DEPARTMENT OF DEFENCEENVIRONMENT AND ENGINEERING BRANCH

DIRECTORATE OF CONTAMINATION ASSESSMENT, REMEDIATION ANDMANAGEMENT

Contamination Management Manual

Annex HFire Training Areas

March 2018, Amended August 2019

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© Commonwealth of Australia 2018This work is copyright. Apart from any use as permitted under the Copyright Act1968, no part may be reproduced by any process without prior written permissionfrom the Australian Government Department of Defence.Announcement statement—may be announced to the public.Secondary release—may be released to the Australian Government Department ofDefence, its contractors and their equivalents in United States of America, Canada,New Zealand and Great Britain.All Defence information, whether classified or not, is protected from unauthoriseddisclosure under the Crimes Act 1914. Defence information may only be released inaccordance with the Defence Security Manual as appropriate.First edition 2018

SponsorDirectorate of Contamination Assessment, Remediation and Management

DeveloperEnvironment and Engineering Branch

Issued byAlison Clifton with the authority of Assistant Secretary Environment and EngineeringBranch

Effective DateMarch 2018

Amendment DateAugust 2019

Review DateAugust 2020 or when changes to processes require an update

Amendments to the document can be proposed as required. Proposals foramendment of this document are to be forwarded to:

Director of Contamination Assessment, Remediation and ManagementEmail: ncrp@defence.gov.au

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Quick Reference GuideWhy is this an issue for Defence?

Mandatory requirementsFire training areas (FTAs) are common across the Defence Estate. Types of FTAs vary greatly fromone site to another and can include current operational facilities, former or redundant FTAs or informaltraining areas where historically, potentially limited environmental management practices occurred.

The following requirements are mandatory when undertaking project works on or in the vicinity of, firetraining areas:

Undertake the Garrison Estate Management System Environmental Factor Management -Contaminated Site Record (GEMS EFM – CSR) search to access and review available data andsite history (current and former land use) during planning and site selection and prior to thecommencement of any intrusive works.

Conduct a site investigation and collect environmental samples if sufficient existing informationdoes not exist to inform the management of risks posed by potential or actual sitecontamination. Site investigations may include a Pre-construction Contamination Assessment(PCA), Stage 1 Preliminary Site Investigation (Stage 1 PSI) or Stage 2 Detailed SiteInvestigation (Stage 2 DSI).

Prepare an environmental management/remediation plan with actions identified to preventpotential ongoing contamination and off-site migration of contamination.

Document and record works and investigations, monitoring and remediation that is conducted.

Further information Defence Contamination Management Manual Defence PFAS Construction and Maintenance Framework – Guidance for managing the risks of

PFAS contamination for works on the Defence estate. Pollution Prevention Management Manual Annex 1C – Fire Fighting Foam Management Defence Environment and Sustainability Manager (ESM)

HSE Risk

Historical site activities can causecontamination. Health, safety andecological risks may arise fromcontamination, depending on thenature, extent and concentrationof the contaminant and theexposure pathways.

Commercial RiskSignificant costs may beinvolved with investigations,remediation and monitoring,and these works have thepotential to cause projectdelays.

Reputational Risk

Community concerns relatingto the potential for off-sitemigration of contaminationrepresent a reputational risk toDefence. Proactive stakeholderengagement will help minimisereputational risk.

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Table of contentsQuick Reference Guide ............................................................................................................................ ii

Abbreviations............................................................................................................................................. i

1. Introduction.....................................................................................................................................1

1.1 Background..........................................................................................................................1

1.2 Purpose................................................................................................................................2

1.3 Defence Documentation ......................................................................................................2

2. Regulatory Overview......................................................................................................................4

2.1 Overview ..............................................................................................................................4

3. Contamination risk .........................................................................................................................8

3.1 Background..........................................................................................................................8

3.2 Conceptual Site Model.........................................................................................................8

4. Projects and Contamination Management...................................................................................12

4.1 Background........................................................................................................................12

4.2 Case Studies......................................................................................................................12

4.3 Case Study 1: Redundant informal Fire Training Area......................................................13

4.4 Case Study 2: Operational Fire Training Area...................................................................14

4.5 Management ......................................................................................................................15

5. Data and Reporting ......................................................................................................................17

5.1 GEMS EFM – CSR ............................................................................................................17

5.2 Geographic Information Systems ......................................................................................17

6. References...................................................................................................................................18

Table indexTable 3-1 Phases of contamination .....................................................................................................9

Table 4-1 Management considerations..............................................................................................15

Figure indexFigure 1-1 Overview of Defence Environmental Documentation and Annex H ....................................3

Figure 3-1 Potential Contamination Risks at Fire Training Areas .......................................................11

