AECOM Australia Pty Ltd +61 3 9653 1234 tel Level 9 +61 3 9654 … · 2015-05-14 · AECOM...

AECOM Australia Pty Ltd

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Australia

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26 March 2015

Executive Officer Environment and Natural Resources Committee Parliament House Spring Street East Melbourne, VIC 3002

Fax No: [email protected]

Dear Committee Members

Inquiry into CFA Training College at Fiskville

1.0 Introduction

Thank you for your invitations (dated 6 February) to Darryl Strudwick and Melissa Saunders of AECOM Australia Pty Ltd (AECOM) to make a submission to the Inquiry into the CFA Training College at Fiskville. Please find our submission below, which addresses the terms of reference of the Inquiry, as stated in the letters of invitation.

2.0 Nature of Involvement and Works at the Site

In January 2013, the Environment protection Authority (EPA) issued two Clean Up Notices to CFA relating to the Fiskville Training College. The Notices require (amongst other things), by the dates specified in the Notices, CFA to:

- Engage the Services of an EPA-appointed Environmental Auditor and submit to EPA for approval the Environmental Auditor’s proposed (s53V) Environmental Audit scope;

- Submit to EPA an Environmental Audit Report by an EPA-appointed Environmental Auditor, prepared in accordance with section 53V of the Act and consistent with the approved Environmental Audit scope;

- Submit to EPA a Clean Up Plan that has been verified by an EPA-appointed Environmental Auditor;

- Submit to EPA an Auditor verification report prepared by an EPA-appointed Environmental Auditor confirming the extent and quality of the implementation of the Clean Up Plan undertaken by CFA;

- Engage the Services of an EPA-appointed Environmental Auditor to complete an Environmental Audit in accordance with Section 53X of the Environment Protection Act 1970 (EP Act); and

- Submit to EPA an Environmental Audit Report prepared in accordance with section 53X of the Environment Protection Act by the EPA-appointed Environmental Auditor (including a Statement or Certificate of Environmental Audit).

AECOM was invited by CFA to prepare a proposal to provide Environmental Auditor Services at the Site as required in the Notices issued by EPA. CFA accepted AECOM’s proposal in January 2013. Darryl Strudwick of AECOM is the EPA-appointed Environmental Auditor and Melissa Saunders was until recently the Project Manager.

Key tasks that the EPA-appointed Environmental Auditor (i.e. Darryl Strudwick of AECOM) has undertaken to date are:

- Submitted to EPA for approval the proposed (s53V) Environmental Audit scope;

- Completed an Environmental Audit Report in accordance with Section 53V of the Environment Protection Act 1970, dated 11 April 2014. This report has been available on the EPA website since July 2014; and

- Verified a Clean Up Plan for the Site by completing a “Clean Up Plan Assessment Report”, dated 29 May 2014. The Clean Up Plan which was verified by the Environmental Auditor was prepared by CFA, titled Clean Up Plan, CFA Fiskville Training College, 4549 Geelong – Ballan Road, Fiskville, Victoria, dated 29 May 2014.

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3.0 Inquiry Terms of Reference

To the extent that AECOM is able to comment on the terms of reference contained in your letter, our knowledge is contained within the s53V Environmental Audit Report and Clean Up Plan Assessment Report. The s53V Environmental Audit Report is available on the EPA web-site. A copy of the Clean Up Plan Assessment Report is attached to this letter.

These reports contain information with respect to items 21, 22, 24, and 25 of your letter to Darryl Strudwick and items 26, 27, 29 and 30 of your letter to Melissa Saunders. We are unable to comment on items 23 and 28 (i.e. the role of past and present executive management at Fiskville).

For the purposes of the terms of reference, it is important to note that:

- the s53V Audit relates to contamination caused by the use of the Site as a live fire training facility, including storage of chemicals used in training, firewater capture, treatment, storage and disposal and the burial of drums and other material, including in on-Site landfills;

- The objectives of the s53V Audit are to assess the risk to beneficial uses of:

land, groundwater and surface water at and surrounding the site posed by the historical contamination of land, groundwater and surface water resulting from the use of the site as a fire training facility;

surface waters posed by the historical and on-going fire water management and treatment at the site; and

land, groundwater and surface water posed by the current storage and management of chemicals used in live fire training;

- The s53V Audit does not assess:

The risk of harm to human health associated with persons undertaking live fire training activities (either historical or current) in an occupational setting. This includes occupational exposure to fuels, foams or any other potentially harmful substance used during live fire training activities;

