Defence’s National PFAS Investigation and Management Program has been established to manage, contain and remediate the effects of per-and poly-fluoroalkyl substances (PFAS) contamination in and around a number of its properties. It has its origins in reviews looking into where and how firefighting foam was historically used, to identify the properties most likely to be impacted by legacy PFAS contamination.
Defence has now completed detailed site investigations for PFAS contamination both in and around 19 of 28 Defence properties. Where those investigations have been finalised, Defence is actively working to manage and remediate identified environmental contamination risks.
The precautionary principle has been key to Defence’s approach to the management of PFAS risks. While there are uncertainties around the behaviours and impacts of PFAS, there is sufficient knowledge to apply the precautionary principle.
Interim response actions
Before the completion of environmental investigations, and usually before a complete understanding of the findings of an investigation are available, Defence, in accordance with the precautionary principle, puts in place a number of interim response actions in and around various Defence properties to address specific risks or break potential exposure pathways. These actions can include the provision of alternative water supplies to affected residents and communities; the implementation of groundwater and surface water treatment technologies; drain maintenance
activities; and management of PFAS source areas consistent with relevant state and territory regulations.
Provision of alternative drinking water
Health authorities advise that exposure to PFAS can occur from contaminated food, water (groundwater and surface water) and various consumer products. Defence identified that some residents surrounding a number of Defence properties were, or may have been, ingesting groundwater containing PFAS. Where PFAS-contaminated groundwater was the residents’ primary source of drinking water, Defence provided an alternative supply of drinking water (initially bottled water). Defence has provided alternative drinking water to residents in communities
surrounding RAAF Base Williamtown, RAAF Base Tindal, RAAF Base Pearce and the Army Aviation Centre Oakey.
The following assistance has also been provided:
- In Williamtown, Defence has funded Hunter Water Corporation to connect 342 properties around RAAF BaseWilliamtown to town water.
- In Oakey, Defence has funded the Toowoomba Regional Council to connect 36 properties around the Army Aviation Centre Oakey to town water.
- In Katherine, Defence worked with local providers to install rainwater tanks and other infrastructure including plumbing and guttering at 67 properties around RAAF Base Tindal.
- In Katherine, Defence worked with the Northern Territory Power and Water Corporation (NT PWC) to install and operate an interim groundwater PFAS treatment system at the town water treatment facility to meet current town water demand. In 2019, Defence also provided $21 million to NT PWC for the purchase, installation and initial operational support of a permanent groundwater PFAS treatment system which is large enough to meet the forecast future demand for town water.
- In Bullsbrook, Defence continues to provide 26 residents who have had PFAS detected in their groundwater bores with bottled water until a sustainable long-term solution is found.
Groundwater treatment systems
In a similar application of the precautionary principle, before investigations were finalised, Defence installed water treatment plants to treat high-concentration sources at RAAF Base Williamtown, RAAF Base Tindal, RAAF Base Edinburgh and the Army Aviation Centre Oakey.
As at June 2020, 4.6 billion litres of water has been treated through the PFAS water treatment plants currently in operation across the Defence estate. These plants are commissioned to remove the three primary PFAS chemicals of concern—perfluoro-octane sulfonate (PFOS), perfluoro-octanoic acid (PFOA) and perfluoro-hexanoic acid (PFHxS)—to below drinking water guidance values, in accordance with environmental discharge requirements of relevant states or territories. In most cases they have achieved removal to below the limit for reporting.
As part of its response, Defence will assess the contribution existing groundwater water treatment plants make to the reduction of PFAS contamination, or the migration of PFAS contamination, at the relevant source area or site.
PFAS Management Area Plan and Ongoing Monitoring Program
Responding to PFAS contamination requires an effective, evidence-based and nationally consistent response. Each Defence site where an investigation has been concluded has a PFAS Management Area Plan (PMAP), which is specific to the conditions at each site and is based on the findings of the investigation. PMAPs recommend remediation actions and related studies at the site to monitor, manage and reduce the risks of PFAS exposure and mitigate the migration of PFAS through groundwater and surface water flows from specific on-base source areas to locations beyond the site. At the completion of planned remedial works, Defence will seek to determine whether minimisation of PFAS migration from a source area has been achieved ‘so far as reasonably practicable’.