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AbbreviationsAbbreviation Meaning

AFFF Aqueous Film Forming Foam

ATC Alcohol Type Concentrate

ASC NEPM National Environment Protection (Assessment of Site Contamination) Measure1999 (Cth) (NEPC 2013)

AST Aboveground Storage Tank

BTEX Benzene, Toluene, Ethylbenzene and Xylene

CoPC Contaminants of Potential Concern

CSM Conceptual Site Model

CSR Contaminated Sites Record

DCARM Directorate of Contamination Assessment, Remediation and Management

DEPAC Directorate of Environmental Planning, Assessment and Compliance

DEQMS Defence Estate Quality Management System

DNAPL Dense Non Aqueous Phase Liquid

DoEE Commonwealth Department of Environment and Energy

DRN Defence Restricted Network

DUXOMM Defence Unexploded Ordnance Management Manual

ECC Environmental Clearance Certificate

EO Explosive Ordnance

EPBC Act Environment Protection and Biodiversity Conservation Act 1999 (Cth)

ESM Environment and Sustainability Manager

FTAs Fire Training Areas

GEMS EFM –CSR

Garrison Estate Management System Environmental Factor Management –Contaminated Site Record

GIS Geographic Information System

LNAPL Light Non Aqueous Phase Liquid

NEPC National Environment Protection Council

NEMP National Environmental Management Plan

NEPMs National Environment Protection Measures

NSIMS National Spatial Information Management System

OMP On-going management plan

PAH Polycyclic Aromatic Hydrocarbons

PCA Pre-construction Contamination Assessment

PCB Polychlorinated Biphenyls

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Abbreviation Meaning

PFAS Per- and Poly-Fluoroalkyl Substances

PMAP PFAS Management Area Plans

PFOA Perfluorooctanoic Acid

PFOS Perfluorooctane Sulfonate

Stage 1 PSI Stage 1 Preliminary Site Investigation

Stage 2 DSI Stage 2 Detailed Site Investigation

TRH Total recoverable hydrocarbons

UST Underground Storage Tank

UXO Unexploded Ordnance

WHS Act Work Health and Safety Act 2011 (Cth)

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1. Introduction1.1 Background

Fire Training Areas (FTAs) and associated facilities form an essential part of Defenceoperations, and are a common feature on many bases across the Defence Estate. The type oftraining facility will vary greatly across the Defence Estate, and may include:

Operational facilities with highly developed systems, containment processes andmanagement protocols for contamination risks.

Operational facilities with limited systems and/or containment processes forcontamination risks.

Former (redundant) facilities where former infrastructure or burning props have beenremoved and the area left vacant (non-operational area).

Historical informal training areas where the location of the training exercise may havechanged over time, and where no formal site management occurred.

Intensive training activities can impact the environment of current or former FTAs and sopotential risks associated with contamination should be considered prior to any intrusive worksbeing conducted within these areas.

This annex provides guidance on managing the risks associated with contamination fromcurrent or historical use of FTAs. Contamination refers to existing chemical contamination ofsoil, water and sediment associated with:

Historical/past industrial or military activities and practises that have now ceased.

On-going operational activities where a recent incident (e.g. spill or leak) has resulted incontamination, but operations at the area, or in the facility, is continuing.

The management measures used to address both historical and recent contamination arecommon, however, the timeframe by which the measures are implemented may differdepending on the degree of risk posed by the contamination to human health and theenvironment.

1.1.1 Per- and Poly-Fluoroalkyl Substances

The range of potential contamination issues that may be associated with FTAs, includescontamination caused by the application of aqueous film forming foams (AFFF) containing Per-and Poly-Fluoroalkyl Substances (PFAS).

AFFF is a fire-fighting foam that has been used extensively worldwide, and within Australia,from about the 1970s by both civilian and military authorities due to its effectiveness inextinguishing liquid fuel fires. Certain formulations of AFFF contain PFAS, that are now knownto be persistent in the environment. The use of AFFF may have caused PFAS contamination ofsoil, groundwater, sediments, surface water and infrastructure.

Defence is delivering a national program to understand the presence and extent, and managethe impacts of PFAS across the estate.

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The National PFAS Investigation and Management program has conducted programs of worksto assess soil, sediment, surface water and groundwater at specific locations on and off base forthe presence of PFAS. At sites with an identified history of AFFF use or storage the programincludes:

Review of historical use, storage and management of AFFF.

Identifying pathways and receptors for potential migration of PFAS.

Community and stakeholder engagement.

Human health and ecological risk assessment to inform any future actions that may berequired to mitigate risks.

