 Potential impactsUnlikely to have positive environmental and socioeconomic benefits.

Unlikely to have positive environmental and socioeconomic benefits.

May have positive environmental and socioeconomic benefits.




5 Est. Net Env. Benefit Negative Negative Marginal Negative Marginal Marginal

6 Proportion of action to risk Scale and Cost disproportionate to risk

Scale and Cost disproportionate to risk



Scale and Cost disproportionate to risk Scale and Cost proportionate to risk

7 Best practice status Measure is less than accepted industry practice

Measure constitutes accepted industry practice

Measure is less than accepted industry practice




8 Verification status Remediation technology status verified

Remediation technology status verified



Remediation technology status verified N/A

9 Technology assessment Likely to have significant logistical considerations

Likely to have significant logistical considerations


May have significant logistical considerations

Likely to have significant logistical considerations N/A

10 Risks and mitigation High (list issues) High (list issues) High (list issues) High (list issues) Medium Medium

11 Key dependenciesOption is dependent upon implementation of other options or external factor (list)

Option is dependent upon implementation of other options or external factor (list)




Option is NOT dependent upon implementation of other options or external factor

12 Defence Capability Highly unlikely to affect capability Likely to affect capability Highly unlikely to affect capability May affect capability Highly unlikely to affect capability Highly unlikely to affect capability

13 Project Fit TBC TBC TBC TBC Consistent with other sites Consistent with other sites

14 Scalability Option not able to be scaled Option not able to be scaled Option not able to be scaled Option able to be scaled Option able to be scaled Option able to be scaled

15 Jurisdictional regulator/s EPA, Parks Victoria, DWELP, WGCMA

EPA, Parks Victoria, DWELP, WGCMA



EPA, Parks Victoria, DWELP, WGCMA EPA, Parks Victoria, Fisheries

16Owner / occupier consents and views Owner consent required Owner consent required Owner consent required Owner consent required Owner consent required Comments/views of owner/occupier

17 Community Community unlikely to accept option Community unlikely to accept option Community unlikely to accept option Community unlikely to accept option Community may accept option Community unlikely to accept option

Overall Comment in response to Assessment Criteria: 1 - Cost4- Potential Impacts10 - Risks and Mitigation11 - Key dependencies.

1: Volume of material4: Will initially destroy ecosystem compared to benefit provided.10: No current disposal options in Victoria.11: Treat/manage surface water and source of discharge to The Heart Morass to minimise recontamination.Cultural Heritage considerations for ecosystem modification.

1: Volume of material4: Will initially destroy ecosystem compared to benefit provided.10: No current licensed treatment options in Victoria.11: Treat/manage surface water and source of discharge to The Heart Morass to minimise recontamination.Cultural Heritage considerations for ecosystem modification.

1: Large area to cap4: Will initially affect ecosystem compared to benefit provided.10: Covering impacted sediment may result in residual re-contamination risk.11: Treat/manage surface water and source of discharge to The Heart Morass to minimise recontamination.Cultural Heritage considerations for ecosystem modification.

1: Volume of material & Repository cost4: Will initially destroy ecosystem compared to benefit provided.10: Siting of repository and management responsibility.11: Treat/manage surface water and source of discharge to The Heart Morass to minimise recontamination.Cultural Heritage considerations for ecosystem modification.

1: Significant water engineering works and water treatment cost. Volume of water.4: May need to acquire lands for surface detention. Option may create storage wetland with associated ecological risks. Increased bird strike risk.11: Success highly dependant on other measures (source management) and generally wouldn't be considered on its own. Treat/manage sediments of The Heart Morass to minimise recontamination.

1: Low cost4: Ongoing community stigma associated with administration of advice and monitoring enforcement.10: Ongoing consumption and ecological risks

1. Human consumption of fish caught from The Heart Morass. 2. Human consumption of ducks recreationally hunted from The Heart Morass.3. Exposure of aquatic ecological receptors in surface waters, and to higher order predators consuming these biota.6. Shallow groundwater (Upper Alluvium) impacts migrating off-site onto private properties.8. Migration pathways from soil sources on-site

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Source control - soil/sediment management

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The Heart MorassImpacted surface water within The Heart MorassImpacted sediment within The Heart MorassStormwater Drains (Source Area ID 17)

Pathway management - water

Table E3-B: Site Surface Water Options Analysis

Risk Source AreaContributing SourcesRisk ID and Description



Management Option (Functional) TitleExcavation & Off-site Disposal of sediments

Excavation & Treatment of sediments

Stabilisation/ Immobilisation of sediments

In-situ Containment (capping) of sediments

Ex-situ Containment (repository) of sediments

Surface water capture and treatment

Shallow groundwater capture and treatment

In-situ Interception (e.g. PRB, Hydraulic Control)

Drainage improvement - Open Drainage improvement - Closed Management controls

Nature of Hazard Control Elimination Elimination Substitution Engineering Control Engineering Control Engineering Control Engineering Control Engineering Control Engineering Control Engineering Control Administrative ControlOption Applicable No No No No

1Cost Range estimate Category 2 Category 2 Category 2 Category 3 Category 2 Category 3 Category 2

2Effectiveness rating High High Medium High Medium High Medium

3Implementation period / timeframe Short term Short term Short term Medium term Long term Short term Medium term

4Potential impacts May have positive environmental and

socioeconomic benefits.May have positive environmental and socioeconomic benefits.



Likely to have positive environmental and socioeconomic benefits.



5Est. Net Env. Benefit Significant Significant Moderate Moderate Moderate Significant Significant

6Proportion of action to risk Scale and Cost marginally

proportionate to riskScale and Cost marginally proportionate to risk




Scale and Cost marginally proportionate to risk


7Best practice status Measure is less than accepted

industry practiceMeasure constitutes accepted industry practice

Measure is less than accepted industry practice





8Verification status Remediation technology status

verifiedRemediation technology status verified






9Technology assessment May have significant logistical

considerationsMay have significant logistical considerations




Unlikely to have significant logistical considerations


10Risks and mitigation High (list issues) High (list issues) High (list issues) High (list issues) Medium Medium Medium

11Key dependencies








12Defence Capability May affect capability May affect capability May affect capability May affect capability Unlikely to affect capability Unlikely to affect capability Highly likely to affect capability

13Project Fit TBC TBC TBC TBC Consistent with other sites Consistent with other sites Consistent with other sites

14Scalability Option able to be scaled Option able to be scaled Option able to be scaled Option able to be scaled Option able to be scaled Option able to be scaled Option able to be scaled

15Jurisdictional regulator/s EPA EPA N/A N/A N/A N/A N/A

16

Owner / occupier consents and views Comments/views of owner/occupier Comments/views of owner/occupier Comments/views of owner/occupier Comments/views of owner/occupier Comments/views of owner/occupier Comments/views of owner/occupier Comments/views of owner/occupier

17Community Community may accept option Community may accept option Community may accept option Community likely to accept option Community likely to accept option Community may accept option Community may accept option


1: Volume of sediments & Length of Drains4: Mobilisation of sediments in surface water drainage.10: No current disposal options in Victoria.11: Requires treatment/management of source area and surface water PFAS impacts to minimise re-contamination.

1: Volume of sediments4: Mobilisation of sediments in surface water drainage.10: No current licensed treatment options in Victoria.11: Requires treatment/management of source area and surface water PFAS impacts to minimise re-contamination.

1: Large area to cap4: Will not remove impacted sediment.10: Covering impacted sediment may result in residual re-contamination risk. Scouring of capping may mobilise contaminants.11: Requires treatment/management of source area and surface water PFAS impacts to minimise re-contamination.

1: Volume of material & Repository cost.4: Will initially destroy ecosystem compared to benefit provided.10: Siting of repository and management responsibility.11: Requires treatment/management of source area and surface water PFAS impacts to minimise re-contamination.

1: Significant water engineering works and water treatment cost.4: May need to acquire lands to surface detention. Option will create wetland with associated ecological risks. Increased bird strike risk.11: Success highly dependant on other measures (source management) and generally wouldn't be considered on its own.

1: Cost of concrete lining open drainage network.4: May increase drainage discharge from site (reduced infiltration).10: Risk of seepage within drainage backfill from shallow groundwater discharging to surface waters. May still need to manage sediment for effective construction/implementation.Could be dependant on other measures (source management).

1: Low cost4: Ongoing community stigma associated with administration of advice and monitoring enforcement.10: Ongoing consumption and ecological risks

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Site Surface WaterStormwater Drains (Source Area ID 17)1. Human consumption of fish caught from The Heart Morass. 2. Human consumption of ducks recreationally hunted from The Heart Morass.3. Exposure of aquatic ecological receptors in surface waters, and to higher order predators consuming these biota.6. Shallow groundwater (Upper Alluvium) impacts migrating off-site onto private properties.8. Migration pathways from soil sources on-site


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Pathway management - water Engineering Control

Table E3-C: Southeast Area Options Analysis

Risk Source AreaContributing Sources



Engineering Control Exposure (receptor) Control

Management Option (Functional) TitleExcavation & Off-site Disposal Excavation & Treatment Stabilisation/ Immobilisation In-situ Containment (capping) Ex-situ Containment (repository) Shallow groundwater capture and treatment In-situ Interception (e.g. PRB, Hydraulic Control)

Fencing Source Areas - Risk to on-site cattle only

Consumption advisory; management controls - Risk to on-site cattle only

Nature of Hazard Control Elimination Elimination Substitution Engineering Control Engineering Control Engineering Control Engineering Control Engineering Control Administrative Control

1Cost Range estimate Category 2 Category 2 Category 2 Category 3 Category 3 Category 2 Category 2 Category 4 Category 4

2Effectiveness rating High High Medium Medium High with Supplementary Option Medium Medium High Medium with Supplementary Option

3Implementation period / timeframe Short term Short term Short term Short term Medium term Long term Long term Short term Short term

4Potential impacts Likely to have positive environmental

and socioeconomic benefits.Likely to have positive environmental and socioeconomic benefits.








5Est. Net Env. Benefit Moderate Moderate Marginal Moderate Moderate Moderate Marginal Marginal Marginal



Scale and Cost marginally proportionate to risk Scale and Cost proportionate to risk Scale and Cost proportionate to risk Scale and Cost marginally proportionate to risk Scale and Cost marginally proportionate to risk Scale and Cost proportionate to risk Scale and Cost proportionate to risk





Measure constitutes accepted industry practice Measure constitutes accepted industry practice Measure constitutes accepted industry practice N/A Measure constitutes accepted

industry practice


verifiedRemediation technology status verified Remediation technology not verified Remediation technology status

verifiedRemediation technology status verified Remediation technology status verified Remediation technology status verified N/A N/A

9Technology assessment Unlikely to have significant logistical




Unlikely to have significant logistical considerations May have significant logistical considerations May have significant logistical considerations Unlikely to have significant logistical

considerations N/A

10Risks and mitigation Low Medium Medium Medium Medium Medium High (list issues) Low High (list issues)

11Key dependencies










12Defence Capability Highly unlikely to affect capability Highly unlikely to affect capability Highly unlikely to affect capability Highly unlikely to affect capability Unlikely to affect capability Highly unlikely to affect capability Highly unlikely to affect capability Highly unlikely to affect capability Highly unlikely to affect capability

13Project Fit TBC TBC TBC TBC TBC Consistent with other sites Not used at other sites Consistent with other sites Consistent with other sites

14Scalability Option not able to be scaled Option able to be scaled Option able to be scaled Option able to be scaled Option able to be scaled Option able to be scaled Option able to be scaled Option able to be scaled Option not able to be scaled

15Jurisdictional regulator/s EPA EPA N/A N/A N/A N/A N/A N/A EPA, DEDJTR, DHHS

16

Owner / occupier consents and views Comments/views of owner/occupier Comments/views of owner/occupier Comments/views of owner/occupier Comments/views of owner/occupier Comments/views of owner/occupier Comments/views of owner/occupier Comments/views of owner/occupier Occupier consent required Occupier consent required

17Community Community likely to accept option Community likely to accept option Community likely to accept option Community may accept option Community may accept option Community may accept option Community may accept option Community likely to accept option Community may accept option


1: Volume of sources4: -10: No current disposal options in Victoria.

1: Volume of sources4: -10: No current licensed treatment options in Victoria.

1: Large treatment volume.4: - 10: Significant assessment to verify dosing rate and treatment effectiveness.

1: Large area to cap4: Will not remove impacted materials.10: Covering impacted material may result in residual re-contamination risk. Ongoing management of cap required.

1: Volume of material & Repository cost4: -.10: Siting of repository and management responsibility.

1: Cost to install extraction and treatment plant. 4: Will not remove impacted materials.10: Risk of inadequate capture and seepage discharge to drainage network. Does not address overland discharge from impacted surface materials (requires source management). Treated water and waste discharge considerations. Monitoring performance requirements.

1: Cost to install extraction and treatment plant or install filter media. 4: Will not remove impacted materials.10: Risk of inadequate capture and seepage discharge to drainage network. Does not address overland discharge from impacted surface materials (requires source management). Treated water and waste discharge considerations. Filter media (PRB) replacement and treatment/disposal. Monitoring performance requirements.

1: Low cost4: Ongoing community stigma associated with administration of advice and monitoring enforcement.10: Ongoing consumption risk

1: Low cost4: Ongoing community stigma associated with administration of advice and monitoring enforcement.10: Ongoing consumption risk

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Source control - soil management

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Stormwater Drains (Source Area ID 17)Former Fire Training Area (Source ID 08 and 09)

1. Human consumption of fish caught from The Heart Morass. 2. Human consumption of ducks recreationally hunted from The Heart Morass.3. Exposure of aquatic ecological receptors in surface waters, and to higher order predators consuming these biota.4. Human consumption of meat, milk or offal from livestock raised on-site into which PFAS has bioaccumulated.5. Shallow groundwater impacts migrating on-site.6. Shallow groundwater (Upper Alluvium) impacts migrating off-site onto private properties.7. Deeper groundwater impacts migrating off-site.8. Migration pathways from soil sources on-site.