The risk of harm to human health to persons undertaking other training activities at the site that do not have access to live fire training areas (or areas impacted by live fire training activities) including:

Management/ Leadership/ Planning/Communication courses*

Driving courses*

Emergency rescue courses*;

The risk of harm to human health to on-site residents posed by live fire training activities that do not have access to live fire training areas (or areas impacted by live fire training activities)* ;

*Note that the risk of harm to human health to any persons on the site that have access to live fire training areas (or areas impacted by live fire training activities), is assessed in this audit. In addition, the risk posed to residents from airborne contaminated particles sourced from live fire training areas (if any) is assessed by the audit;

Risks posed to beneficial uses of land, surface water and groundwater caused by past activities at the site that do not relate to fire training use, the storage of chemicals used in training, firewater capture, treatment, storage and disposal, and the burial of drums and other material, including in on-site landfills (i.e. agricultural practices and historical occupation of the site by Amalgamated Wireless Australasia).

Risks to the air environment (and beneficial uses) potentially caused by the on-going use of the site as a fire training facility. This exclusion relates to an assessment of risk associated with air quality during live fire training events.

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4.0 Closure

Please contact us if you have any questions regarding our submission. We request that future enquiries to AECOM be directed to Darryl Strudwick.

Yours faithfully

Darryl Strudwick Melissa Saunders Technical Director Principal Environmental Scientist

Mobile: Mobile: Direct Dial: Direct Dial: Direct Fax: Direct Fax:

encl: Clean Up Plan Assessment Report, 29 May 2014

Country Fire Authority

29-May-2014

Clean Up Plan Assessment Report CFA Fiskville Training College, 4549 Geelong - Ballan Road, Fiskville, Victoria

AECOM Clean Up Plan Assessment Report

Revision – 29-May-2014 Prepared for – Country Fire Authority – ABN: 39 255 319 010

Clean Up Plan Assessment Report CFA Fiskville Training College, 4549 Geelong - Ballan Road, Fiskville, Victoria

Client: Country Fire Authority

ABN: 39 255 319 010

Prepared by

AECOM Australia Pty Ltd Level 9, 8 Exhibition Street, Melbourne VIC 3000, Australia T +61 3 9653 1234 F +61 3 9654 7117 www.aecom.com ABN 20 093 846 925

29-May-2014

Job No.: 60285333

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© AECOM Australia Pty Ltd (AECOM). All rights reserved.

AECOM has prepared this document for the sole use of the Client and for a specific purpose, each as expressly stated in the document. No other party should rely on this document without the prior written consent of AECOM. AECOM undertakes no duty, nor accepts any responsibility, to any third party who may rely upon or use this document. This document has been prepared based on the Client’s description of its requirements and AECOM’s experience, having regard to assumptions that AECOM can reasonably be expected to make in accordance with sound professional principles. AECOM may also have relied upon information provided by the Client and other third parties to prepare this document, some of which may not have been verified. Subject to the above conditions, this document may be transmitted, reproduced or disseminated only in its entirety.



Quality Information

Document Clean Up Plan Assessment Report

Ref

60285333

\\aumel1fp001\projects\60285333\6. draft docs\6.1 reports\cup\60285333_cup_assessment report_final_29may14.docx

Date 29-May-2014

Project Manager Melissa Saunders

Project Director Darryl Strudwick

Revision History

Revision Revision Date

Details Authorised

Name/Position Signature

FINAL 29-May-2014

Clean Up Plan Assessment Report

Darryl Strudwick Technical Director



Table of Contents Endorsement of Clean Up Plan i 1.0 Introduction 1 2.0 Clean Up Plan 2 3.0 Compliance of Clean Up Plan with Clean Up Notice 3

3.1 Delineation of the level, extent and quantity of any waste or contaminants 3 3.1.1 Soil 3 3.1.2 Surface Water and Sediment 3 3.1.3 Groundwater 3 3.1.4 Other 3 3.1.5 Summary of Compliance with Clean Up Notice 4

3.2 Removal of waste and removal or remediation of contaminants on and extending beyond the boundary of the premises 4 3.2.1 On-Site 4 3.2.2 Off-Site 5 3.2.3 Summary of Compliance with Clean Up Notice 5

3.3 Clean up to restore beneficial uses to segments where wastes or contaminants are identified 6 3.3.1 Land 6 3.3.2 Surface Water and Sediment 6 3.3.3 Groundwater 6 3.3.4 Summary of Compliance with Clean Up Notice 6