Development of PFAS Management Area Plans (PMAP), providing a roadmap forresponse management by Defence of potential risks arising from PFAS contamination.

Implementation of an on-going monitoring plan (OMP) to provide information on changesin PFAS contamination originating from the Base and to inform risk managementdecisions by Defence and State /Territory agencies.

For specific information relating to the assessment and management of PFAS impacts,reference must be made to:

Defence PFAS Investigation and Management Branch (PFASIMB)

Defence PFAS Construction and Maintenance Framework

Defence Estate Quality Management System (DEQMS).

1.2 Purpose

This guidance on FTAs will assist Defence personnel and contractors to supervise Defenceworks that may encounter contamination at these locations.

This guidance relates strictly to existing contamination issues. For planning and installation ofnew FTAs, or management of existing FTAs to prevent contamination, reference should bemade to the Pollution Prevention Management Manual Annex 1C - Fire Fighting FoamManagement

For information relating to the management of PFAS contaminated infrastructure and/ orconcrete, the user is directed to Defence Guidance document on Defence PFAS Constructionand Maintenance Framework.

1.3 Defence Documentation

This guidance document is an Annex to the Defence Contamination Management Manual andsupports compliance with site contamination management policy as detailed in the DefenceEnvironment and Heritage Manual. An overview of where this Annex fits into the Manual ispresented in Figure 1-1.

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Figure 1-1 Overview of Defence Environmental Documentation and Annex H

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2. Regulatory Overview2.1 Overview

Defence and its contractors must operate to comply with all Commonwealth legislation,including the Work Health Safety (WHS) Act, Environmental Protection and BiodiversityConservation (EPBC) Act and the National Environment Protection Measures (NEPM).Reference can be made to the Defence Legal Obligations and Compliance Register (LOCR)found on DEQMS.

Defence may not be subject to State and Territory law in all situations. Whether or not Defenceis bound by State and Territory law is a complex issue and legal advice must be obtained toconfirm whether a particular State or Territory law is applicable to Defence. Defencecontractors must comply with relevant State or Territory laws.

Guidance relating to the assessment of site contamination is outlined in the NationalEnvironment Protection Council (NEPC) 1999 (Cth), National Environment Protection(Assessment of Site Contamination) Measure (NEPM) as amended in May 2013.

2.1.1 NEPM

The National Environment Protection (Assessment of Site Contamination) Measures 1999 (Cth)(the ASC NEPM) was made under the National Environment Protection Council Act 1994 (Cth).The ASC NEPM is the national guidance document for the assessment of site contamination inAustralia. It is given effect by the National Environment Protection Measures (Implementation)Act 1998 (Cth) for the Commonwealth and individual legislation and guidelines in each Stateand Territory.

The National Environment Protection Council (NEPC) agreed to vary the NEPM by approvingan amending instrument to the ASC NEPM in 2013.

All assessments of site contamination on the Defence Estate are to be undertaken inaccordance with the recommended process and guidance provided in the ASC NEPM.

The purpose of the ASC NEPM is to establish a nationally consistent approach for theassessment of site contamination; to ensure sound environmental management practices by thecommunity, including regulators, site assessors, site contamination consultants, environmentalauditors, landowners, developers and industry parties.

The desired outcome of the ASC NEPM is to provide adequate protection of human health andthe environment, where contamination has occurred, through the development of an efficientand effective national approach to the assessment of site contamination.

The ASC NEPM and schedules are available for download through the NEPC website. TheASC NEPM Toolbox contains additional information including calculators, spreadsheets andother supporting documents to assist with application of the amended ASC NEPM.

2.1.2 PFAS National Environmental Management Plan

The PFAS National Environmental Management Plan (NEMP) provides a practical, risk-basedframework for the environmental regulation of PFAS-contaminated materials and sites. ThePFAS NEMP has been developed collaboratively by the Heads of EPAs Australia and NewZealand, and the Commonwealth Department of Environment and Energy (DoEE), and hasbeen endorsed by the Commonwealth Government.

Reference must be made to Defence PFASIMB guidance documentation available on DEQMSto ensure current PFAS policy and procedures are adopted at the time of works.

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2.1.3 Environment and Heritage Manual

The Environment and Heritage Manual (EHM) (2019) describes the agreed approach toenabling Defence capability through long-term sustainable management of the environment.The EHM provides instruction and policy guidance for all Defence personnel and contractors onDefence’s legislative obligations and stewardship goals in line with the Defence EnvironmentalPolicy and Environmental Strategy 2016-2036.

The Defence Environment and Heritage Manual is an administrative policy framework documentthat applies to all Defence personnel.