Table E3-D: Fire Station and Testing Area Options Analysis

Risk Source Area

Contributing Source Area IDs


Source, Pathway or Exposure (Receptor) Control measureManagement Option (Functional) TitleExcavation & Off-site Disposal Excavation & Treatment Stabilisation/ Immobilisation In-situ Containment (capping) Ex-situ Containment (repository) Shallow groundwater capture and treatment In-situ Interception (e.g. PRB, Hydraulic

Control)Nature of Hazard Control Elimination Elimination Substitution Engineering Control Engineering Control Engineering Control Engineering Control


2Effectiveness rating High with Supplementary Option High with Supplementary Option Medium with Supplementary Option High with Supplementary Option Medium with Supplementary Option Medium Medium

3Implementation period / timeframe Medium term Medium term Medium term Short term Medium term Long term Long term

4Potential impacts








5Est. Net Env. Benefit Moderate Moderate Marginal Moderate Moderate Moderate Marginal

6Proportion of action to risk Scale and Cost disproportionate to

riskScale and Cost disproportionate to risk



Scale and Cost disproportionate to risk Scale and Cost marginally proportionate to risk Scale and Cost marginally proportionate to risk





Measure constitutes accepted industry practice Measure constitutes accepted industry practice Measure constitutes accepted industry practice



verifiedRemediation technology status verified Remediation technology status verified Remediation technology status verified

9Technology assessment Likely to have significant logistical

considerationsLikely to have significant logistical considerations



Likely to have significant logistical considerations May have significant logistical considerations May have significant logistical considerations

10Risks and mitigation Low Medium Medium Medium Medium Medium High (list issues)

11Key dependencies








12Defence Capability Highly likely to affect capability Highly likely to affect capability Likely to affect capability May affect capability Highly likely to affect capability Highly unlikely to affect capability May affect capability

13Project Fit TBC TBC TBC TBC TBC Consistent with other sites Not used at other sites

14Scalability Option not able to be scaled Option able to be scaled Option able to be scaled Option able to be scaled Option able to be scaled Option able to be scaled Option able to be scaled


16


17Community Community likely to accept option Community likely to accept option Community likely to accept option Community may accept option Community may accept option Community may accept option Community may accept option


1: Volume of sources4: -10: No current disposal options in Victoria.11: Incomplete access due to operational nature of the area.

1: Volume of sources4: -10: No current licensed treatment options in Victoria.11: Incomplete access due to operational nature of the area.

1: Large treatment volume.4: - 10: Significant assessment to verify dosing rate and treatment effectiveness11: Incomplete access due to operational nature of the area.

1: Large area to cap4: Will not remove impacted materials.10: Covering impacted material may result in residual re-contamination risk. 11: Incomplete access due to operational nature of the area. May be practical in grassed areas as part of pavement upgrades.

1: Volume of material & Repository cost4: -.10: Siting of repository and management responsibility.11: Incomplete access due to operational nature of the area. May need to be contemplated with upgrades only

1: Cost to install extraction and treatment plant. 4: Will not remove impacted materials.10: Risk of inadequate capture and seepage discharge to drainage network. Does not address overland discharge from impacted surface materials (requires source management). Treated water and waste discharge considerations. Monitoring performance requirements.

1: Cost to install extraction and treatment plant or install filter media. 4: Will not remove impacted materials.10: Risk of inadequate capture and seepage discharge to drainage network. Does not address overland discharge from impacted surface materials (requires source management). Treated water and waste discharge considerations. Filter media (PRB) replacement and treatment/disposal. Monitoring performance requirements.


1. Human consumption of fish caught from The Heart Morass. 2. Human consumption of ducks recreationally hunted from The Heart Morass.3. Exposure of aquatic ecological receptors in surface waters, and to higher order predators consuming these biota.5. Shallow groundwater impacts migrating on-site.6. Shallow groundwater (Upper Alluvium) impacts migrating off-site onto private properties.8. Migration pathways from soil sources on-site.

Stormwater Drains (Source Area ID 17)Current Fire Station (Source ID 06)Grassed area near runways used for AFFF testing (Source ID 16)

Fire Station and Testing Area

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Table E3-E: Northwest Area Options Analysis

Risk Source AreaContributing Source Area IDs





Nature of Hazard Control Elimination Elimination Substitution Engineering Control Engineering Control Engineering Control Engineering Control


2Effectiveness rating High High Medium Medium High with Supplementary Option Medium Medium

3Implementation period / timeframe Short term Short term Short term Short term Medium term Long term Long term

4Potential impacts Likely to have positive environmental

and socioeconomic benefits.Likely to have positive environmental and socioeconomic benefits.






5Est. Net Env. Benefit Moderate Moderate Moderate Moderate Moderate Moderate Marginal



Scale and Cost marginally proportionate to risk Scale and Cost proportionate to risk Scale and Cost disproportionate to

risk Scale and Cost marginally proportionate to risk Scale and Cost marginally proportionate to risk














Unlikely to have significant logistical considerations May have significant logistical considerations


11Key dependencies








12Defence Capability Highly likely to affect capability Highly likely to affect capability Likely to affect capability Likely to affect capability Highly likely to affect capability Unlikely to affect capability Likely to affect capability




16


17Community Community likely to accept option Community likely to accept option Community likely to accept option Community may accept option Community may accept option Community may accept option Community may accept option


1: Volume of sources4: -10: No current disposal options in Victoria.11: Incomplete access due to operational nature of the area.

1: Volume of sources4: -10: No current licensed treatment options in Victoria.11: Incomplete access due to operational nature of the area.

1: Large treatment volume.4: - 10: Significant assessment to verify dosing rate and treatment effectiveness11: Incomplete access due to operational nature of the area.

1: Large area to cap4: Will not remove impacted materials.10: Covering impacted material may result in residual re-contamination risk. 11: Incomplete access due to operational nature of the area. May be practical in grassed areas as part of pavement upgrades.

1: Volume of material & Repository cost4: -.10: Siting of repository and management responsibility.11: Incomplete access due to operational nature of the area. May need to be contemplated with upgrades only

1: Cost to install extraction and treatment plant. 4: Will not remove impacted materials.10: Risk of inadequate capture and seepage discharge to drainage network. Does not address overland discharge from impacted surface materials (requires source management). Treated water and waste discharge considerations. Monitoring performance requirements. Potentially significant access restrictions.

1: Cost to install extraction and treatment plant or install filter media. 4: Will not remove impacted materials.10: Risk of inadequate capture and seepage discharge to drainage network. Does not address overland discharge from impacted surface materials (requires source management). Treated water and waste discharge considerations. Filter media (PRB) replacement and treatment/disposal. Monitoring performance requirements. Potentially significant access restrictions.

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Northwest AreaStormwater Drains (Source Area ID 17)MEOMS and grassed area used for AFFF testing (Source ID 01, 02, 03 and 14)1. Human consumption of fish caught from The Heart Morass. 2. Human consumption of ducks recreationally hunted from The Heart Morass.3. Exposure of aquatic ecological receptors in surface waters, and to higher order predators consuming these biota.5. Shallow groundwater impacts migrating on-site.8. Migration pathways from soil sources on-site.

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Table E3-F: Central Area Options Analysis

Risk Source AreaContributing Source Area IDs





Nature of Hazard Control Elimination Elimination Substitution Engineering Control Engineering Control Engineering Control Engineering Control


2Effectiveness rating High with Supplementary Option High with Supplementary Option High with Supplementary Option Medium Medium Medium Medium

3Implementation period / timeframe Short term Short term Short term Short term Medium term Long term Long term

4Potential impacts








5Est. Net Env. Benefit Moderate Moderate Marginal Moderate Moderate Moderate Marginal

6Proportion of action to risk Scale and Cost disproportionate to

riskScale and Cost disproportionate to risk



Scale and Cost disproportionate to risk Scale and Cost marginally proportionate to risk Scale and Cost marginally proportionate to risk










considerationsUnlikely to have significant logistical considerations



May have significant logistical considerations May have significant logistical considerations May have significant logistical considerations


11Key dependencies








12Defence Capability Highly likely to affect capability Highly likely to affect capability Likely to affect capability May affect capability Highly likely to affect capability Unlikely to affect capability May affect capability




16


17Community Community likely to accept option Community likely to accept option Community may accept option Community likely to accept option Community likely to accept option Community may accept option Community may accept option


1: Volume of sources4: -10: No current disposal options in Victoria.11: Potential incomplete access to some sources due to operational nature of the area.

1: Volume of sources4: -10: No current licensed treatment options in Victoria.11: Potential incomplete access to some sources due to operational nature of the area.

1: Large treatment volume.4: - 10: Significant assessment to verify dosing rate and treatment effectiveness11: Potential incomplete access to some sources due to operational nature of the area.

1: Large area to cap4: Will not remove impacted materials.10: Covering impacted material may result in residual re-contamination risk. 11: Potential incomplete access to some sources due to operational nature of the area. May be practical in grassed areas as part of pavement upgrades.

1: Volume of material & Repository cost4: -.10: Siting of repository and management responsibility.11: Potential incomplete access to some sources due to operational nature of the area. May need to be contemplated with upgrades only

1: Cost to install extraction and treatment plant. 4: Will not remove impacted materials.10: Risk of inadequate capture and seepage discharge to drainage network. Does not address overland discharge from impacted surface materials (requires source management). Treated water and waste discharge considerations. Monitoring performance requirements. Potentially significant access restrictions.

1: Cost to install extraction and treatment plant or install filter media. 4: Will not remove impacted materials.10: Risk of inadequate capture and seepage discharge to drainage network. Does not address overland discharge from impacted surface materials (requires source management). Treated water and waste discharge considerations. Filter media (PRB) replacement and treatment/disposal. Monitoring performance requirements. Potentially significant access restrictions.

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Central AreaStormwater Drains (Source Area ID 17)Former AFFF Testing Area (Source ID 11)Current Fire Training and Former Sewage Treatment (Source Area ID 13)

1. Human consumption of fish caught from The Heart Morass. 2. Human consumption of ducks recreationally hunted from The Heart Morass.3. Exposure of aquatic ecological receptors in surface waters, and to higher order predators consuming these biota.5. Shallow groundwater impacts migrating on-site.8. Migration pathways from soil sources on-site.

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August 2018

APPENDIX F Ongoing monitoring plan

Ongoing Monitoring Plan PFAS Management Area Plan – RAAF Base East Sale (0937)

Document History

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Distribution

Ongoing Monitoring Plan PFAS Management Area Plan – RAAF Base East Sale (0937)

July 2018

Copies Recipient Copies Recipient

1 PDF Department of Defence – 26 Brindabella CCT Canberra, ACT, 2600

1 PDF Senversa Project File

1 Reliance - This document has been prepared solely for the use of Department of Defence. No responsibility or liability to any third

party is accepted for any damages arising out of the use of this document by any third party.

2 Copyright and Intellectual Property – © Senversa Pty Ltd. No portion of this document may be removed, extracted, copied,

electronically stored or disseminated in any form by a third party without the prior written permission of Senversa or Department of

Defence. Intellectual property in relation to the methodology undertaken during the creation of this document remains the property of

Senversa.

3 Privacy and Confidentiality – This report was prepared for Department of Defence and may contain confidential information.

Permission from Senversa and the Department of Defence should be sought before any written reference to the contents of this

report is made public that identifies any people, person, address or location named within or involved in the preparation of this

report.

Senversa Pty Ltd ABN: 89 132 231 380 Level 6, 15 William Street, Melbourne VIC 3000 tel: + 61 3 9606 0070; fax: + 61 3 9606 0074 www.senversa.com.au

Primary Author

Project Manager

Senior Environmental Engineer Project Delivery Manager

Peer Review

PFAS Lead and Project Director

Document History

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Document History

Version Date Description Officer 0 9 May 2018 DRAFT - Ongoing Monitoring Plan

1 8 June 2018 DRAFT – Changes to OMP following Defence and Site Auditor Review

2 10 July 2018 DRAFT – Changes to OMP following further comments from Defence and Site Auditor on objectives and frequency of monitoring

Contents

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Contents

Document History ..................................................................................................................................................................... ii

List of Acronyms ....................................................................................................................................................................... v

1.0 Introduction................................................................................................................................................................... 1 1.1 Background................................................................................................................................................................... 1 1.2 Objective ....................................................................................................................................................................... 1 1.3 Purpose and Scope of OMP ......................................................................................................................................... 2 1.4 Management and Monitoring Areas............................................................................................................................. 2 1.5 Responsible Parties ..................................................................................................................................................... 3 1.6 Implementation and Review of OMP............................................................................................................................ 3

2.0 Background Information .............................................................................................................................................. 5 2.1 Management Area Description .................................................................................................................................... 5 2.2 Surface Water ............................................................................................................................................................... 6

2.2.1 Catchment Drainage .......................................................................................................................................... 6 2.2.2 Environmentally Significant Surface Water Bodies ............................................................................................. 6 2.2.3 Site Open Surface Drainage Network ................................................................................................................. 6 2.2.4 Site Closed Stormwater Network ........................................................................................................................ 7 2.2.5 Surface Water Features ..................................................................................................................................... 7 2.2.6 Irrigation Channel Network ................................................................................................................................. 7 2.2.7 Dams ................................................................................................................................................................. 7 2.2.8 Artificial Lakes .................................................................................................................................................... 8

2.3 Geology and Hydrogeology ......................................................................................................................................... 8 2.3.1 Local Geology .................................................................................................................................................... 8 2.3.2 Local Hydrogeology ............................................................................................................................................ 9

2.4 Impacts to Groundwater and Surface Water ............................................................................................................. 10 2.4.1 Potential PFAS Source Areas........................................................................................................................... 10 2.4.2 Groundwater Results ........................................................................................................................................ 11 2.4.3 Surface Water and Sediment Results ............................................................................................................... 12 2.4.4 Water Use ........................................................................................................................................................ 13

3.0 Ongoing Monitoring Program .................................................................................................................................... 14 3.1 Sampling and Analysis Quality Plan ......................................................................................................................... 14 3.2 Groundwater Monitoring ............................................................................................................................................ 14

3.2.1 Monitoring Network .......................................................................................................................................... 14 3.2.2 Water Level Gauging ........................................................................................................................................ 15 3.2.3 Sampling Locations and Frequency .................................................................................................................. 15

3.3 Surface Water and Sediment Monitoring .................................................................................................................. 16 3.3.1 Water Level Monitoring .................................................................................................................................... 16 3.3.2 Sampling Locations and Frequency .................................................................................................................. 16

3.4 Sample Analysis ......................................................................................................................................................... 17 3.5 Data Quality Objectives .............................................................................................................................................. 18

4.0 Reporting Requirements ............................................................................................................................................ 20

Contents

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4.1 PFAS Screening Criteria ............................................................................................................................................ 20 4.2 Reporting of Results .................................................................................................................................................. 20

5.0 Monitoring of Management Measures and Potential Risks ...................................................................................... 22 5.1 Monitoring of Management Measures ....................................................................................................................... 22 5.2 Monitoring Potential Future Risks ............................................................................................................................. 22 5.3 Further Investigation .................................................................................................................................................. 23 5.4 Revision of Risk Assessment .................................................................................................................................... 23

6.0 References .................................................................................................................................................................. 25

Figures

Figure 1: Site Location

Figure 2: Source Areas and Migration Pathways

Figure 3: On-site Groundwater Monitoring Network

Figure 4: Off-site Groundwater Monitoring Network

Figure 5: On-site Surface Water Monitoring Network

Figure 6: Off-site Surface Water Monitoring Network

Appendix A: SAQP Guidance

Appendix B: Well Construction Details

List of Acronyms

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List of Acronyms

Acronym Definition

AS Australian Standard

ANZECC Australian and New Zealand Environment and Conservation Council

COC Chain of custody

DO Dissolved oxygen

DQO Data quality objective

EC Electrical conductivity

EPA Environment Protection Authority (Victoria)

LOR Limit of reporting

NATA National Association of Testing Authorities

NEMP National Environment Management Plan

NEPM National Environment Protection Measure, Assessment of Site Contamination (2003)

OMP Ongoing Management Plan

PFAS Per- and polyfluoroalkyl substances

PFHxS Perfluorohexane sulfonic acid

PFOA Perfluorooctanoic acid

PFOS Perfluorooctane sulfonic acid

PMAP PFAS Management Area Plan

QA Quality assurance

QC Quality control

SWL Standing water level

TOC Total organic carbon

WGCMA West Gippsland Catchment Management Authority

µg/L Micrograms per litre

Introduction

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1.0 Introduction

Department of Defence (Defence) engaged Senversa Pty Ltd to prepare an Ongoing Monitoring Plan (OMP) for PFAS impacts identified at the RAAF Base East Sale (‘the site’) and emanating from the site. The location of the site, and the site boundary, is shown in Figure 1.