3.4 Details of mitigation measures and associated monitoring programs and reporting dates 7 3.4.1 Mitigation Measures 7 3.4.2 Monitoring Programs 7 3.4.3 Summary of Compliance with Clean Up Notice 7

3.5 Reduction of risk identified in the 53V environmental audit report 8 3.6 Details of clean up measures required to support the s53X audit 8 3.7 Timeframes specified in Clean Up Plan 8

4.0 Proposed Technology 9 4.1 Introduction 9 4.2 Implementation 9 4.3 Technology Background 9

4.3.1 Containment 9 4.3.2 Remediation 9

4.4 Practicality of Approach 10 4.4.1 Containment 10 4.4.2 Water Treatment 11 4.4.3 Surface Water and Sediment Remediation 12 4.4.4 Perched Water Remediation 13 4.4.5 Capping of Former Landfills 13

4.5 Timing 13 4.6 Best Practice 13 4.7 Other Considerations 14

4.7.1 Roles and Responsibilities 14 4.7.2 Impacts on Third Parties 14

5.0 Limitations or Constraints on Endorsement 15 6.0 References 16 7.0 Limitations 17



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Endorsement of Clean Up Plan Table 1 Endorsement Statement

Name of the Notice Holder Country Fire Authority

Site Location 4549 Geelong – Ballan Road, Fiskville, Victoria

Details of the Notice 90004570 and 90004571 dated 31 December 2014

Documents that constitute the Clean Up Plan

CFA (2014a) Clean Up Plan, CFA Fiskville Training College, 4549 Geelong – Ballan Road, Fiskville, Victoria, 29 May 2014 and appendices including:

- Cardno Lane Piper (2013a) Feasibility Study of Water System Upgrade, Diversion Work and Remediation, CFA Fiskville Training College, 4549 Geelong-Ballan Rd, Fiskville, Victoria, 17 December 2013 Ref: 212163.22Report01.3.

- Cardno Lane Piper (2013b)Technical Drawings for Diversion Channel Re-alignment, PAD Training Area Stormwater Diversion, Fiskville Wetland and Diversion Channel Landscaping Plan.

- Cardno Lane Piper (2014a) Investigation of Risks at Former Landfills, Fiskville Training College, 4549 Geelong-Ballan Road, Fiskville, Victoria, 21 March 2014 Ref: 212163.13Report01.5 (including Appendix J, Landfill Environmental Management Plan).

- CFA (2014b) Water Quality Management Plan, Fiskville Training College, March 2014 Ref: 212163.8Report WQMP 01.6.

Statement of the Auditor’s verification of the plan

The Auditor verifies that CFA has produced a Clean Up Plan in accordance with Clean Up Notices 90004570 and 90004571. The Auditor has reviewed this CUP (CFA, 2014a), provided comments to CFA and is satisfied that his comments have been incorporated into the final plan.

The verification of this CUP (CFA, 2014a) is subject to the limitations and constraints provided in Section 5.0 of the attached Assessment report.

Reference to the Auditor’s Assessment report

AECOM (2014) Clean Up Plan Assessment Report, CFA Fiskville Training College, 4549 Geelong – Ballan Road, Fiskville Victoria (i.e. this report)

Signed:

Darryl Strudwick,

Environmental Auditor, appointed pursuant to the Environment Protection Act 1970

AECOM Australia Pty Ltd

Date: 29 May 2014



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1.0 Introduction This Clean Up Plan (CUP) Assessment Report (report) has been prepared by Mr Darryl Strudwick (an EPA appointed Environmental Auditor - Contaminated Land) of AECOM Australia Pty Ltd (AECOM), at the request Ms Sherry Herman, Program Manager, of the Country Fire Authority (CFA).

This report relates to the CFA Fiskville Training College, located at 4549 Geelong – Ballan Road, Fiskville, Victoria (the Site). The Site location is shown on Figure 1 of the CUP (CFA, 2014a).

EPA issued two Clean Up Notices (Notices) to CFA for the Site, dated 22 January 2013. These Notices were later revoked and replaced with Notices dated 31 December 2013. Copies of the Clean Up Notices 90004570 and 90004571 (dated 31 December 2013) are attached to the CUP (CFA, 2014a) as Appendix B.