The EHM is divided into 13 chapters addressing:

Chapter 1 – Environment and heritage management in Defence

Chapter 2 – Environmental assessment and approval

Chapter 3 – Heritage management

Chapter 4 – Domestic biosecurity

Chapter 5 – Native species and communities

Chapter 6 – Soil management;

Chapter 7 – Bushfire management

Chapter 8 – Pollution prevention

Chapter 9 – Site contamination management

Chapter 10 – Estate water management

Chapter 11 – Estate energy management

Chapter 12 – Waste minimisation and management

Chapter 13 – Estate climate adaptation

Each chapter links back to a Strategic Aim of the Defence Environmental Policy and providessupporting documentation to support the implementation of the policy. Chapter 9 addresses sitecontamination management.

2.1.4 Commonwealth Work Health and Safety Act 2011

The Work Health and Safety Act 2011 (Cth) commenced in 2012 and is regulated by Comcare,a Commonwealth Government agency that works in partnership with the Safety, Rehabilitationand Compensation Commission. The WHS Act provides for a nationally consistent framework toprotect workers and other persons against harm to their health and safety through theelimination or minimisation of the risks so far as reasonably practicable.

Under the WHS Act, employers must take all reasonably practicable steps to protect the healthand safety at work of its employees and those who are at or in the vicinity of a workplace underthe employer's control. This means that Defence and its contractors have obligations to protectthe health and safety of workers and others operating within the vicinity of contaminated landthat is on or near to a workplace under Defence control.

Model Codes of Practice administered by Safe Work Australia provide practical guides toeliminate and minimise the risks to health and safety as required under the WHS Act.

Any controls outlined in the Defence Health and Safety Manual (SafetyMan) must beimplemented when managing contaminated materials.

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2.1.5 Environment Protection and Biodiversity Conservation Act 1999 (Cth)

The Environment Protection and Biodiversity Conservation Act 1999 (Cth) (EPBC Act) is theAustralian Government’s central piece of environmental legislation. It provides a legalframework to protect and manage matters of national environmental significance.

The EPBC Act protects:

The environment, where actions proposed are on, or will affect Commonwealth landand the environment; and

The environment, anywhere globally on land and water, where a Commonwealthagency – including the Department of Defence – are proposing to take an action.

The EBPC Act also protects nine matters of national environmental significance:

World heritage properties

National heritage places

Wetlands of international importance (Ramsar wetlands)

Listed threatened species and communities

Listed migratory species

Commonwealth marine areas

The Great Barrier Reef Marine Park

Nuclear actions (including uranium mining)

A water resource in relation to coal seam gas development and large coal miningdevelopment.

Defence uses a comprehensive environmental impact assessment and approval program tounderstand and manage the impacts of its activities on the environment and heritage, and toensure compliance with the EPBC Act.

Under the Defence Environment and Heritage Manual, the Director of Environmental Planning,Assessment and Compliance (DEPAC) is the Defence technical authority for determiningcompliance with the EPBC Act. All matters that may trigger the EPBC Act are to be referred toDEPAC.

DEPAC undertakes a self-assessment against the Significant Impact Guidelines 1.1 and 1.2published by the Department of the Environment and Energy to determine if a ‘significantimpact’ EPBC Act protected matter is likely. The self-assessment process considers the natureand extent of contamination and if the presence, disturbance, removal or remediation of existingcontamination is likely to have a significant impact on EPBC Act protected matters. Where asignificant impact to the environment is ‘likely’ the action must be referred to the Minister for theEnvironment and Energy to make a determination on whether a proposed action is a ‘controlledaction’.

For more information with regard to the EPBC Act refer to http://www.environment.gov.au/epbc/.

2.1.6 Off-site migration

The Defence Project Manager should obtain professional advice to inform the reporting andmanagement of any contamination that is found to have migrated off-site into a State/Territoryjurisdiction.

Delineating the nature and extent of the off-site contamination will assist Defence to implementappropriate mitigation measures and to manage any legal implications. A link to the variousState and Territory environmental agencies can be found in the Defence Environmental

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Strategy, Defence Contamination Management Manual. Any interaction with State or Territoryenvironmental regulators must only occur in consultation with DCARM, and, in the case of siteswith evidence of PFAS contamination, with PFASIM Branch.

Sites that are the subject of a current or previous PFAS investigations must only undertake anyengagement with the State or Territory regulator in accordance with the agreed stakeholderengagement strategy for that site.

2.1.7 Defence Legal Obligations and Compliance Register

Defence and its contractors must operate to comply with all Commonwealth legislation,including the WHS Act, EPBC Act and the NEPM. In addition, Defence and its contractorsshould be generally familiar with the legislative and other regulatory requirements associatedwith the site activities undertaken relevant to the State or Territory in which the site is located.Contractors must comply with State and Territory laws where applicable. Reference can bemade to the Defence Legal Obligations and Compliance Register (LOCR) found on DEQMS.