1.1 Background

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

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

Most people living in developed nations will have some level of PFAS in their body due to their widespread use. In June 2016, the Environmental Health Standing Committee (enHealth)1, published guidance statements advising that there is currently no consistent evidence that exposure to PFOS and PFOA causes adverse human health effects. In May 2018, the Department of Health published advice from the Expert Health Panel2 established by the Australian Government, which concluded that “there is mostly limited, or in some cases no evidence, that human exposure to PFAS is linked with human disease”.

However, since these chemicals remain in humans and the environment for many years, it is recommended that as a precaution, human exposure to PFAS be minimised.

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

This OMP has been developed in accordance national guidance in the form of the PFAS National Environmental Management Plan (PFAS NEMP), Defence estate and environmental strategies, and Defence PFAS-specific strategies and guidance.

1.2 Objective

The objective of the OMP is to set out a program of monitoring of groundwater, surface water and sediment quality to continue to assess the changes in the nature and extent of PFAS within the environment, where there is an identified potentially elevated risk to a receptor, or a potential future risk to a receptor, associated with Defence’s historical use of legacy AFFF.

1 EnHealth is a subcommittee of the Australian Health Protection Principal Committee, and is responsible for providing agreed environmental health policy advice. Its membership includes representatives from the Health portfolios of Australian and New Zealand governments. 2 The Expert Health Panel is an independent panel established by the Australian Government, and published their advice in the Expert Health Panel for PFAS Report (Expert Health Panel for PFAS, 2018) available from: http://www.health.gov.au/internet/main/publishing.nsf/Content/ohp-pfas-expert-panel.htm

Introduction

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1.3 Purpose and Scope of OMP

The purpose of undertaking the monitoring specified within the OMP is to:

a) assess any changes in concentrations of PFAS in groundwater and surface water migrating from source areas, and in sediment collected along potential surface water migration pathways since the discontinued use of legacy AFFF (3M lightwater formulation) in 2004;

b) provide ongoing confirmation of earlier findings that risks to receptors utilising impacted media are low and acceptable, or that risk management measures for potentially elevated risks are appropriate;

c) fulfils the recommendations outlined in the PFAS Management Area Plan (PMAP) to provide supporting data to inform the ongoing management requirements for impacted media on and off-site contributing to a potentially elevated risk to receptors.

The monitoring proposed in this OMP is primarily to evaluate changes in the nature and extent of groundwater, surface water and sediment in the management and monitoring areas (Figure 1). Where relevant, the data collected will also be used to support the ongoing evaluation of management responses outlined in the PMAP, although this is not the specific purpose of the monitoring detailed in this OMP, and additional data may be required to support such an evaluation. Specific further investigation or monitoring to assess the feasibility of a management option, or monitoring to assess the efficacy of the implementation of a management response will be outlined in separate documentation, for example, this could be within:

• an SAQP for a feasibility study;

• a remediation action plan for implementation of a management response; or

• a validation plan following the implementation of a management response.

For example, a discharge study to assess the feasibility of drainage improvement works may include a greater frequency of monitoring of water levels in shallow groundwater and the surface water in the main drains than is required in this monitoring plan to assess trends in migration.

This document provides the following:

• Identifies roles and responsibilities including those of Defence (Section 1.4).

• Describes site setting and relevant features of the environmental setting (Section 2.0).

• Summarises the recommended sampling network and frequency (Section 3.0).

1.4 Management and Monitoring Areas

The Management Area incorporates the RAAF Base East Sale property (including an area of Defence-managed land to the east and southeast leased for livestock grazing) (on-site). It also includes a Monitoring Area that incorporates private properties to the south and southeast of the RAAF Base, and The Heart Morass wetlands (including private and publicly managed land) (off-site). Background monitoring locations have also been included within the Latrobe River and Flooding Creek to assess the potential contributions from wider catchment PFAS impacts.

The extent of the proposed Management Area and Monitoring Areas is also shown in Figure 1 (attached).

Introduction

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1.5 Responsible Parties

As the occupier of the site and source of PFAS impacts, Defence is responsible for the implementation of this OMP, which includes the following roles and responsibilities.

Role Responsibilities

Department of Defence (PFAS Investigations Management Branch, Base Managers, Environmental and Sustainability Officers)

Implementation of the requirements of the OMP, including engagement of suitably trained and qualified environmental personnel (Sampler) who is experienced in environmental sampling, monitoring and interpretation of results and a NATA Accredited Laboratory for sample analysis. Provide access to base and facilitate access to private properties. Review monitoring reports and assess additional monitoring requirements or risk revision based on recommendations.

Groundwater and surface water Quality Sampler Contractor / Consultant

Planning and undertaking the monitoring activities in accordance with this OMP and reference guidance Development and implementation of a sampling and analysis quality plan (SAQP) as per the guidance provided within this document including collection of water samples, and submission of samples to NATA (National Association of Testing Authorities) accredited laboratory. Arrange access approvals to base and private properties for sampling. Report the outcomes of the monitoring to Defence in line with the requirements specified in this OMP and SAQP.

NATA Accredited Laboratory Contractor

Reporting of analysis of results to Defence and/or Sampler. Provide NATA certified reports to Defence, including provision of electronic reporting to allow updating Defence database with the latest results and all associated Quality Assurance/Quality Control (QA/QC).

1.6 Implementation and Review of OMP

This OMP will be implemented for an initial period of 12 months to provide one dataset that assesses temporal (seasonal) and spatial (location) changes in PFAS concentrations. At the end of the 12 month period, the data will be reviewed and evaluated to establish:

• The ongoing sampling frequency considered suitable to assess nature and extent of groundwater and surface water PFAS impacts sourced from the site over time, based on the system dynamics and environmental setting such as hydrogeology and flow events.

• The implementation period for ongoing monitoring to establish trends to a statistical confidence limit.

• Trigger points and contingency measures to be adopted for increasing concentrations.

However, updates within the initial 12 month period may be required, for reasons such as the following:

• The groundwater monitoring well or surface water location network changes due to the installation of new locations or modification of existing locations from damage or construction works.

• Procedures for data collection (sampling) need to change.

• Updates to reference documents or guidelines.

• Revision of the human health and ecological risk assessment for the site.

• The publishing of updated criteria for PFAS.

• Availability of analytical techniques to detect additional PFAS.

Introduction

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• Implementation of management responses or infrastructure upgrades associated with or near to current identified source areas or migration pathways (e.g. drainage network).

This OMP is a working document and will be reviewed for currency and relevance on a periodic basis (at least annually) and as required by Defence. Revision may also be required to address regulatory changes or policy changes within Defence.

As described above, the OMP will be implemented for an initial period of 12 months, and the frequency of ongoing monitoring and required monitoring locations, will be reviewed at this point. It is emphasised that ongoing monitoring is anticipated to be required beyond the initial 12 month period, and is likely to be implemented for a period of at least three years.

Background Information

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2.0 Background Information

2.1 Management Area Description

The RAAF Base East Sale is in the Gippsland region of Victoria, approximately 220 km southeast of Melbourne and approximately 5 km east of the centre of Sale (Figure 1).

The East Sale Base is an active major RAAF Base, airport and training centre and supports a capacity of approximately 700 personnel. The site is 8 km2 (800 ha) in area and includes a range of land uses that are ancillary to the aerodrome and aircraft support areas, such as accommodation, childcare facilities, recreation areas, cleared open space and leased grazing land. It will continue to be used as a RAAF Base, airport and training school for the foreseeable future. Significant upgrades to site facilities are currently underway to accommodate proposed growth of the training school.

The Base is commonwealth land located in a rural area east of Sale township, with all land surrounding the Base zoned ‘Farming (FZ)’ in the Willington Shire Council municipality. The surrounding land is used principally for dairy farming (and associated pasture irrigation), but also cattle (beef) grazing and associated rural residential uses, with approximately 30 rural residential homes within a 1 km radius of the site boundary.

The Base is located in an environmentally sensitive area, close to wetlands of ecological significance, including The Heart Morass to the south, and the Gippsland Lakes RAMSAR site at Lake Wellington to the east (Figure 3). Drainage from the site leads to these areas (Figure 4).

The Heart Morass is also located between two areas of the Gippsland Lakes RAMSAR wetlands, which are wetlands considered to have significant ecological value. In addition, this area is used as a game reserve for duck hunting, fishing, and other recreational purposes and is highly valued by the community.

The region generally, and specifically the wetlands to the south and lakes systems to the east, are culturally significant for the local indigenous community.

The Management Area includes the Base, 13 private properties and The Heart Morass (which incorporates six of the private properties and public land). The boundary of the Management Area (Figure 1) was determined by the findings of the HHERA, the potential risks (with currently incomplete pathways) requiring monitoring or further investigation outlined in the DSI and analysis of both surface water discharge from site and groundwater flow direction (generally to the southeast) from likely source areas or impacted boundary monitoring wells.

The Management Area incorporating private properties to the east and southeast is defined as an off-site Monitoring Area, as there are currently low and acceptable risks to off-site land based private properties, and may be revised with further investigations of the extent of shallow and deeper groundwater impacts in this area or based on results of ongoing monitoring. The outer extents have generally been aligned with property boundaries (i.e. straight line boundaries in some cases) where there is uncertainty of the nature and extent of groundwater impacts off-base in these areas and therefore includes a conservative consideration of the potential for future impacts from migration of PFAS from the base. Based on groundwater flow directions and flow velocity, PFAS impacts associated with Defence’s use of AFFF on the Base would not expect to currently be present beyond this area, if present at all on these properties.

Private properties incorporating the waters of The Heart Morass are included as a Monitoring Area due to the potentially elevated risks for human consumption of aquatic animals in this area and to the ecosystems.


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2.2 Surface Water

2.2.1 Catchment Drainage

The site is located in the ‘Gippsland Lakes and Hinterland’ landscape priority area within the West Gippsland region (WGCMA, 2012). The major rivers across the broader West Gippsland catchment drain towards this low lying area, with the confluence of the Thomson and Latrobe Rivers to the south of Sale township at the Sale Common. The Latrobe River drains east from the Common into Lake Wellington and ultimately the Southern Ocean. Groundwater and surface water across the catchment generally drains from west to east, towards the Gippsland Lakes.

2.2.2 Environmentally Significant Surface Water Bodies

The Heart Morass wetlands are located approximately 500 m to the south of the site (see Figure 1). The Heart Morass includes 1,125 ha of land covered by a protective covenant, with the eastern portion a State Game Reserve managed by Parks Victoria. The Latrobe River runs adjacent to the wetlands, with the river and wetlands draining into Lake Wellington approximately 4 km east of the site. The Dowd Morass wetlands are located directly south of the Latrobe River and the Sale Common wetlands are located to the east of the confluence of the Thompson and Latrobe Rivers.

The Heart Morass was historically significantly degraded due to widespread clearing, heavy grazing, poor water management, acid sulphate soils and salinity impacts, resulting in the wetland drying completely for the first time in 2006 (WGCMA, 2016). Rehabilitation of the area has occurred since 2006, with a subsequent improvement in the health and function of the local ecology. The Heart Morass is also located between two areas of the Gippsland Lakes RAMSAR wetlands, which are wetlands considered to have significant ecological value. In addition, this area is used as a game reserve for duck hunting, fishing, and other recreational purposes and is highly valued by the community.

2.2.3 Site Open Surface Drainage Network

There are a number of closed (concrete lined) stormwater drains which become open, unlined drainage channels that generally follow the topography of the site and divert surface runoff across and off the site to the south, north and east. The alignment of these drainage lines is shown on Figure 2. Generally, surface water diverts around the runways, discharging to the north and east from the northern boundary, and to the south from the southern site boundary. Stormwater captured across the majority of operational areas is generally diverted southwards along three engineered open drains and the principle drainage discharge point is at the south-eastern boundary to The Heart Morass. The three main drainage lines comprise:

• Eastern “main” Drain: This originates in the north of the site from the eastern end of the airfield where it is shallow and then deepens to 4-5 m as it runs north-south in the eastern portion of the site, where ultimately it discharges in the south-eastern corner of the site to The Heart Morass. The Eastern Drain aligns with a natural former unnamed creek that is evident on historical site geology maps.

• Western Drain: This originates in the northwest from the Base facilities and operational areas and is generally between 1-2 m deep and concrete lined at its base until approximately the golf course area (Figure 2). Drainage runs in an unlined channel to the southern boundary where water accumulates in a recently constructed stormwater retention pond as part of recent drainage upgrade works in this area (2016), which now divert all surface water east in a concrete lined culvert to converge with the Eastern Drain. It is noted from site observations and discussion with Base personnel that the Western Drain previously discharged at the intersection with the southern boundary off-site into an overflow drain and then through the adjacent agricultural land (now a dam is present), before draining to The Heart Morass.