As part of each PMAP, Defence is also implementing an Ongoing Monitoring Program to monitor and track PFAS contamination at Defence properties over the coming years. The Ongoing Monitoring Program provides an evidence base for the continuing management of PFAS contamination. It will assist Defence to evaluate the progress and success of remediation activities and to identify where more might need to be done. PMAPs will be reviewed annually or as new technology becomes available, and an annual Ongoing Monitoring Program Interpretive Report
will be published.
Defence’s strategy for responding to PFAS contamination is adaptive and recognises the evolving nature of scientific knowledge, technological advances in PFAS treatment, and the need for flexibility. Responses generally involve one or more of the following three principal components:
- source management—by removal, destruction, treatment, disposal and/or other methods, leading to the source no longer being present or the risk being reduced to accepted levels
- pathway management—by capping, containing, stabilising, diverting and/or other methods
- receptor management—by using point-of-use technology (e.g. filters); providing alternative essential services (e.g. drinking water); providing public information and behaviour advisories (e.g. limits on dietary intake); and/ or other methods focused on people, livestock and other environmental receptors.
Using the knowledge and experience gained in recent years, including information about the distribution, concentration and migration of PFAS and exposure pathways at each site, Defence is now focusing on reducing and/or removing high-concentration soils in source areas which leach contamination into surface water and groundwater. Primary remediation options include soil excavation and disposal at appropriately licensed offsite facilities; stabilisation or immobilisation to lock contamination in place; and capping to prevent infiltration of water which would enable leaching of contamination into groundwater or surface water sources.
The range of treatment and technology options that are commercially available to treat PFAS contamination is limited. Commercially proven soil treatment technologies are more limited than water treatment technologies. Issues of scale, efficiency, effectiveness and financial sustainability remain important considerations. Defence continues to support PFAS technology research and development validation, engaging with national and international partners to discuss issues of mutual interest including developments in investigations, remediation and management, and
specific technical issues.
As of 30 June 2020, Defence has independently funded 11 research activities valued at approximately $6.8 million. Most relate to trials for remedial technologies for soil, groundwater and concrete. Additional research has supplemented site-specific Human Health and/or Ecological Risk Assessments, including a PFAS plant uptake study (in fruit and vegetables) and a study to evaluate PFAS transfer from chickens to their eggs as a result of drinking PFAS-contaminated water.
In addition to funding a research grants program administered by the Australian Research Council, in 2018 Defence contracted the Commonwealth Scientific and Industrial Research Organisation (CSIRO) to consider a number of critical questions for the management of estate PFAS risks, including when pump and treat systems for contaminated groundwater should be used; when contaminated soil should be excavated and treated; and how to manage PFAS-contaminated asphalt and concrete most efficiently and effectively.
Consultation and collaboration
Defence works closely with affected communities, Commonwealth agencies, state and territory environmental and health authorities, local councils, local interest groups and businesses to be open and transparent about the progress of investigations. This consultation facilitates the sharing of sampling results and, where relevant, sharing of precautionary advice developed by state and territory authorities.
Defence aims to provide PFAS-affected communities with transparent, timely and direct communication about the release of investigation outcomes; remediation and management activities; opportunities for residents to discuss their concerns about PFAS contamination; and how residents can access further information. As of the end of June 2020, Defence has held 142 community engagement events for PFAS-affected communities. Defence has also established community information lines and a website for the National PFAS Investigation and Management
Program. The website hosts all publications released through the PFAS Investigation and Management Program, as well as site-specific answers to frequently asked questions, information on investigation areas, links to precautionary advice issued by state and territory authorities, and links to other agency websites.
Defence’s total spend on PFAS environmental investigations and remediation action for 2019–20 was approximately $80 million. Defence’s total contribution to the whole-of-government response to PFAS contamination since 2015–16 is approximately $450 million, including $45 million to other agencies for specific initiatives. This expenditure has enabled Defence to determine the nature and extent of PFAS contamination, and to work to manage and remediate contamination across the estate and in surrounding communities.
The cost of each environmental investigation is determined by the physical environment on and around the Defence property, and by the nature of the historical use of legacy firefighting foam. Remediation costs for each property depend on the scope of work and the options selected for remediation and management.