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3. Contamination risk3.1 Background

FTAs are used to develop firefighting skills. The layout and infrastructure associated with FTAsvaries across the Defence Estate; however, key features typically present may include some, orall, of the following:

Flammable liquid and gases/fuel storage and distribution areas.

Water distribution, sewers and other utilities.

Water filtration, reclamation features, retention basins.

Hazardous materials (e.g. accelerants) storage areas.

Fire training props (e.g. old aircraft or vehicle bodies).

Pits or bunded areas for training use or testing of equipment.

Underground Storage Tank (UST) or Aboveground Storage Tank (AST), for the storageof petroleum products used in training activities.

▲Example fire training prop ▲Example fire pit ▲Example operational FTA

FTAs pose an environmental risk where there is potential for contamination of soil, stormwaterand groundwater to migrate, via erosion, runoff or groundwater flow, and impact theenvironment on and/or off-site. Concrete and other FTA infrastructure may also becomecontaminated.

Additional contamination risks will exist if on-site storage of petroleum and other hazardouschemicals in USTs or ASTs are present. For specific guidance relating to underground andaboveground fuel storage, reference is made to:

Defence PFAS Investigation Management Branch (PFASIMB)

DCMM Annex E Defence Fuel Installations

PPMM Annex 1D Fuel and Chemical Storage and Handling.

3.2 Conceptual Site Model

A Conceptual Site Model (CSM) describes the contamination sources, pathways and receptorsand the potential linkages between these.

The initial CSM is constructed from the results of a Stage 1 Preliminary Site Investigation(Stage 1 PSI) and is the basis for defining where potential source-pathway-receptor linkagesmay exist, which require further investigation. The CSM must be continually reviewed andupdated throughout the assessment process to inform subsequent decisions on whether furtherinvestigation or contamination management actions are required.

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The CSM should identify complete and potential pathways between known or potentialcontamination sources and receptors. Where the pathway between a source and a receptor isincomplete, the exposure to chemical substances via that pathway cannot occur, but thepotential for that pathway to be completed (for example, by abstraction of groundwater or achange in land use) should be considered in all stages of assessment. The CSM can also beused to consider where management measures would reduce the likelihood of an exposurepathway becoming complete.

The essential elements of a CSM are:

Known and potential sources of contamination and contaminants of concern including themechanism(s) of contamination (e.g. ‘top down’ spill or sub-surface release from corrodedtank or pipe).

Potentially affected media (e.g. soil, sediment, groundwater, indoor and ambient air).

Human and ecological receptors.

Potential and complete exposure pathways.

For contaminated land site investigation reports (e.g. Stage 2 Detailed Site Investigation (Stage2 DSI)) the CSM is to be presented as a graphic, a table or flow chart and adequately describedin written text.

Table 3-1 Phases of contamination

Phase Description

Non Aqueous PhaseLiquid (DNAPL)

Liquid that is more dense than water and does not dissolve inwater.

Light Non AqueousPhase Liquid (LNAPL)

Liquid that is lighter than water and has limited solubility inwater.

Adsorbed Some of the DNAPL and LNAPL attached to the soil particlesas it moves through the soil profile from the fire pits.

Dissolved A relatively small proportion of DNAPL and LNAPL hasdissolved in groundwater and moves with groundwater flow.

Vapour Vapours which may accumulate in the soil profile anddischarge at the ground surface.

Airborne Contaminants may be airborne, and available for inhalation,including asbestos fibres, contaminants attached to dustparticles and dissolved in aerosol (e.g. water spray).

3.2.1 Contaminants of potential concern

AFFF products used at FTAs on the Defence estate may have contained PFAS. PFAScompounds are highly mobile and persistent in the environment.

Historical use of petroleum oil and lubricant waste, halogenated and non-halogenated solventsand fuels as fire training accelerants can cause contamination.

Polycyclic aromatic hydrocarbons (PAH) and dioxins/furans can be generated from the burningof polychlorinated biphenyls (PCBs), waste fuels and other organochlorine chemicals duringtraining exercises.

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Reduced dissolved oxygen and rapid eutrophication occurs when AFFF or Alcohol TypeConcentrate (ATC) is released to surface waters, impacting nutrient loads and resultant waterquality.