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• Central Drain: The Central Drain system is located south of the airfield and drains central areas towards the retention pond and Western Drain. The Central Drain system predominantly consists of an unlined open channel that ranges in depth from 0.5 m to 2 m deep.

To the north of the runways, stormwater drainage flows north and discharges off-site into stormwater drains along Cobains Road, with the stormwater travelling towards the low lying areas east of the site, and ultimately to Lake Wellington beyond. There is also a number of shallow stormwater drainage lines present on the site that drain to the Western, Central or Eastern Drain. Shallow drainage alignments are present in the northeast corner and in the east that could act as pathway for off-site surface water migration in times of high flow.

The water within the drainage lines on-site is not known to be collected or used for any purposes such as irrigation or stock watering.

2.2.4 Site Closed Stormwater Network

A below ground formal network of stormwater drains is present across the operational areas in the west of the site (Figure 2). This network captures stormwater from sealed areas of the site, with drains observed to be present in a number of key legacy AFFF usage and storage areas. These include warehouses and maintenance areas, fire stations, chemical storage areas, roadways, and paved areas where fire trucks were parked, filled with AFFF and maintained.

The below ground closed stormwater drainage network ultimately discharges off-site via the main open surface drains.

2.2.5 Surface Water Features

There are several areas of inundation in low lying areas in the southern and eastern portions of the site that likely collect surface water run-off during high rainfall events. The Eastern Drain, which is inferred to intersect shallow groundwater corresponds with the location of a former creek system identified as the only on-site surface water on the surface geology map for the site. There are also inundation features to the west of the site associated with a former creek system that flowed into The Heart Morass.

2.2.6 Irrigation Channel Network

The site is located within the Macalister Irrigation District (MID), the largest irrigation area south of the Great Dividing Range, which supplies water to central Gippsland via a large, formal network of irrigation channels and associated infrastructure. The MID comprises a gravity fed irrigation network that feeds water sourced from Lake Glenmaggie to the ‘farm gate’, where it is directed by individual properties into their on-farm irrigation systems (SRW, 2016). The MID district is dominated by dairy cattle but in some areas supports horticulture, beef cattle and cropping. The irrigation season in the Sale area runs from August to May, with the water used primarily for irrigation of dairy pasture and some other incidental uses such as stock watering.

The site is at the south-eastern edge of the MID, and the network does not extend to properties on the east or southeast of the site where bore water is relied on for irrigation.

2.2.7 Dams

No significant dams or surface water storage bodies are present on-site.

A number of private dams are present on properties surrounding the site, with the majority of these dams being unlikely to receive water from the site. A large off-site dam located to the south of the site previously received surface water draining from the site, however, drainage line upgrade works (as discussed above) have diverted this pathway, with site surface water now diverted to the Eastern Drain prior to off-site migration. This off-site dam to the south also appears to have been upgraded recently, and is filled with groundwater from extraction bores on the property.


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2.2.8 Artificial Lakes

Two small artificial ornamental lakes are located at the on-site golf course which do not permanently contain water. One larger ornamental lake directly north of the current fire training area (Source ID 13 on Figure 2) is located at the eastern end of the golf course and is fed by a fire hydrant. From information provided by the Base, water from this lake is not used for any purpose, however, has been used historically to irrigate the golf course.

Lake Edwards, located to the south of the site entrance, was formerly a quarry created when the Base was constructed which was subsequently filled with waste derived from on-site (SMEC, 2005). The lake was anecdotally reported as being used for swimming and recreational purposes prior to being drained over 10 years ago due to safety concerns, with the area remaining fenced off. The lake can fill during periods of high rainfall such as during the DSI groundwater sampling, but is dry for the majority of the year, indicating the invert level is too high to regularly receive shallow groundwater in this area.

2.3 Geology and Hydrogeology

2.3.1 Local Geology

The majority of the DSI intrusive locations, and the previous investigation at the site targeted the shallow Quaternary-aged flood plain and quaternary alluvial terrace deposits (0 – 6 m bgl - clays, silts and clayey sands). Several DSI locations targeted the quaternary Lower Alluvium (approximately 7-10 m bgl) and the Quaternary-aged sediments of the Haunted Hills Formation (10-15 m bgl - silty sands, sands and gravelly sands) as well, with one location advanced to the top of the Boisdale Formation (Nuntin Clay – 36 m bgl).

The Macalister Irrigation District Soil Permeability Map (SKM, 2001) indicates that a majority of the site is within a moderate to high permeability plain, with very low permeability units present on the eastern boundary portion of the site and in the southwestern portion of the site.

The following table summarises the general sub-surface soil conditions encountered across the site during the DSI (Senversa, 2017a).

Summary of Soil Conditions Encountered



0.0 – 0.05/0.1 Grass/Topsoil/ Crushed Rock/ Concrete / Asphalt

Grass and topsoil were encountered at most grid based surface soil sample locations in the open space and grazing lease areas. Some areas were covered by a thin profile of crushed rock. Concrete surface slab or asphalt surface cover was present at three locations. Topsoil was observed as soil directly below the grass surface cover and generally consisted of: Fill (topsoil): Brown, sandy silt with fine grained sand, trace clay and roots. Uniformly graded, rounded sand.

0.0 – 1.0 Fill Fill: Brown/yellow brown/red brown, sand/ silty sand / sandy gravel / sandy silt with minor to trace angular gravel, silt and clay. Anthropogenic material observed at 25 of the 412 locations included trace fine brick fragments, concrete fragments, glass, plastic, wood, metal, material, ash, bitumen and terracotta.


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0.1 – 5.0 to 7.0 Upper Alluvium The Upper alluvium consists of interbedded silts, sand and clays. The following lithologies were present in this general order from shallow to deep. Clayey SILT/ Silty CLAY: Low to medium plasticity brown, yellow brown and red brown silty clay/clayey silt with trace fine grained sand. Uniformly graded, rounded sand. SILT: Non-plastic Orange-brown mottled brown and light grey, soft, silt with minor fine sand with trace clay. Uniformly graded, rounded sand. Clayey SAND/ Sandy CLAY: Low plasticity. Brown to light brown and grey, soft, clayey sand/ sandy clay. Uniformly graded, fine grained, well rounded sand. Sandy SILT/Silty SAND: Brown mottled light brown, orange, yellow and grey, fine grained silty sand/sandy silt with trace clay. Uniformly graded, rounded sand. CLAY: Low to high plasticity clay, brown mottled yellow and red brown, trace silty and fine grained sand.

5.5 – 10 to 12 m Lower Alluvium The unit was separated from the Upper alluvium by a 1-2 m thick clay or silty clay unit. The Lower alluvium consisted of the following lithologies. Silty CLAY/ Clayey SILT: Low plasticity to non-plastic. Light brown mottled blue-grey, yellow and orange stiff, silty clay with trace fine grained sand. Uniformly graded, rounded sand. Silty/Clayey SAND: Low plasticity. Brown mottled orange, yellow and grey, silty/clayey sand. Uniformly to gap graded, rounded sand. SAND: Brown, fine to medium grained sand with trace silt and clay. Uniform to gap graded, rounded sand.

10 – 36+ m Haunted Hills Formation

The Haunted Hills Formation was separated from the alluvium by a 2-5 m thick silty clay and clay layer (likely aquitard) and consisted of the following additional thickly interbedded lithologies. Clayey SAND/Sandy/Silty CLAY: Low to Medium plasticity, brown mottled grey, firm sandy clay/clayey sand with fine to medium grained sand. Uniformly to gap graded, rounded sand. Sandy GRAVEL: Non-plastic. Orange-brown to pale grey-brown, fine to coarse grained sandy gravel and cobbles with minor fine to coarse grained sand, trace silt and clay. Well graded, rounded sand and gravel. Silty CLAY: Medium plasticity, dark grey, firm. SAND: Dark grey, medium to coarse grained sand. Gap graded, sub-rounded sand. Silty SAND: Brown mottled grey-orange, fine grained silty sand with trace clay. Uniformly graded, rounded sand

+36 m Nuntin Clay (Boisdale Formation)

The Nuntin Clay Member of the Boisdale Formation was inferred to have been encountered at one location and consisted of medium to high plasticity silty clay, dark grey, firm, with trace fine grained uniformly graded, rounded sand. The Nuntin clay is known regionally as an aquitard between the Haunted Hills Formation and Wurruk Sands member.

The site lithology encountered confirms the presence of interbedded alluvial deposits (clays, silts and sands) likely associated with alluvial flood plains, palaeochannels and oxbow lakes.

Surface coverage varied across the site based on different site area uses. Leased grazing areas and open space exhibited grass surface coverage while populated areas had a combination of bitumen, concrete and crushed rock coverage.

2.3.2 Local Hydrogeology

The complexity of the geology and hydrogeology at the site controls the movement of groundwater in the area. There are three main shallower water bearing zones that were assessed as part of the DSI (Senversa, 2017a). A thick, impervious clay layer separates these three shallower units from the deep, regionally significant groundwater unit that supplies drinking water in the region.

The hydrogeological units encountered at the site during previous investigations and DSI works include the hydrogeological units in the following summary table.


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Site Lithology Encountered Summary

Hydrogeological Unit

Depth Range (m bgl)


Unit Description

Upper Alluvium Aquifer

0-6 1 – 5.5 (average: 2.8) Interbedded silt, sand and clay, with occasional gravels.

Lower Alluvium Aquifer

5-12 0.8-4.5 (average: 2.9) The Lower alluvium aquifer was separated from the Upper alluvium by a 1-2 m thick clay or silty clay unit. The Lower alluvium aquifer consisted of mainly sand with varying components of silt and clay.

Haunted Hills Formation Aquifer

10-36 1.2 - 3.9 (average: 2.4) The Haunted Hills Formation aquifer was separated from the alluvium by a 2-5 m thick silty clay and clay layer aquitard, followed by bands of silty/clayey sands and characteristic alluvial sandy gravels.

Nuntin Clay (Boisdale Formation)

>36 (extent of investigation

Groundwater not encountered in this unit at the limit of investigation.

This unit, the upper aquitard unit of the Boisdale formation, consisted of silty clay with trace fine grained sand.

Groundwater flow direction in each of the three water bearing units encountered at the site is generally towards the southeast, consistent with the local topography.

2.4 Impacts to Groundwater and Surface Water

2.4.1 Potential PFAS Source Areas

From approximately 2004, Defence commenced phasing out of legacy AFFF (generally 3M lightwater AFFF formulation) across the Defence Estate, and therefore this primary source of impacts is no longer used at the site. However, the impacted environmental media at the site is providing an ongoing (secondary) source of PFAS impacts. Newer AFFF formulations (such as Ansulite) not containing PFOS, PFHxS and PFOA, but still containing PFAS, continue to be used on Defence Bases for emergency situations, however, their use is managed and PFAS from this source is less likely to enter the environment into the future.

A number of source areas where legacy AFFF was used and introduced into the environment were identified during the PSI (Senversa, 2016). Based on a review of previous environmental assessments and the site history, several key areas have been identified as the potential primary sources of PFAS resulting from the historical on-site storage, use and disposal of legacy AFFFs.

The key potential source areas identified on site are described as follows and presented on Figure 2:

Generally, the most significant source areas (‘Group 1 Source Areas’) that represent a high risk of impact to environmental media at the site and surrounds were locations where there was repeated application of foams and concentrate to the ground during the course of fire fighting training, and other supporting activities such as infrastructure maintenance and testing, or storage of AFFF. These include the following key areas:

• Northwest area – fire truck maintenance areas, AFFF storage, fuelling area (Source IDs 01, 02 and 03), former fire station (Source ID 04) and chemical storage area (Source ID 05).

• Central/eastern area –current fire station (Source ID 06).

• Southern area – former fire training grounds (Source ID 08 and 09) and waste burial areas (Source ID 07)

• Central area – AFFF foam and equipment testing (Source Area 11)


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Other source areas identified that represent a high to medium risk of impact to environmental media at the site and surrounds, where legacy AFFF concentrate and/or foam was regularly used or stored, but with less frequent rates of application (‘Group 2 Source Areas’) than the above sources, or the site surface water bodies and drains where AFFF is likely to have migrated from source areas following use.

Other source areas that have a lower risk of potential impact to the environment (Group 3 and Group 4 Source Areas) were identified, however, were not established to be significant areas of potential risk within the DSI and HHERA.

Further to on-site sources of PFAS, a number of sources of PFAS were identified in the area given the Latrobe and Thomson river catchments are within an industrialised catchment. These included power stations up-gradient in the Latrobe Valley and a fire training facility in West sale. Other off-site sources with potential to act as a source of PFAS impacts to the Latrobe River, wetlands to the south of the Latrobe River and Lake Wellington potentially include (but are unlikely to be restricted to) Esso’s Longford Plant, the Dutson Downs Weapons Range, Dutson Downs Treatment Plant (and associated open outfall drain, which accepted waste water from Latrobe Valley power stations, Australian Paper Mills and Rosedale tannery, and discharge outlet to Lake Coleman) and Dutson Downs and Longford Landfills. Low concentrations of PFAS were also recorded in soils on private properties surrounding the Base, with the presence of some PFAS compounds not seen on Base, which suggests a potential for agricultural products such as herbicides and fertilisers to be providing a diffuse source of PFAS in the area.

The DSI confirmed the coincident nature of identified impacts with the source area findings of the PSI, indicating legacy AFFF was widely used across many parts of the site, with higher PFAS concentrations recorded near the following sources:

• Maintenance and testing areas in the northwest.

• The former and current fire stations.

• The former fire training areas in the southeast.

• The former AFFF testing areas and sewage treatment plant/current fir training area.

The DSI also identified impacts surrounding the grassed areas near the runway (to the west of the control tower) to be a more significant source than assessed in the PSI. Further, groundwater quality immediately down gradient of the former refuelling area within the AIR5428 construction area reported elevated PFAS suggesting a further source nearby.

2.4.2 Groundwater Results

• On-site, PFOS concentrations have been reported above the limit of reporting in the majority of on-site groundwater monitoring wells. The highest concentrations were reported in shallow groundwater in or near identified on-site source areas. Whilst the reported concentrations in some locations are well above the recreational screening criteria adopted in the DSI (Senversa, 2017a), shallow groundwater is not extracted or used at the site. Further to this:

Detectable PFAS has not been found in the deep aquifer Base supply groundwater extraction bore.