Requirement 3.1 of Notice 90004570, requires CFA to submit an Environmental Audit report, prepared in accordance with Section 53V of the Environment Protection Act (the Act) and consistent with the approved environmental audit scope, to EPA by 31 March 2014. An Environmental Audit report, dated 11 April 2014, was provided to EPA (Environmental Audit Report – Risk to Land, Surface Water and Groundwater, CFA Fiskville Training College, 4549 Geelong – Ballan Road, Fiskville, Victoria, 11 April 2014 [AECOM, 2014a]).

Requirement 3.3 of Notice 90004571, requires CFA to submit an Environmental Audit report prepared in accordance with Section 53X of the act to EPA by 30 June 2017.

Requirements 3.2 of Notice 90004570 and 3.1 of Notice 90004571, requires CFA to submit to EPA a CUP, verified by an EPA appointed Auditor, by 30 May 2014. According to the Notices, the CUP must include the following:

a) delineation of the level, extent and quantity of any waste or contaminants;

b) removal of waste and removal or remediation of contaminants on and extending beyond the boundary of the premises;

c) clean up to restore beneficial uses to segments where wastes or contaminants are identified;

d) details of mitigation measures and associated monitoring programs and reporting dates;

e)1 reduction of risk identified in the 53V environmental audit report (Notice 90004570);

e)2 details of clean up measures required to support the s 53X audit (Notice 90004571); and

f) the date(s) by which requirements a) – e) above will be completed or specified (as the case may be).

CFA provided the Auditor with a final CUP on the 29 May 2014 (CFA, 2014a). The CUP (CFA, 2014a) has been reviewed by the Auditor and forms the basis of this verification

In providing this endorsement, the Auditor has referenced the “EPA Interim advice to Environmental Auditors - Endorsement of Clean Up Plans”, which was previously provided to Auditors.

In preparing this report and concluding with respect to the endorsement of the CUP (CFA, 2014a), the Auditor has relied upon the CUP (CFA, 2014a) and the appendices attached to the CUP (CFA, 2014a) that relate to the feasibility assessment of remedial options for water and sediment, surface water and stormwater diversion / controls, remediation and on-going management of the former landfills, and on-going Site management (including monitoring). These documents are listed in the Endorsement Statement located at the front of this report.



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2.0 Clean Up Plan The CUP (CFA, 2014a) has been developed to address the requirements of Notice 90004570 and Notice 90004571. The actions to be undertaken identified in the CUP (CFA, 2014a) are grouped into six stages:

- Stage 1: Containment

- Stage 2: Site Assessment

- Stage 3: Off-Site Works

- Stage 4: Remediation

- Stage 5: Plans and Procedures

- Stage 6: Monitoring

As noted in Section 3.2 of the CUP (CFA, 2014a), these stages of work are not sequential and in many instances are to be implemented in parallel.

The recommendations of the s53 Audit report (AECOM, 2014a) and the Clean Up Notice requirements that are intended to be addressed by the CUP are identified at the beginning of the description of each stage of work.

The CUP (CFA, 2014a) presents a high level plan for further works at the site (including further assessment and remediation). The detailed assessment and documentation of specific works proposed are to be provided in documents to be provided at a later date (eg. Sampling and Analysis Plan, Remedial Action Plans, updated Water Quality Management Plan). The proposed timing of these detailed documents is provided in the CUP (CFA, 2014a). It is noted that the specific remediation options for surface water (and perched groundwater) and sediments at the site are those recommended in a feasibility assessment. These are subject to further investigation of their applicability and effectiveness and are dependent upon agreement of discharge criteria and waste classification as well as various approvals.



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3.0 Compliance of Clean Up Plan with Clean Up Notice According to the interim advice provided to Auditors, the Auditor can only verify a CUP if it includes all of the elements specified in the Notices. The following is an assessment of the CUP with respect to the elements of the Notices. It is arranged according to the Notice conditions and describes the components of the CUP that are relevant to each Notice condition, followed by a summary of compliance which contains the Auditors assessment.

3.1 Delineation of the level, extent and quantity of any waste or contaminants

Section 4.3.3 of the CUP (CFA, 2014a) outlines the methodology to be adopted for proposed further soil, surface water and sediment and groundwater assessment at the Site, which is to be documented in a Sampling and Analysis Quality Plan (SAQP) to be finalised by August 2014.

3.1.1 Soil

The scope of work for further soil assessment is described in Section 4.3 (Stage 2: Site Assessments) of the CUP (CFA, 2014a). It addresses:

- Areas of the site that have not previously been assessed,

- Data gaps identified during soil investigations to date and the s53V Audit, and

- The requirements of the s53X Audit to be completed by June 2017.