As a result, Contaminants of Potential Concern (CoPC) that are relevant to works in and aroundFTAs include:

PFAS

Heavy metals (notably lead)

Total recoverable hydrocarbons (TRH)

Benzene, toluene, ethylbenzene and xylene (BTEX)

PAH

Phenols

PCBs

Dioxins

Volatile organic compounds

4-methyl-2-pentanone

2-hexanone

2-butanone

ATC

The potential presence of unexploded ordnance (UXO) or explosive ordnance (EO) should beassessed. Where the potential presence of UXO or EO exists, reference should be made to theDraft Defence Unexploded Ordnance Management Manual (DUXOMM).

3.2.2 Graphical conceptual site model

A visual representation of a CSM relating to FTAs and the potential contamination sources,pathways and receptors is presented in Figure 3-1. It is noted that different contaminants in aplume will migrate a different rates.

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Figure 3-1 Potential Contamination Risks at Fire Training Areas

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4. Projects and ContaminationManagement4.1 Background

When conducting works or planning a redevelopment of a current or former FTA the Defenceproject manager should consider a number of key features of the training facility including, butnot limited to:

Facility age and design – The age of the facility may influence the extent and magnitude ofcontamination present. Historic areas may not have been built to today’s standards and withlimited or no environmental controls in place they will present a higher potential forcontamination, particularly where they have been in operation for an extended period.

Frequency of use – The current and historical use of the facility would influence the amount ofaccelerant stored and applied to the FTA. Frequently used training areas are expected to havehigher concentrations of contaminants compared to those that have been used sporadicallyover a similar period.

Location – If the location of the training area has varied over time, contaminants may be spreadover a greater area, increasing the extent of potential contamination. The proximity to surfacewater or other sensitive receptors may also influence contaminant migration pathways.

Wastewater collection system – The extent of contamination in wastewater generated fromfire training activities varies depending on the number of cycles of waste water use that areperformed. Wastewater management and disposal practices vary on a site-by-site basisdepending on the infrastructure at the FTA. Some FTAs have been designed to adequatelycollect and contain waste water and the potential for associated contamination is likely to belower. Planning for on-site treatment or management of FTA wastewater must consider thepotential presence of AFFF residues, as well as flammable or combustible hydrocarbons inwastewater and associated infrastructure. For operational management practices specific toPFAS impacted wastewater, the user is directed to Defence Guidance available in the PollutionPrevention Management Manual Annex 1C – Fire Fighting Foam Management

Depth to groundwater – The depth to the water table influences the potential for contaminantsto migrate from the FTA. The closer the water table is to the ground surface, the higher the riskthat groundwater quality will be impacted by the leaching of contaminants from the soil. It is alsoimportant to understand groundwater quality and beneficial use of groundwater, both on-siteand for the surrounding area.

4.2 Case Studies

The following case studies highlight the contamination risks related to FTAs and identifymanagement measures and sources of further information to support Defence project managersto address these contamination issues. These case studies are hypothetical examples only.

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4.3 Case Study 1: Redundant informal Fire Training Area

4.3.1 Scenario

A vacant, heavily vegetated area of land on an operational Defencefacility is the selected location for a new Defence workshop. However,during intrusive site works to level the site, and install undergroundinfrastructure for utilities, a strong hydrocarbon odour was noticed inthe shallow soils.

Anecdotal evidence and discussions with on-site personnel suggestedthat the site was used historically for fire training activities. A review ofhistorical aerial photographs identified cleared areas of land with novegetation growth. A further desktop review of Defence documentsalso revealed photographs of the area in use for fire training exercises.

4.3.2 Risks

HSE Risk – Site activities may commence in areas of contaminatedmedia without appropriate site assessment to characterise anddelineate the contamination. This could potentially resulted in theexposure of Defence personnel or contractors to site contamination.Commercial Risk – Significant unplanned costs may be incurred forinvestigations, remediation and monitoring, and these works have thepotential to present delays to the project.Reputational Risk – Proactive stakeholder engagement can reducethe legal and reputational risks associated with the off-site migration ofcontamination.

4.3.3 Key considerations and management measures

Completion of appropriate documentation includingEnvironmental Incident form to report the unexpected find andpreparation of Environmental Clearance Certificate (ECC) priorto any further intrusive site investigations.

Review the Garrison Estate Management System EnvironmentalFactor Management – Contaminated Site Record (GEMS EFM –CSR) to access and review available data and site historyinformation (current and former land use).

If existing information is not available, the physical setting of thesite must be characterised via a site investigation and thecollection of environmental samples (as required). Siteinvestigations may include a Pre-construction ContaminationAssessment (PCA), Stage 1 PSI or Stage 2 DSI and mustconsider the potential for off-site migration of contamination viasurface water run off or groundwater.

Prepare an environmental management/remediation plan with actions identified toprevent potential ongoing contamination and off-site migration of contamination.

Document and record works and investigations, monitoring and remediation that isconducted.