Exposure to impacted groundwater is unlikely other than for intrusive maintenance workers who may incidentally contact groundwater during intrusive works which encounter the shallow water table. This was assessed in the HHERA to represent a low and acceptable risk (Senversa, 2017b).

• Sampling of off-site private bores during the PSI and DSI indicates PFAS migration has not occurred in the water bearing zones where these private bores are located, with no detectable PFAS reported, except for one private irrigation bore (currently not used and has not been used for drinking water purposes) where a low concentration of PFAS was recorded below the drinking water screening criteria adopted in the DSI (Senversa, 2017a). Further sampling of bore water


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from stock troughs and outdoor domestic use taps connected to a source bore to the south of the site within the Investigation Area for the HHERA did not record PFOS levels above the recreational screening criteria adopted in the DSI (Senversa, 2017a). While a single reading from the bore did detect elevated PFOS levels, this result was not replicated in additional sampling of the bore

• Two paired off-site publicly available monitoring wells recorded detectable PFAS, at concentrations exceeding the drinking water screening criteria adopted in the DSI. The two monitoring wells in which PFAS was detected are located adjacent to the southeast corner of the site, where elevated concentrations have been reported in both soil and groundwater on-site. These sampling results indicate that PFAS migration off-site has occurred in this area.

2.4.3 Surface Water and Sediment Results

• Drainage line sampling identified detectable concentrations of PFOS and other PFAS in almost all samples. The highest concentrations were reported close to source areas (including the fire station in the central area, the maintenance and operations area in the northwest corner and the former waste burial and former fire training areas in the southeast corner). Shallow groundwater is also indicated to be discharging into the Eastern Drain and contributing to PFAS impacts within this drain.

• Reported PFAS concentrations in drainage sediments were relatively low (below soil screening levels for protection of human health in a residential setting), however the presence of detectable PFAS in most samples indicates that these have the potential to act as an ongoing source of PFAS to surface water bodies and drainage lines.

• On-site, reported PFAS concentrations in surface waters range up to approximately 100 times the primary contact recreation screening criteria adopted in the DSI to assess direct contact activities such as swimming, however the majority are less than 20-30 times this screening level. The drains are not used for recreational purposes.

• Off-site, detectable but low PFOS concentrations were reported in most surface water samples but were generally below the recreational use screening criteria adopted in the DSI to assess direct contact activities such as swimming. The detections off-site in sediment and surface water indicated the need for further evaluation of risk which was assessed in the HHERA and established a low and acceptable risk. As additional temporal data is collected during monitoring, depending on the results, this may require revision of this assessment.

• During the PSI (May 2016) and DSI (September-December 2016) sampling, some of the low-lying inundation features located to in the east and south of the site temporarily held water following rainfall events, with some areas permanently vegetated with reeds and areas appearing boggy throughout the timeframe of the DSI works. There is potential for these features to be in contact with the shallow water table during periods of elevated infiltration and recharge, however during the timeframe of the DSI, invert levels measured in these features and shallow groundwater did not indicate a direct connection. Surface water collected may have included run-off from primary source areas (such as the fire training areas), with legacy AFFF potentially concentrated there once water evaporated, potentially providing a transport pathway for PFAS to other areas of the site or surrounds, via the movement of surface water.


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2.4.4 Water Use

A local Water Use Survey completed for properties surrounding the site in the Senversa PSI (Senversa, 2016) provided the following additional information:

• Rainwater tanks provided the primary drinking water supply at all properties surveyed.

• Several registered bores were no longer in use.

• The upper groundwater aquifers are commonly extracted across properties to the north, southeast, south and west of the site for non-potable uses. Reported uses of the shallow groundwater included domestic non-potable supply (bathroom and laundry), outdoor domestic supply, dairy operations, irrigation of pasture, stock watering and abattoir operations.

• Groundwater from the deeper Boisdale Formation is extracted from multiple bores across the area investigated. Reported uses of the deep groundwater included drinking water (Supplements Base water supply), outdoor domestic supply, dairy operations, irrigation of pasture and stock watering.

• Groundwater is also regularly extracted and stored in above ground surface water bodies, termed ‘turkey’s nest’. The water is then accessed when needed for purposes such as irrigation or stock watering.

• The MID irrigation channel network was widely used by dairy farms across the north and western areas off-site, with the water generally used for flood irrigation of pasture.

Within the Management Area, the following groundwater extraction bores (no bores are used for drinking purposes) are present on private properties:

• One installed within the Lower Alluvium, 10 considered to be installed in the Haunted Hills Formation, and 2 installed within the Boisdale Formation.

• Nine are used for stockwatering.

• Six are used for irrigation (pasture), with three not currently in use.

• Five are used for outdoor domestic uses (home grown produce/gardens).

During the DSI (Senversa, 2017a) and to inform the HHERA (Senversa, 2018), a number of water supply taps, tanks, bores and stock troughs were sampled, with the results indicating:

• The on-site drinking water supply is partially sourced from the deep groundwater site extraction bore and results from on-site and off-site groundwater bore sampling of this groundwater unit established that detectable PFAS were not present.

• Private property water tank samples were targeted to properties located near to the site boundary and results established that detectable PFAS are not present in the private drinking water supply on these properties.

• Stock troughs located within the site leased grazing area are supplied by water from the on-site water supply and were sampled at four locations. The results established that PFAS does not exceed the adopted stock watering (drinking water) screening criteria adopted in the DSI.

• As indicated above, PFAS was generally not recorded in off-site private extraction bores, with the exception of bores present to the south of the Base, which recorded low concentrations (with one higher concentration not replicated in further sampling).

Ongoing Monitoring Program

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3.0 Ongoing Monitoring Program

3.1 Sampling and Analysis Quality Plan

To ensure the accuracy of sampling results, a Sampling and Analysis Quality Plan (SAQP) should be developed and implemented for the ongoing monitoring. This document should be reviewed prior to the commencement of each monitoring event to ensure currency and incorporate any updates to this OMP in line with Section 1.6. The SAQP should comply with the following guidelines:

• PFAS NEMP (HEPA, 2018).

• NEPC, 2013. National Environment Protection (Assessment of Site Contamination) Amendment Measure 2013 (No. 1), Canberra, National Environment Protection Council (NEPM)

• Environment Protection Authority (EPA) Victoria’s Industrial Waste Resource Guidelines (IWRG) Sampling and Analysis of Waters, Wastewaters, Soils and Wastes, Publication 701.

The objective of the SAQP is to outline the monitoring locations, data quality assurance procedures and justify sampling methods and procedures to be used during the monitoring events based on the technologies available at the time of monitoring.

Further guidance on elements to be included in the SAQP and suggested monitoring methodologies are included in Appendix A.

3.2 Groundwater Monitoring

3.2.1 Monitoring Network

The groundwater monitoring well network is illustrated on Figure 3 for on-site and Figure 4 for off-site. There is a total of 101 monitoring wells on- and off-site, and 13 off-site point of use sample locations (taps or stock troughs from extraction bores) within the monitoring area. This monitoring well network is summarised in the following table. Only a sub-set of these wells have been selected for regular on-going monitoring, as discussed in Section 3.2.

Formation Approximate depth Wells Screened in Aquifer

(m bgl) Onsite Offsite

Alluvium Aquifer shallow well 0 - 10 77 3

intermediate well 7 5

Haunted Hills Aquifer 5 - 30 3 5

Boisdale Aquifer 30 - 100 0 1

Groundwater monitoring well construction details are provided in Appendix B. They illustrate details relevant to sampling including the depth and screened interval for each well.

During monitoring events, the condition of the monitoring well network should be recorded to assess any changes that may impact integrity (requiring repair or replacement), and therefore data accuracy. Where a monitoring well has been damaged or destroyed during base operations or redevelopment, then its location within the monitoring well network should be reviewed in the monitoring round reporting with a recommendation for substitution with an existing well in the vicinity, or replacement of the monitoring well in the network. Where a well is to be decommissioned because it is no longer


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required as part of the network or has been partially destroyed, then the recommendation for this should be provided in the monitoring round reporting.

Monitoring bores located off-site on public and private properties require owner/tenant/land manager permission to be obtained by Defence prior to entering those properties. Where a property owner no longer grants access for sampling, then a suitable alternative (same aquifer, if available) on a nearby property should be recommended in an update to the SAQP.

3.2.2 Water Level Gauging

Gauging of the depth to groundwater in all monitoring wells (point of use bores unable to be gauged) proposed to be sampled will be undertaken in one round prior to each sampling event commencing. The objective is to confirm earlier findings that groundwater migrates south to southeast from the site, and to confirm seasonal variability, especially in interactions with site drainage or for off-site migration potential.

3.2.3 Sampling Locations and Frequency

Groundwater samples will be collected from selected monitoring wells at the frequency outlined in the following Table. The proposed sample locations for the initial 12 months of OMP implementation are shown on Figure 3 for on-site and Figure 4 for off-site.

Frequency Groundwater Wells

On-site Off-site Justification

Once every 3 months (March, June, September, December)

Shallow Upper Alluvium Aquifer: FF-MW1, MW201S, MW202S, MW203, MW607, MW612, MW616, MW622, MW624, MW625, MW627, MW628, MW702, MW706A, MW707, MW708, MW709, MW711, MW712, MW713, MW714, MW715, MW716, MW719, MW720, MW725, MW726, MW727A, MW730, MW733, MW734, MW735, MW738 Lower Alluvium Aquifer: MW701, MW704, MW737, MW739, MW740, MW741, MW201D, MW202D Haunted Hills Formation Aquifer: MW705, MW729

Shallow Upper Alluvium Aquifer: OMW001, OMW004, OMW015 Lower Alluvium Aquifer: OMW002, OMW005, OMW008, OMW016 Haunted Hills Aquifer: OMW003, OMW006, OMW009, OMW010, Point of Use Sampling Locations: P003-OEW002, P003-OEW004, P003-OEW005, P003-OEW006

Monitoring wells are located on boundaries, or adjacent to potential drainage discharge, and provide an indication of off-site migration concentrations. The shorter time interval (relative to additional on-site wells below) provides an ability to respond should significant migration potential be identified. Includes deeper groundwater wells to assess the potential for vertical migration as well as lateral migration. Off-site monitoring wells provide an indication of extent of potential migration from site. Off-site point of use locations are the nearest extraction bores to the downgradient boundaries within the Monitoring Area.

Once every 6 months (end of winter - September, end of summer - March)

Shallow Upper Alluvium Aquifer: MW603, MW609, MW610, MW615, MW617, MW618, MW619, MW620, MW623, MW626, MW629, MW638, MW703, MW718, MW721, MW722, MW724, MW728

Boisdale Formation: OMW014 Point of Use Sampling Locations: P001-OEW001, P004-OEW003, P011-OEW001, P028-OWE001

Select wells within key source areas that provide extent understanding within existing monitoring network. Off-site point of use locations are the nearest extraction bores to the downgradient boundaries within the Monitoring Area, but are within deeper formations and not expected to be impacted in these areas. Groundwater flow velocity suggests migration is to likely be at a low rate, with migration within site boundaries assessed to be contributing low risk to receptors.


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This schedule may be revised following completion of sampling events conducted in accordance with this OMP and review of the results after the initial 12 month implementation period. For example, if PFAS concentrations do not change significantly across the network due to temporal variation, then a reduced frequency of annual monitoring may be suggested. However, where PFAS are detected in wells where not previously detected, then ongoing quarterly monitoring of those locations and/or surrounding locations may be recommended.

3.3 Surface Water and Sediment Monitoring

3.3.1 Water Level Monitoring

Surface water elevation at key monitoring points within the Eastern Main Drain should be established during the sampling rounds. Surveyed monitoring points will be required to be set up within the drain to record elevations during sampling events. The objective is to confirm earlier findings that shallow groundwater may be discharging into the drain at points along the Eastern Main Drain, and the drain may be losing water to groundwater along other sections.

Surface water elevation data for the Latrobe River and The Heart Morass can be obtained from West Gippsland Catchment Management Authority (WGCMA).

3.3.2 Sampling Locations and Frequency

Surface water and sediment samples will be collected from selected sample locations at the frequency outlined in the following table. The proposed sample locations for the initial 12 months of OMP implementation are shown on Figure 5 for on-site and Figure 6 for off-site.

Frequency Sample Locations

Onsite Offsite Justification

Surface Water – Once every 3 months (March, June, September, December)

SW201, SW203, SW206, SW208, SW209, SW216, SW217, SW222, SW223, SW224, SW226, SW227, SW228, SW230, SW231, SW232, SW233, SW235, SW237, SW238, SW239, SW242, SW246, SW247, SW248, SW249, SW250, SW251, SW252, SW256, SW257, SW258, SW259, SW260

Drainage Outlet: OSW001, OSW002, OSW033 The Heart Morass: OSW004, OSW010, OSW011, OSW014, OSW015, OSW016, OSW019, OSW030, OSW031, OSW032, OSW034, OSW035, OSW041, OSW044, OSW049, OSW052, OSW082, OSW088, OSW089, OSW092 Latrobe River: OSW012, OSW080, OSW093 Flooding Creek: OSW077

Quarterly monitoring to be completed at end of season conditions including higher flow (end of winter) and lower flow (end of summer), to establish seasonal concentration trends. Select on-site locations that target key source area contributions to drainage system and spatial extent, or recorded high concentrations in previous sampling. Off-site locations target the key sampling locations within The Heart Morass where surface water concentrations were established to provide the most information regarding potential risk. Locations within the Latrobe River located to assess wider catchment contribution upgradient, contribution for The Heart Morass mid interval where the main drain alignment discharges, and downgradient after the last interaction from The Heart Morass with the River. Flooding Creek location to assess contribution from wider catchment source with high concentration identified in previous monitoring.


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Frequency Sample Locations

Sediment – Once every 3 months (March, June, September, December)

SD201, SD206, SD208, SD209, SD216, SD217, SD223, SD226, SD227, SD230, SD231, SD233, SD239, SD242, SD246, SD247, SD251, SD256, SD257, SD258, SD259, SD260

Northern Drainage Outlet: OSD049 Eastern Main Drainage Outlet: OSD001, OSD002, OSD033 The Heart Morass: OSD004, OSD010, OSD011, OSD014, OSD015, OSD016, OSD019, OSD030, OSD031, OSD032, OSD034, OSD035, OSD041, OSD052, OSD082, OSD088, OSD089

Assess potential for sediment concentrations to change seasonally, and assess changes in distributions depending on seasonal flows both on-site and off-site. Select on-site locations that target key source area contribution to drainage system, or recorded high concentrations in previous sampling. Off-site locations target contributions from drainage discharge into The Heart Morass, with highest concentrations in previous round principally within the main body of The Heart Morass reducing radially from the outlet drain discharge.