4.3.4 More information

Defence Environment and Sustainability Manager (ESM) Defence PFAS Construction and Maintenance Framework DCMM Annex C – Stockpiles and Reuse of Excavated Materials Pollution Prevention Management Manual Annex 1C – Fire Fighting Foam Management

Why is this an issue?A lack of understanding ofthe nature and extent ofpotential contaminationassociated with redundantFTAs may result in theexposure of Defencepersonnel or contractors tosite contamination. The riskof potential ongoing off-sitemigration may causegreater risks of health orenvironmental impacts off-site, and risk Defence’sreputation.

How can I manage it?Review the GEMS EFM –CSR for availableinformation and data.Undertake a siteinvestigation (PCA, Stage 1PSI, Stage 2 DSI) to fill thedata gap (if required).Undertake the above duringplanning and site selectionand prior to thecommencement of anyintrusive works.

Further information? PFASIMB Defence ESM PFAS Guidelines DCMM Annex C

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4.4 Case Study 2: Operational Fire Training Area

4.4.1 Scenario

Upgrade of underground stormwater infrastructure located adjacent to anoperational fire training area will require soil excavation.

No previous investigation works have occurred for the training area andthe extent of potential contamination is unknown.

4.4.2 Risks

HSE Risk – Site activities may commence in contaminated areas withoutappropriate site assessment to characterise and delineate thecontamination. This could potentially result in the exposure of Defencepersonnel or contractors to site contamination.

Commercial Risk – Significant unplanned costs may be incurred forinvestigations, remediation and monitoring or waste disposal of excessmaterials, and these works have the potential to present delays to theproject.

4.4.3 Key considerations and management measures

Review the GEMS EFM – CSR to access and review availabledata and site history information (current and former land use).

If existing information is not available, the physical setting of thesite must be characterised via a site investigation and thecollection of environmental samples (as required). Siteinvestigations may include a PCA, Stage 1 PSI or Stage 2 DSI.

Thorough and timely planning is essential to minimise disruption tothe operational facility.

Prevent potential ongoing contamination and further off-site migration of contamination,and establish procedures for the remediation or management of contamination; tominimise any unacceptable risks of potential exposure to contamination. This processmust include a stop work procedure where risks to human health or the environment areidentified.

Consideration of pollution prevention requirements for new stormwater systems andassociated design upgrade requirements.

Document and record works and investigations, monitoring and remediation that areconducted.

4.4.4 More information

Defence ESM

Defence PFAS Construction and Maintenance Framework

DCMM Annex C Stockpiles

Pollution Prevention Management Manual Annex 1C – Fire Fighting Foam Management

Why is this an issue?Intrusive works or siteredevelopment in areaswhere there is inadequateunderstanding of historicalcontaminant sources canresult in risks to Defencepersonnel and contractorsand potential delays toproject works.

How can I manage it?Characterisation of thearea to understand risksassociated with CoPC.Manage excavated soils inaccordance with relevantprocedures and guidelines

Further information? PFASIMB Defence ESM PFAS Guidelines Stockpile Guidelines PPMM – Fire Fighting

Foam Management

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4.5 Management

A staged approach may be required to understand, characterise and to manage the potential forcontamination at legacy fire training areas and surrounding land.

Each stage of works should be considered as a discrete task, and hold points arerecommended at the completion of each stage to consider whether progression to the nextstage is required.

A Stage 1 PSI and/or Stage 2 DSI may already have been completed for many legacy firetraining areas across the estate, and pollution prevention or contamination managementmeasures may be in place. For these sites, a review of existing reports, data and documentationthat may be available on the GEMS EFM – CSR must be undertaken as a priority before worksproceed.

A summary of some of the key items to be considered is provided in Error! Reference sourcenot found.. Stages should be completed as necessary to ensure the risk of contamination ismanaged.

Table 4-1 Management considerations

Stage of works Summary of points for consideration Next steps

Pre-constructionContaminationAssessment (PCA)

Review of the GEMS EFM – CSR. Limited soil sampling in the footprint of the

construction area. If groundwater isshallow and construction will requiredewatering consider collection ofgroundwater samples also.

Analysis of samples for the CoPC,including those discussed in SectionError! Reference source not found..

A PCA is suitable forconstruction projects wherespoil, and / or waste water,needs to be characterised forre-use, temporary stockpilingor for off-site disposal.Obtain approval fromDefence (reuse) or regulator(off-site disposal) based onthe data and any relevantECC conditions.

Stage 1:Preliminary SiteInvestigation

Establish historical use of the area througha desktop review and interviews withpersons familiar with historic legacy wastesites use.

Understand the physical setting of the site(including soils, hydrogeology andhydrology).