The sampling of surface water and sediment should be undertaken at the same time period as groundwater sampling, where possible, so that concentrations at the point in time can be compared to each other to assess the potential for groundwater discharge into the surface water system seasonally. Consideration should be given to the water levels and environmental flows released into The Heart Morass when monitoring to understand a range of seasonal scenarios that may impact concentrations within The Heart Morass, and therefore determine ongoing monitoring periods. WGCMA manage flows into The Heart Morass and should be contacted when planning sampling rounds to assess likely conditions at the time of sampling, as the flow releases are dependent on climatic conditions for the year. Details of the potential environmental watering of the lower Latrobe wetlands is provided in Section 2 of the Victorian Environmental Water Holder Seasonal Watering Plan 2018-19 (VEWH, 2018).

This schedule may be revised following completion of sampling events conducted in accordance with this OMP and review of the results after the initial 12 month implementation period.

It is noted that some locations may not have sufficient water to sample during dry periods of the year. Where that is the case the condition of the location will be recorded. In order to obtain samples during wet periods the timing of monitoring may be adjusted or complemented by additional sampling events (where not already being undertaken as part of feasibility studies/monitoring during implementation of the PMAP) for locations that are generally dry, with consideration also given to sampling after flood or heavy rainfall events, which may mobilise impacts generated from overland flow from source areas. The planned response to high flow events should be detailed within the SAQP for the ongoing monitoring.

3.4 Sample Analysis

A NATA (National Association of Testing Authorities) accredited laboratory for PFAS analysis should be used for the monitoring rounds. Consideration should be given to consistency of primary and secondary laboratories between previous and future sampling rounds.

Groundwater monitoring well samples, including quality control samples, should be analysed for the extended suite of PFAS analysis, anions, cations, and total organic carbon (TOC). Point of use groundwater samples should be analysed for the limited suite of PFAS analysis (including PFOS, PFHxS and PFOA). Standard limits of reporting are to be 0.002-0.01 µg/L ensuring that screening criteria to be adopted for groundwater are achieved, where possible.

Surface water samples, including quality control samples, should be analysed for the extended suite of PFAS analysis. Standard limits of reporting are to be 0.002-0.01 µg/L ensuring that screening criteria to be adopted for surface water are achieved, where possible.


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Sediment samples, including quality control samples, should be analysed for the extended suite of PFAS analysis, pH and total organic carbon. Standard limits of reporting are to be 0.0005-0.005 mg/kg for sediment ensuring that screening criteria to be adopted for sediment are achieved, where possible.

A NATA (National Association of Testing Authorities) accredited laboratory for PFAS analysis should be used for the monitoring rounds. Consideration should be given to consistency of primary and secondary laboratories between previous and future sampling rounds.

The list of PFAS generally included in the extended suite are outlined below:

• Perfluorobutane sulfonic acid (PFBS) • Perfluoropentane sulfonic acid (PFPeS) • Perfluorohexane sulfonic acid (PFHxS) • Perfluoroheptane sulfonic acid (PFHpS) • Perfluorooctane sulfonic acid (PFOS) • Perfluorodecane sulfonic acid (PFDS) • Perfluorobutanoic acid (PFBA) • Perfluoropentanoic acid (PFPeA) • Perfluorohexanoic acid (PFHxA) • Perfluoroheptanoic acid (PFHpA) • Perfluorooctanoic acid (PFOA) • Perfluorononanoic acid (PFNA) • Perfluorodecanoic acid (PFDA) • Perfluoroundecanoic acid (PFUnDA) • Perfluorododecanoic acid (PFDoDA) • Perfluorotridecanoic acid (PFTrDA) • Perfluorotetradecanoic acid (PFTeDA)

• Perfluorooctane sulfonamide (FOSA) • N-Methyl perfluorooctane sulphonamide

(MeFOSA) • N-Ethyl perfluorooctane sulfonamide

(EtFOSA) • N-Methyl perfluorooctane

sulfonamidoethanol (MeFOSE) • N-Ethyl perfluorooctane

sulfonamidoethanol (EtFOSE) • N-Methyl perfluorooctane

sulfonamidoacetic acid (MeFOSAA) • N-Ethyl perfluorooctane sulfonamidoacetic

acid (EtFOSAA) • 4:2 Fluorotelomer sulfonic acid (4:2 FTS) • 6:2 Fluorotelomer sulfonic acid (6:2 FTS) • 8:2 Fluorotelomer sulfonic acid (8:2 FTS) • 10:2 Fluorotelomer sulfonic acid (10:2

FTS)

3.5 Data Quality Objectives

The data quality objective process is a systematic planning approach outlined in the NEPM (2013) that is used to define the purpose of the investigation to be undertaken and the type, quantity and quality of data needed to inform decisions relating to the assessment of site contamination. Proposed DQOs for the ongoing monitoring are outlined in the table below.

DQO Seven-step Process

1. State the problem. Elevated concentrations of PFAS have been reported in surface water, sediment and groundwater migrating from site towards The Heart Morass. These elevated concentrations are not considered to pose a significant risk to human health from recreational direct contact, however are contributing to a potentially elevated risk for ecosystem receptors and the consumption of ducks or fish by humans. Further, the concentration trends in surface water, sediment and groundwater are not well understood based on the available monitoring data.

2. Identify the decision/goal of the study. The goal is to monitor the nature and extent of PFAS impacts, and identify trends and changes to PFAS impacts in the environment on and off-site that may alter the understanding or assessment of identified risks into the future.


m11818_332_appf_rev2 - omp 19

DQO Seven-step Process

3. Identify the information inputs. The primary inputs are considered to be: • PFAS concentrations in groundwater, surface water and sediment.

• Groundwater standing water level (SWL) which informs the inferred groundwater flow direction with in the aquifer.

4. Define the boundaries of the study. Ongoing monitoring will be undertaken at a selected number of groundwater monitoring wells, point of groundwater use and surface water locations at and surrounding the site within the Management and Monitoring Areas (shown on Figure 1).

5. Develop the analytical approach/decision rules. The data will be used in the to assess whether site-derived PFAS has changed in nature and extent which may alter the understanding or assessment of identified risks into the future to human or ecological receptors.

The useability of the data will be assessed in terms of accuracy and reliability in forming conclusions on the concentrations within the samples collected, based on guidance from the relevant sources listed above. The data quality objectives, measures and acceptance criteria to be adopted for monitoring should be outlined in the SAQP to be developed for each monitoring round.

It is required that, as a minimum, the following type and frequency of quality control samples be collected.

• Field duplicates (intra laboratory and inter laboratory) samples at a rate of at least 1 in 20 separately groundwater and surface water.

• Rinsate blanks where equipment decontamination will be necessary (e.g. groundwater sampling) at a rate of one per day per set of equipment.

As part of the reporting, the results of the monitoring should be used to assess trends using an appropriate statistical approach such as Mann-Kendall methods, or similar, to identify increases, declines or stabilisation of concentrations across monitoring rounds to a specified statistical confidence limit based on the amount of data collected over time. Some examples of the decisions to be made from investigation results include:

• If detections of PFAS are reported in field blanks or rinsate blanks, then consider if there is a potential for cross contamination between sample locations and what impact this has on conclusions of trends.

• If reported PFAS concentrations near the main drain outfall into the Heart Morass increase, then re-assess the PMAP management responses to consider management actions to reduce the volume of PFAS-impacted surface water entering The Heart Morass.

• If PFAS concentrations reported in samples collected from off-site water supply or irrigation bores increase to levels associated with potentially unacceptable risks to human health, then assess management controls regarding groundwater use in the area, and consider further risk assessment of potential exposure pathways associated with groundwater use.

6. Specify performance or acceptance criteria. Adopted screening criteria will be used to provide a screening level of results obtained during sampling, and asses if risk revision is required.

A data validation checklist with specific acceptance criteria and discussion of results must be documented and reviewed as part of the SAQP development.

At the end of the initial monitoring period, reporting should assess trends in concentrations. This should include development and use of a statistical based decision criteria to assess the significance of trends. Where significant trends are identified, the requirement for further monitoring, assessment and/or management (in the case of an increasing trend) or cessation of monitoring (in the case of a decreasing trend) will be assessed.

7. Develop the plan for obtaining data. The overarching scope and methodology is provided in this OMP. Prior to each sampling event, a SAQP should be developed which assesses the appropriateness of sample locations, sampling methodologies and risk screening/assessment criteria. The SAQP is to outline the optimum manner to collect the data required to meet the objectives for the assessment and which will meet the project DQOs.

Permission to access groundwater monitoring wells located on public and private properties is to be confirmed by Defence.

Reporting Requirements

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4.0 Reporting Requirements

4.1 PFAS Screening Criteria

PFAS screening criteria have been adopted for groundwater and surface water from the PFAS NEMP (2018). As recommended in the PFAS NEMP, criteria for protection of 99% of freshwater species are to be adopted. The adopted criteria are specified below.

Water Quality Indicator Ecological Receptors Recreational Users Drinking Water

PFOS 0.00023 µg/L NA NA

PFOS/PFHxS NA 0.7 µg/L 0.07 µg/L

PFOA 19 5.6 µg/L 0.56 µg/L

NA – Not applicable for identified receptors

4.2 Reporting of Results

After the completion of each event, the data collected should be documented in monitoring report that, as a minimum, includes the following:

• Detail of the scope of monitoring completed.

• Description of the sampling methodologies used.

• A summary of observations made while sampling (e.g. any visual or olfactory observations that may indicate impacts to surface water or groundwater).

• A summary of any changes to the monitoring network condition that may affect data integrity, or require rectification works, and recommendations for repair, replacement of decommissioning of a location.

• Presentation of the analysis results in a table that includes comparison with the following PFAS guidelines. The table should also include historical monitoring data.

• Presentation of the water level results for the monitoring period in a table, including depth from survey point and reduced level elevation. Additional information for surface water levels in the Latrobe River and The Heart Morass should be sourced from WGCMA.

• Presentation of the reduced groundwater levels for the event on a figure (three figures in total) with inferred contours and inferred groundwater flow direction.

• Discussion of the analytical data quality including review of the quality control sampling results and laboratory quality control data.

• Inclusion of the following information as attachments:

Groundwater sampling forms including field water quality parameter measurements. Chain of custody forms. Laboratory analytical certificates. Equipment calibration certificates.

• Discussion of trends in concentrations and groundwater flow direction, and use of a statistical based decision criteria (where enough data is available) to assess whether cessation of monitoring can occur or further assessment is required based on trends.

Reporting Requirements

m11818_332_appf_rev2 - omp 21

• State whether the risk profile has changed overall, or for any specific location, so that appropriate actions can be taken to manage the risk.

Should ongoing monitoring results indicate that surface water or groundwater conditions have significantly changed, qualitative assessment of the significance of these changes should be undertaken to assess whether the risk profile has changed on- or off-site and whether additional management measures, a review of the practicability of management measures, or a revision of the risk assessment is required.

Monitoring of Management Measures and Potential Risks

m11818_332_appf_rev2 - omp 22

5.0 Monitoring of Management Measures and Potential Risks

This section of the OMP details uncertainties in investigations, monitoring and management that may require consideration of contingency measures and/or reassessment of risk with changes in conditions (higher concentrations of surface water, migration of groundwater), further investigations establishing a greater extent of groundwater than identified, or implementation of management measures.

5.1 Monitoring of Management Measures

Further to the overall monitoring of PFAS nature and extent in groundwater and surface water outlined in this OMP, specific monitoring of management measures should be undertaken to assess the efficacy of implementation. Each Remediation Action Plan developed for a management option should establish the requirement of an individual ongoing management plan, which may include:

• changes in monitoring frequency utilising the existing monitoring network;

• changes to the monitoring network, e.g. through this establishment of additional monitoringlocations;

• the development of contingency measures to be implemented at specified changes in condition;

• the development of trigger points, below PFAS concentrations in the environment are assessed tohave reduced to a level where risks previously identified as elevated may have been reduced toacceptable levels, or where PFAS exposure potential in the environment has reduced to the extentwhere further risk assessment and/or cessation of continued monitoring may be warranted.

The HHERA sampling works completed for the site included baseline monitoring of off-site biota (including aquatic plants, macroinvertebrates, fish and eels) and water quality. Demonstrating that concentrations of PFAS in biota have reduced may be an important metric to understand that the potential for PFAS exposure in the environment (e.g. to ecological receptors, or to human consumers of fish) has reduced and that further monitoring and/or management is not required. As such, further consideration should be given to biota monitoring as the management measures are implemented and the monitoring outlined within this OMP demonstrates improvements in the source of impacts to biota, primarily being PFAS identified within the surface water and sediments within The Heart Morass.

5.2 Monitoring Potential Future Risks

Fluctuations in concentrations of contaminants in surface water on- or off-site, or the migration of impacts in groundwater may change the risk profile for the site.

The DSI identified potential risk sources associated with the following groundwater pathways from the CSM that require monitoring for changes that may trigger additional management or emergency response. These are generally associated with sources that have the potential to provide a risk in future should migration of impacts, or changes in off-site water use, occur.

• Shallow groundwater (Upper Alluvium) impacts migrating on-site. Groundwater impacts frominitial assessment of sources were not delineated during the DSI phase of investigation butrecorded high concentrations of PFAS in shallow groundwater. Further, source areas present inthe northwest corner and southeast corner of the site also recorded high concentrations in shallowgroundwater. In these locations, nature and extent is better understood, but not necessarilydelineated.

• Shallow groundwater (Upper Alluvium) impacts migrating off-site onto private properties. PFASpresence above adopted screening criteria is potentially migrating off-site to the south, east andsoutheast, however, the shallow groundwater is not currently extracted and used on surrounding


m11818_332_appf_rev2 - omp 23

properties. These concentrations may present a future risk to off-site users of shallow groundwater, should the nature or intensity of land use change and groundwater extraction occurs near to the site. There is also a potential that discharge of Upper Alluvium groundwater could occur to The Heart Morass to the south of the site at concentrations exceeding the adopted ecosystem screening criteria.

• Deeper groundwater (Lower Alluvial and Haunted Hills Formation) impacts migrating off-site. Lower Alluvium and Haunted Hills Formation groundwater results exceed adopted drinking water and recreational use screening criteria at monitoring wells adjacent to the former fire training area and on the boundary in the southeast of the site and have the potential to be migrating off-site in the southeastern area.

The monitoring proposed in the OMP should consider the above potential risks in the interpretation of results and periodic review of the OMP, and consider if further monitoring or investigation is required.

5.3 Further Investigation

As discussed above, the DSI and Interim HHERA have identified a number of uncertainties that do not affect current risk to receptors, but are sources of risk that should be considered for further investigation such that management controls can be implemented to protect future risk to receptors (such as definition of a groundwater quality restricted use zone, or reduction in the size of the Management Area). This mainly includes migration of shallow and deeper groundwater from the site.

Further investigations to delineate source areas or boundary conditions (investigated for the first time at the site during the DSI), should be considered as part of the overall risk management strategy for the site. Where further investigations are completed, on and off-site, then a review of this monitoring plan should be undertaken and updated where these locations are considered to require monitoring of potential risks into the future.

5.4 Revision of Risk Assessment

Revision of the risk assessment may be triggered by:

• Changes in conditions (higher concentrations in surface water, migration of groundwater)

• Further investigations establishing a greater extent of groundwater than identified, or

• Monitoring of implementation of management measures

The assessment of risk should include consideration of the source, exposure pathway and receptors relevant to the downstream environment. An outline of the elements of the risk assessment is provided below:

Source – identify the origin of the impact, the magnitude of the chemical or trend, the timeframe of the source (intermittent, repeated, seasonal).

Exposure pathway – review completeness of exposure pathway by reassessing water quality results and potentially obtaining more downstream data points.

Receptors – Assess the existing downstream users, has use of waters changed, how long is water used etc.


m11818_332_appf_rev2 - omp 24

If risk profile has been assessed to have changed, develop a response plan to enable the selection and implementation of a response or combination of measures to action in a timely manner before an imminent environmental impact to offsite surface waters or groundwater users is likely to occur. Contingency measures must be capable of meeting the following criteria:

• Be implemented in a timely manner, commensurate with the risk posed by the impact.

• Achieve a level of control that addresses the immediate risk, noting that restoration of beneficial uses is not the primary short term objective.

• Response must be easily implemented and take into account the specific logistical factors, technical and time constraints.

• The response is implemented as a short-term risk mitigation measure and is not intended to provide a long-term solution for addressing site-wide impacts.

The details of the response will be determined based upon the situation at hand.

References

m11818_332_appf_rev2 - omp 25

6.0 References

• EPA Victoria, 2000. Groundwater Sampling Guidelines, Publication 669, Environment Protection Authority Victoria, April 2000.

• EPA Victoria, 2006. Hydrogeological Assessment (Groundwater Quality) Guidelines, Publication 668, Environment Protection Authority Victoria, September 2006.

• EPA Victoria, Sampling and Analysis of Waters, Wastewaters, Soils and Wastes, Publication 701, June 2009.

• Expert Health Panel for PFAS, 2018. Expert Health Panel for PFAS Report.

• HEPA, 2017. PFAS National Environmental Management Plan released by the National Chemicals Working Group of the Heads of EPAs Australia and New Zealand (HEPA)

• NEPC, 2013. National Environment Protection (Assessment of Site Contamination) Amendment Measure 2013 (No. 1), Canberra: National Environment Protection Council.

• Senversa, 2017a. Detailed Site Investigation – RAAF Base East Sale – Per- and Poly-fluoroalkyl Substances (PFAS) Investigations, 7 June (Final – reference M11818_119_RPT_Rev4_DSI).

• Senversa, 2017b. Interim Human Health and Ecological Risk Assessment. 5 December 2017 (Final)

• USEPA, 2000. Guidance on Systematic Planning Using the Data Quality Objectives Process, EPA QA/G-4: United States Environmental Protection Agency.

• USEPA, 2002. Guidance on Environmental Data Verification and Data Validation, Washington D.C: United States Environmental Protection Agency.

• Victorian Environmental Water Holder, 2018. Seasonal Watering Plan 2018-19. http://www.vewh.vic.gov.au/watering-program/seasonal-watering-plan

http://www.vewh.vic.gov.au/watering-program/seasonal-watering-plan

Figures

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Figures Figure 1: Site Location

Figure 2: Source Areas and Migration Pathways

Figure 3: On-site Groundwater Monitoring Network

Figure 4: Off-site Groundwater Monitoring Network

Figure 5: On-site Surface Water Monitoring Network

Figure 6: Off-site Surface Water Monitoring Network




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Groundwater Gauging and Sampling Gauging Methodology

The gauging should be undertaken as follows:

• All wells to be gauged over a minimal period (one-two days, where possible and dependant on rainfall), separate and prior to any groundwater sampling that may be undertaken.

• Depth to water must be measured with an interface probe. It is not expected that light non-aqueous phase liquid (LNAPL) will be detected, but if it is its thickness must be measured and its presence confirmed using a bailer.

• Depth to base of monitoring well must be measured with an interface probe. It is not expected that dense non-aqueous phase liquid (DNAPL) will be detected, but if it is its thickness must be measured and its presence confirmed using a bailer.

• The depth to groundwater is to be measured and recorded to the nearest millimetre from the highest point or survey mark of the PVC standpipe.

• Gauging records should include the time of day and notes on the condition of the well.

• The interface probe and any parts of the measuring tape that come into contact with the water must be decontaminated between each monitoring well to avoid cross contamination.

Sampling Methodology

Groundwater sampling should be undertaken in accordance with the guidance provided in the following publications:

• EPA Victoria, Groundwater Sampling Guidelines, Publication 669, April 2000. • EPA Victoria, Hydrogeological Assessment (Groundwater Quality) Guidelines, Publication 668,

September 2006.

• IWRG 701.

• PFAS NEMP.

The general methodology is summarised as follows:

• Gauging of the water level prior to sample collection.

• Purging of groundwater until field measurements of water quality parameters has stabilised within specified limits.

• Water quality parameters (pH, electrical conductivity, redox potential, dissolved oxygen, temperature) recorded regularly during purging.

• Collection of groundwater samples into laboratory supplied vessels. If a pump is used to collect sample, a low water discharge rate is required to minimise agitation and reduce turbidity of the sample.

If groundwater yield is not sufficient to allow drawdown to be minimised in accordance with EPA guidelines (i.e. it is not possible to achieve a stabilised water level), consider a suitable alternative method to achieve a representative sample of groundwater.



Purge Water Collection and Disposal

Groundwater generated from purging groundwater wells should be collected for disposal by a licensed waste disposal contractor in accordance with regulations at the time of sampling. The water may need to be temporarily stored at the Defence site prior to collection and disposal.

Avoidance of Cross Contamination

Procedures to minimise the potential for cross contamination should be included in the SAQP and may include:

• Sampling groundwater monitoring wells in the following order:

Sampling all of the wells where PFAS impacts have not been reported first. Sampling all off-site wells where PFAS impacts have been reported second. Sampling all on-site wells where PFAS impacts have been reported third with

consideration of lowest concentrations to highest concentrations (dependant on siteaccess and logistics).

• The use of dedicated disposable sampling consumables. Disposable equipment must not bere-used between wells. The equipment used must be of a material that will not cause PFAScontamination of the water.

• Decontamination of re-usable equipment to be completed in accordance with PFAS NEMP.

• The use of dedicated disposable gloves that are replaced between purging and collection of eachsample.

Sample Handling and Transport

Samples collected must be immediately stored on ice in a chilled esky and transported under chain of custody protocols within laboratory holding times.

Surface Water and Sediment Sampling Sampling Methodology

Surface water and sediment sampling must be undertaken in accordance with the guidance provided in the following publications:

• IWRG 701.

• PFAS NEMP.

Surface water samples should be collected directly into laboratory supplied sampling containers, as per the following methodology below:

• Direct collection of surface water away from the edge of the water body and from approximately0.1 m below the water surface into a laboratory supplied bottle for PFAS analysis. The bottleopening must be pointed down to avoid the collection of surface films.

• A bottle holder with extending arm may be used where it is not possible to reach the surface waterotherwise.

• Water quality parameters (pH, electrical conductivity, redox potential, dissolved oxygen,temperature) must be recorded after sampling.



Sediment samples should be collected into laboratory supplied sampling containers, as per the following methodology below:

• Use a sediment sampler, or hand tools, to collect the top 0.1m of sediment, taking care not to disturb depositional layering of sediments.

• Collect sediments into laboratory supplied sample jars.

• Record sediment observations.

Avoidance of Cross Contamination

Procedures to minimise the potential for cross contamination should be included in the SAQP and may include:

• The use of dedicated disposable sampling consumables. Disposable equipment must not be re-used between locations. The equipment used must be of a material that will not cause PFAS contamination of the water or sediment.

• Decontamination of re-usable equipment to be completed in accordance with PFAS NEMP.

• The use of dedicated disposable gloves that are replaced between collection of each sample.

Sample Handling and Transport

Samples collected should be immediately stored on ice in a chilled esky and transported under chain of custody protocols.

Quality Assurance The data QA/QC procedures to be adopted must provide a consistent approach to evaluation of whether the data quality objectives (DQOs) required by the project have been achieved. The process focuses on assessment of the useability of the data in terms of accuracy and reliability in forming conclusions on the condition of the element of the environment being investigated.

The QA/QC approach must be based on guidance from the following sources:

• PFAS NEMP.

• Australian Standard (AS) 4482.1-2005 Guide to the investigation and sampling of sites with potentially contaminated soil, Part 1: Non-volatile and semi-volatile compounds.

• NEPM.

• United States Environmental Protection Agency - Guidance on Systematic Planning Using the Data Quality Objectives Process EPA QA/G-4.

• United States Environmental Protection Agency - Guidance on Environmental Data Verification and Data Validation EPA QA/G-8.



The data QA/QC elements are presented in the following table.

QA/QC Element Comments

Analytical Laboratories All methods to be used will be accredited by the National Association of Testing Authorities (NATA). The current primary laboratory is ALS Global, with the secondary laboratory being mgt-Eurofins.

Turnaround Times Standard laboratory turnaround times will be requested for all samples submitted for analysis.

Field record sheets Legible accurate records of all sampling locations, water quality parameters, photographic records of samples.

QA/QC Procedures The QA/QC procedures applied will include the use of equipment decontamination, Chain of Custody documentation, laboratory data verification and the use of quality control samples in accordance with Section 8.2 of AS4482.1-2005 (noting soil QC frequency is being applied to water samples). It is required that, as a minimum, the following type and frequency of quality control samples be collected.

• Field duplicates (intra laboratory and inter laboratory) samples at a rate of at least 1 in 20 separately for samples for the full range of chemicals being analysed.

• Rinsate blanks where equipment decontamination will be necessary at a rate of one per day for the full range of analytes.




Appendix B: Monitoring Well Details and Gauging Data

Ongoing Monitoring PlanRAAF Base East Sale - PFAS InvestigationsDepartment of DefenceM11818

Easting Northing Top of Casing

Existing

Surface

Casing Height Screen Interval Well Condition

(MGA) (MGA) (mAHD) (mAHD) (mBTOC) (mBGL) (m) (mBGL)

MW01 Onsite Upper Alluvium Aquifer (shallow well) SW Area - Lake Edward Area Monument 511077.28 5782230.35 6.860 6.330 7.530 7.000 0.530 4.1 - 7.1 Good

MW02 Onsite Upper Alluvium Aquifer (shallow well) SW Area - Lake Edward Area Monument 510940.53 5782288.22 6.280 6.290 2.582 2.592 -0.010 Not known Ok, slight crack in PVC



MW05 Onsite Upper Alluvium Aquifer (shallow well) SW Area - Lake Edward Area Monument 510966.18 5782419.74 9.160 8.840 8.368 8.048 0.320 5.1 - 8.1 Good, 1 bolt missing.


MW1 Onsite Upper Alluvium Aquifer (shallow well)

NW Area - MEOMS and Fuel Tank Farm Area

Flush 511421.97 5783141.19 7.000 7.080 4.823 4.903 -0.080 Not known Good



Flush 511377.89 5783162.92 6.890 6.960 4.633 4.703 -0.070 Not known Good



Stand Pipe 511381.20 5783107.09 6.920 6.910 4.754 4.744 0.010 Not known PVC pipe was bent at the top, would not be able to put a Micropurge pump down

MW201s Onsite Upper Alluvium Aquifer (shallow well)

SE Area - Fire Training and Waste Disposal

Monument 512779.63 5781903.3 5.100 5.060 5.489 5.449 0.040 2.0 - 5.0 Good

MW201d Onsite Lower Alluvium Aquifer (intermediate well)


Monument 512779.56 5781904.8 5.010 5.080 8.475 8.545 -0.070 7.0 - 8.0 Good

MW202s Onsite Upper Alluvium Aquifer (shallow well)


Monument 512770.18 5781868.28 4.790 4.670 5.201 5.081 0.120 2.0 - 5.0 Good

MW202d Onsite Lower Alluvium Aquifer (intermediate well)


Monument 512769.45 5781869.34 4.940 4.660 8.579 8.299 0.280 7.0 - 8.0 Good



Monument 512793.21 5781879.9 4.970 4.970 5.780 5.780 0.000 - Good






Flush 511101.02 5783313.50 6.720 6.720 4.806 4.806 0.000 2.0 - 5.0 Good



Flush 511109.61 5783399.84 6.660 6.650 5.760 5.750 0.010 3.0 - 6.0 Good



Flush 511057.22 5783321.9 6.480 6.510 5.373 5.403 -0.030 1.5 - 5.5 Good



Flush 511171.33 5783170.65 6.510 6.550 4.969 5.009 -0.040 1.5 - 5.5 Good



Flush 511231.54 5783170.70 6.640 6.690 4.913 4.963 -0.050 2.0 - 5.0 Good



Flush 511303.62 5783135.87 6.490 6.570 6.326 6.406 -0.080 1.5 - 6.5 Good



Flush 511316.42 5783190.29 6.520 6.570 4.710 4.760 -0.050 2.0 - 5.0 Good



Flush 511155.97 5783355 6.760 6.810 4.984 5.034 -0.050 1.5 - 5.0 Good



Monument 512486.20 5782074.52 5.740 5.220 6.350 5.830 0.520 2.7 - 5.7 Good



Monument 512527.2 5782002.1 5.890 5.360 6.425 5.895 0.530 2.7 - 5.7 Good



Monument 512754.09 5781809.30 4.980 4.460 5.759 5.239 0.520 2.5 - 5.5 Good



Flush 512883.53 5781769.43 4.770 4.370 5.949 5.549 0.400 2.5 - 5.5 Good



Monument 513002.26 5781764.32 4.390 3.950 5.975 5.535 0.440 2.5 - 5.5 Good

Monitoring Well Information Survey Data Installation Data

Well ID Target Aquifer Area Well Cover Type Total Well DepthLocation




Existing

Surface







Monument 512927.08 5782024.3 5.430 4.990 6.008 5.568 0.440 2.6 - 5.6 Good



Monument 512962.96 5781904.8 4.700 4.710 4.980 4.990 -0.010 2.8 - 5.8 Good



Monument 513066.42 5781875.50 4.890 4.380 5.290 4.780 0.510 2.2 - 5.5 Good



Monument 513052.11 5781921.56 4.850 4.420 4.915 4.485 0.430 2.5 - 5.5 Good



Monument 513123.30 5781863.96 4.910 4.370 5.842 5.302 0.540 2.4 - 5.4 Good



Monument 513189.85 5781883.4 4.700 4.130 5.812 5.242 0.570 2.5 - 5.5 Good



Monument 513028.72 5781816.3 4.540 4.050 5.100 4.610 0.490 2.0 - 5.0 Good



Monument 513149.47 5781738.44 3.500 3.010 4.701 4.211 0.490 2.0 - 5.0 Good



Monument 513088.04 5781689.74 3.280 2.880 5.948 5.548 0.400 2.5 - 5.5 Good

MW636(PC9) Onsite Upper Alluvium Aquifer (shallow well) General Area Monument 511566.35 5781821.5 5.720 4.960 6.500 5.740 0.760 - Good