Document all works undertaken. Risk assessment based on the

Contamination Risk Assessment Tool(CRAT).

The findings of the Stage 1PSI should be communicatedto the Defence ProjectManager for the decision toproceed to the Stage 2 DSI.An ECC may be required.

Stage 2:Detailed SiteInvestigation

Investigation of potentially contaminatedmedia (including soils, sediments,groundwater, and surface water), withsufficient samples collected tounderstand the nature and extent ofcontamination.

Sampling for explosive residues must beconsistent with guidance documentation asdiscussed in Section Error! Referencesource not found., and with ASC NEPMand Australian Standards for other CoPCs.

Geophysical investigation techniques arerecommended in areas where burials orUXO1 may be present.

The scope of works for siteinvestigations and findings ofthe DSI should be discussedwith, and communicated tothe ESM for longer termmanagement of the site.An ECC may be required.

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Stage of works Summary of points for consideration Next steps Develop a CSM to assess the risk to

receptors under the existing land use, andany proposed redevelopment includedduring site works.

Document all works undertaken. Update to CRAT.

Stages 3 – 5:

RemediationPlanning,Implementationand SiteManagement

Undertake risk assessment or remediationoptions analysis and design, as required,to define further remediation ormanagement.

Establish procedures for the remediationor management of contamination tominimise any unacceptable risks ofpotential exposure to contamination. Thisprocess must include a stop workprocedure.

Allow for uncertainty by developingcontingency procedures.

Implement and manage the works inaccordance with the establishedprocedures.

Document works undertaken, includingvalidation of any remedial works.

Site management options and/ormonitoring requirements to be establishedpost completion of necessary assessment.

An ECC may be required.

Decommissioning Consideration must be given tocontamination residues on infrastructure.eg PFAS or PCBs in concrete

Prior to demolition works, an assessmentof the contamination status ofinfrastructure surfaces must be undertakenso that disposal or recycling options forbuilding materials can be determined.

An ECC may be required.

Note:1 Assessment methods and technologies for UXO are beyond the scope of this document, and reference must be madeto the Draft Defence UXO Management Manual (DUXOMM), where this type of assessment is required.

All spoil material generated from excavations at FTAs must adhere to the DCMM Annex C.

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5. Data and Reporting5.1 GEMS EFM – CSR

Data and reports generated as part of the investigation and assessment of contamination mustbe captured in the GEMS EFM – CSR.

The GEMS EFM – CSR is the database used to capture environmental information across theDefence estate, and provides access to historical contamination investigation reports forDefence properties. Contaminated site records are geo-referenced and they can be accessedby Defence personnel or contractors with Defence Restricted Network (DRN) Access.

Contractors/Consultants working on behalf of Defence must provide reports, updated andcompleted GEMS Data Load (GDL) Tool (for new or existing CSR’s), CRAT, ESdat and(Geographic Information System) GIS files relating to contamination to their Defence point ofcontact, Project Manager or ESM who will be responsible for auditing and validatingsubmissions and ensuring the upload of information into the GEMS EFM – CSR.

Refer to the Defence Environmental Strategy, Defence Contamination Management Manual,Annex L – Data Management.

5.2 Geographic Information Systems

All mapping GIS data is required to be provided to Defence in National Spatial InformationManagement System (NSIMS) metadata format. The Defence NSIMS metadata tool is availablethrough an online search and on DEQMS.

Refer to the Defence Environmental Strategy, Defence Contamination Management Manual,Annex L – Data Management.

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6. ReferencesNEPC 2013, National Environment Protection (Assessment of Site Contamination) Measure1999 (Cth) (as amended in 2013), NEPC.

NEPC National Environment Protection (National Pollutant Inventory) Measure, 1998 (Cth).

DCMM Annex K Management of PFAS Contamination.

DCMM Annex C Management of Stockpiles and Re-use of Excavated Material.

Defence Pollution Prevention Management Manual and Annexes

Annex 1A - Acid Sulfate Soils Management

Annex 1B - Copper Chrome Arsenate Treated Timber

Annex 1C - Fire Fighting Foam Management

Annex 1D - Fuel and Chemical Storage and Handling

Annex 1E - Liquid Waste Storage and Handling

Annex 1F - Maintenance and Cleaning Activities

Annex 1G - Open Burning Grounds and Incineration

Annex 1H - Solid Waste Storage and Handling

Annex 1I - Stormwater Management

Annex 1J – Wastewater Treatment Plants

Annex 1K - Heavy Metals on Live Firing Ranges

Annex 1L – Routine Water Quality Monitoring

http://www.defence.gov.au/estatemanagement/Governance/Policy/Environment/Pollution/implementation.asp.