MW638 Onsite Upper Alluvium Aquifer (shallow well) General Area Flush 511890.75 5783001.5 5.570 5.600 4.898 4.928 -0.030 2.0 - 5.0 Cap broken

MW701 Onsite Lower Alluvium Aquifer (intermediate well)


Monument 513061.37 5781149.45 5.48 4.72 10.56 9.80 0.760 7.5 - 10.0 Good



Monument 513167.76 5781688.35 4.18 3.49 5.05 4.36 0.690 2.0 - 5.0 Good



Monument 512733.70 5781887.70 6.27 5.46 6.2 5.39 0.810 2.5 - 5.5 Good



Monument 512833.23 5781892.88 5.93 5.16 11 10.23 0.770 7.5 - 10.5 Good

MW705 Onsite Haunted Hills Aquifer (deep well)


Monument 512830.16 5781894.72 5.68 5.13 15.3 14.75 0.550 12.5 - 15.0 Good


MW706A Onsite Upper Alluvium Aquifer (shallow well) SW Area - Lake Edward Area Monument 511562.23 5782027.05 5.92 5.36 5.040 4.48 0.560 1.8 - 4.2 Good

MW707 Onsite Upper Alluvium Aquifer (shallow well) General Area Monument 512837.57 5781171.30 5.59 4.93 6.1 5.440 0.660 3.0 - 6.0 Good



Monument 513109.66 5781434.23 6.15 5.46 6.8 6.11 0.690 3.0 - 6.0 Good



Monument 512808.42 5781757.31 4.76 4.08 5.67 4.99 0.680 2.0 - 5.0 Good



Monument 512559.94 5781886.19 5.38 4.70 5.43 4.75 0.680 2.0 - 5.0 Good



Monument 513267.69 5781773.97 4.58 3.87 5.32 4.61 0.710 2.0 - 5.0 Good






Monument 514206.25 5781628.05 3.32 2.52 6.89 6.09 0.800 3.0 - 6.0 Good




Monument 512576.90 5782128.29 6.21 5.44 6.48 5.71 0.770 2.8 - 5.8 Good


MW719 Onsite Upper Alluvium Aquifer (shallow well) General Area Flush 512459.23 5783093.51 5.22 5.28 4.89 4.950 -0.060 2.0 - 5.0 Good




Existing

Surface









Flush 511324.42 5782680.80 7.19 7.33 4.9 5.04 -0.140 2.0 - 5.0 Good



Flush 511055.89 5783116.68 6.51 6.57 4.84 4.90 -0.060 2.0 - 5.0 Good



Flush 510914.18 5782984.85 6.84 6.93 4.970 5.06 -0.090 2.0 - 5.0 Good



Flush 511106.89 5782987.74 7.02 7.13 5.95 6.06 -0.110 3.0 - 6.0 Good



Flush 511157.71 5783232.41 6.76 6.84 4.41 4.49 -0.080 1.5 - 4.5 Good



Flush 511181.57 5783134.49 6.70 6.78 3.87 3.95 -0.080 1.5 - 4.5 Good

MW727A Onsite Upper Alluvium Aquifer (shallow well)


Flush 511181.13 5783132.90 6.61 6.66 4 3.55 -0.050 1.5 - 3.5 Good



Monument 511164.08 5782955.08 6.94 7.06 6.030 6.15 -0.120 3.0 - 6.0 Good

MW729 Onsite Haunted Hills Aquifer (deep well) General Area Flush 511823.51 5782660.90 5.91 5.90 13.96 13.950 0.010 12.0 - 14.5 Good




Flush 511061.09 5783474.30 6.42 6.45 3.55 3.58 -0.030 1.0 - 4.0 Good

MW732 Onsite Upper Alluvium Aquifer (shallow well) SW Area - Lake Edward Area Flush 510949.21 5782285.63 6.24 6.36 6.94 7.06 -0.120 4.0 - 7.0 Good



Flush 510924.92 5783445.01 6.36 6.44 3 3.08 -0.080 0.8 - 3.8 Good



Monument 510888.80 5783295.18 7.29 6.59 4.15 3.45 0.700 1.0 - 4.0 Good



Monument 513057.98 5781149.90 5.43 4.69 5.58 4.84 0.740 2.0 - 5.0 Good



Flush 511157.88 5783446.32 6.57 6.54 5.82 5.79 0.030 5.0 - 6.0 Good

MW737 Onsite Haunted Hills Aquifer (deep well)


Flush 511152.05 5783442.37 6.59 6.58 15.92 15.91 0.010 15.0 - 18.0 Good




Monument 513167.49 5781682.74 4.49 3.54 9.530 8.58 0.950 5.8 - 8.8 Good



Monument 513105.77 5781435.26 6.41 5.44 11.270 10.30 0.970 7.0 - 10.0 Good



Monument 512409.88 5781237.13 5.20 4.44 11.180 10.42 0.760 7.0 - 10.0 Good

OMW001 Offsite Upper Alluvium Aquifer (shallow well) Off-site Stand Pipe 513211.03 5781757.7 3.580 3.200 4.490 4.110 0.380 Not known Good

OMW002 Offsite Lower Alluvium Aquifer (intermediate well) Off-site Stand Pipe 513211.56 5781759.7 3.460 3.180 8.300 8.020 0.280 Not known Good

OMW003 Offsite Haunted Hills Aquifer (deep well) Off-site Stand Pipe 513212.35 5781761.7 3.490 3.130 25.800 25.440 0.360 Not known Good

OMW004 Offsite Upper Alluvium Aquifer (shallow well) Off-site Stand Pipe 513124.91 5781070 4.250 4.000 5.600 5.350 0.250 Not known Good



OMW007 Offsite Upper Alluvium Aquifer (shallow well) Off-site Stand Pipe 511445.59 5780967.5 4.530 4.430 - - 0.100 Not known Poor - PVC bent, Dirt present wihtin well.


OMW009 Offsite Haunted Hills Aquifer (deep well) Off-site Monument 511446.77 5780970.1 4.830 4.460 14.070 13.700 0.370 Not known Good

OMW010 Offsite Lower Alluvium Aquifer (intermediate well) Off-site Stand Pipe 511002.03 5783849 6.200 6.200 14.600 14.600 0.000 Not known Good

OMW011 Offsite Haunted Hills Aquifer (deep well) Off-site Monument 511002.5 5783849 6.200 6.200 20.350 20.350 0.000 Not known Good

OMW012 Offsite Lower Alluvium Aquifer (intermediate well) Off-site Monument 511602.72 5783753.9 6.560 5.440 9.880 8.760 1.120 Not known Good





Existing

Surface





OMW014 ^ Offsite Boisdale Aquifer (deep well) Off-site Stand Pipe 513147.26 5781319.3 4.980 4.060 188* 0.920 Not known Good

OMW015 Offsite Upper Alluvium Aquifer (shallow well) Off-site Stand Pipe 515788.4* 5782584* Not known 1.41* Not known 5.540 Not known None N/A

OMW016 Offsite Lower Alluvium Aquifer (intermediate well) Off-site Stand Pipe 515788.4* 5782584* Not known 1.44* Not known 15.000 Not known 14.2 - 20.0* N/A

P001-OEW001 Offsite Point of Use Off-site Pump 514450.5 5782308.5 N/A N/A Not known Not known Not known Not known N/A














* Data from Visualising Victoria's Groundwater Website^ Total depth not gauged.

tel: + 61 3 9606 0070 fax: + 61 3 9606 0074 [email protected] www.senversa.com.au L6 15 William Street, Melbourne VIC 3000 Senversa Pty Ltd ABN 89 132 231 380


August 2018

APPENDIX G References

BoM, 2016. Climate statistics for Australian locations: Summary Statistics East Sale Airport. Accessed WWW: http://www.bom.gov.au/climate/averages/tables/cw_085072.shtml

CSIRO (2008). Atlas of Australian Acid Sulfate Soils, Australian Soil Resource Information System. Accessed WWW June 2016: http://www.asris.csiro.au/themes/AcidSulfateSoils.html

DEDJTR (Department of Economic Development, Jobs, Transport and Resources), 2015. Victorian Resources Online West Gippsland Region. Accessed WWW: http://vro.agriculture.vic.gov.au/dpi/vro/wgregn.nsf/pages/wg_climate

DEDJTR (Department of Economic Development, Jobs, Transport and Resources), 2016. Coastal Acid Sulfate Soil Distribution – Map 5 for the Gippsland Lakes of Victoria. Accessed WWW June 2016: http://vro.agriculture.vic.gov.au/dpi/vro/vrosite.nsf/pages/vic_acid_sulphate_map5

Department of Environment (DoE), 2016. EPBC Act Protected Matters Report, East Sale 3851. Accessed WWW: http://www.environment.gov.au/webgis-framework/apps/pmst/pmst.jsf

enHealth, 2016. enHealth Statement: Interim national guidance on human health reference values for per- and poly-fluoro-alkyl substances for use in site investigations in Australia. enHealth, Commonwealth of Australia, Canberra. June 2016.

EPA Victoria, 2017. Interim position statement on PFAS, Publication 1669.1, November 2017.

Federal Remediation Technologies Roundtable (FRTR), 2002. Remediation Technologies Screening Matrix and Reference Guide, Version 4.0 (http://www.frtr.gov/matrix2/section3/table3_2.pdf, accessed May 2018)

Food Standards Australia and New Zealand (FSANZ), 2017. Perfluorinated Chemicals in Food.

HEPA, 2018. PFAS National Environmental Management Plan, January 2018.

Interstate Technology and Regulatory Council (ITRC), 2018. Remediation Technologies and Methods for Per- and Polyfluoroalkyl Substances (PFAS), March 2018.

Leonard, J., 2003. Groundwater. Geology of Victoria Chapter 17. In: Birch WD (ed.) Geology of Victoria. Geological Society of Australia Special Publication 23. Geological Society of Australia (Victoria Division).

Senversa, 2016. Preliminary Site Investigation – RAAF Base East Sale – Per- and Poly-fluoroalkyl Substances (PFAS) Investigations, 10 October 2016 (Final – reference M11818_024_rpt_rev3_PSI).

Senversa, 2017a. Detailed Site Investigation – RAAF Base East Sale – Per- and Poly-fluoroalkyl Substances (PFAS) Investigations, 7 June 2017 (Final – reference M11818_119_rpt_rev4_DSI).

Senversa, 2017b. Interim Human Health and Ecological Risk Assessment – RAAF Base East Sale – Per- and Poly-fluoroalkyl Substances (PFAS) Investigations. 5 December 2017 (Final – reference M11818_239_rpt_rev3_HHERA)

Senversa, 2017c. Final Human Health and Ecological Risk Assessment – RAAF Base East Sale – Per- and Poly-fluoroalkyl Substances (PFAS) Investigations. 28 May 2018 (Final - reference M11818_334_rpt_rev0_HHERA)

SKM, 2001. Macalister Irrigation District Soil Permeability Map. Version 1, October 2001. Compiled from Sargeant and Imhof (2000) Major Agricultural Soils in the Maffra Region, prepared for the Victorian Resource Atlas Project by Agriculture Victoria.

SMEC, 2005. Department of Defence, RAAF Base East Sale, Stage 1 Environmental Investigation. July 2005.

http://www.bom.gov.au/climate/averages/tables/cw_085072.shtml

http://www.asris.csiro.au/themes/AcidSulfateSoils.html

http://vro.agriculture.vic.gov.au/dpi/vro/wgregn.nsf/pages/wg_climate

http://vro.agriculture.vic.gov.au/dpi/vro/vrosite.nsf/pages/vic_acid_sulphate_map5

http://www.environment.gov.au/webgis-framework/apps/pmst/pmst.jsf

http://www.frtr.gov/matrix2/section3/table3_2.pdf


August 2018

SRW (Southern Rural Water), 2009. Hydrogeological Mapping of Southern Victoria. Prepared by SKM for SRW. 14 July 2009.

SRW (Southern Rural Water), 2012. Gippsland Groundwater Atlas. October 2010.

SRW (Southern Rural Water), 2016. Macalister Irrigation District. Accessed WWW: http://www.srw.com.au/water-systems/macalister-irrigation-district/

WGCMA (West Gippsland Catchment Management Authority), 2012. West Gippsland Regional Catchment Strategy 2013-2019. Accessed WWW: http://www.wgcma.vic.gov.au/wp-content/uploads/2015/01/RCSpart1.pdf

Woodward Clyde, 2000. Phase II Environmental Impact Assessment, Fire Training Area RAAF Base East Sale, Victoria. 6 April 2000.

http://www.srw.com.au/water-systems/macalister-irrigation-district/

http://www.wgcma.vic.gov.au/wp-content/uploads/2015/01/RCSpart1.pdf

http://www.wgcma.vic.gov.au/wp-content/uploads/2015/01/RCSpart1.pdf

Documents

RAAF Base East Sale PFAS MANAGEMENT AREA …...The Defence Estate Strategy 2016-2036 and the Defence Environmental Strategy 2016-2036 each provide strategic direction for the management