Table 4-7 of the CUP (CFA, 2014a) outlines the tasks to be undertaken to address identified data gaps and also provides reference to the proposed sampling required to address the requirements of the Section 53X Audit.

The Environmental Assessment Areas (EAAs) of the Site described in Table 4-6 of the CUP (CFA ,2014a) are shown on Figure 3 of the CUP (CFA, 2014a).

3.1.2 Surface Water and Sediment

The scope of work for further surface water and sediment assessment is described in Section 4.3 (Stage 2: Site Assessments) of the CUP (CFA, 2014a). Table 4-9 of the CUP (CFA, 2014a) outlines the proposed tasks and scope of works for surface water and Table 4-10 does the same for sediment assessment. These works are proposed to address recommendations of the s53V Report.

3.1.3 Groundwater

The scope of work for further groundwater assessment is described in Section 4.3 (Stage 2: Site Assessments) of the CUP (CFA, 2014a). The proposed tasks and scope of work for further assessment of perched water and the regional aquifer is provided in Table 4-8. Figure 4 of the CUP (CFA, 2014a) shows existing groundwater monitoring bore locations. These works are proposed to address recommendations of the s53V Report, as well as the recent identification of perched water in the vicinity of the southern end of Lake Fiskville (see Section 3 of the CUP [CFA, 2014a]).

3.1.4 Other

3.1.4.1 PAD Infrastructure

The CUP (CFA, 2014a) includes an assessment of the potential for perfluorinated compounds (PFCs) to leach from existing infrastructure associated with live fire training into stormwater and fire water run- off be undertaken.

The scope of work for the assessment of infrastructure at the Practical Area for Drills (PAD) for the presence of PFCs is provided in Table 4-11 of the CUP (CFA, 2014a). These works are proposed to address a recommendation of the s53V Audit Report (AECOM, 2014a).

3.1.4.2 Bis(2-ethylhexyl)phthalate

AECOM (2014a) noted that concentrations of Bis(2-ethylhexyl)phthalate in a small number of samples of various media (sediments, surface water and groundwater) were reported. In some cases, the reported concentrations exceed the adopted environmental quality criterion. The source of this compound and reason for its detection is unclear.



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The proposed scope of work provided in Section 4.3 (Stage 2: Site Assessments) of the CUP (CFA, 2014a) addresses this data gap by including the analysis of Bis(2-ethylhexyl)phthalate in soils, surface water, sediments, perched water and in samples collected from the regional aquifer (where encountered). The specific locations and frequency of Bis(2-ethylhexyl)phthalate analysis in further assessment will be specified in the SAQP to be prepared.

3.1.5 Summary of Compliance with Clean Up Notice

The information provided in Section 4.3 (Stage 2: Site Assessments) is considered to be in compliance with the requirements of the Notices in relation to delineation of the level, extent or quantity of any waste or contaminants.

The data gaps in Table 4-7 of the CUP (CFA, 2014a) address those identified in Sections 5, 6, 9.4 and Appendix D of the s53V Audit Report (AECOM, 2014a). The Auditor notes that the need for further assessment of dioxins and furans (in soil) is specifically highlighted in Section 9.4 of AECOM, 2014a, and should be addressed in the SAQP.

It is noted that the CUP (CFA, 2014a) provides and outline of tasks and generic scope for further investigation / delineation. Detailed scopes and methodology for specific tasks identified in Tables 4-7 to 4-11 will be documented in the SAQP for work proposed for Stage 2: Site Assessments (including soil, sediment, surface water, groundwater and PAD infrastructure sampling activities) to be finalised by August 2014. As referenced in Table 4-12 of the CUP (CFA, 2014a), this SAQP is to be provided for the Auditor for review and endorsement prior to the commencement of field activities.

The CUP (CFA, 2014a) does not specifically refer to further assessment to delineate the degree and extent of contamination that may be identified during the proposed investigations. The SAQP should consider the Notice requirement to delineate the level, extent and quantity of any waste or contamination in the case where it is not achieved during the proposed investigations.

The CUP (CFA, 2014a) notes that following the completion of further assessment as detailed in Section 3.1 of this report, there may be a need for the implementation of further remediation and/or management measures to restore beneficial uses of land, surface waters or groundwater. The Auditor notes that if additional remediation and/or management measures require implementation at the Site, an assessment of potential remediation technologies would need to be conducted and a remediation action plan (RAP) [or similar] be provided to the Auditor for review.

3.2 Removal of waste and removal or remediation of contaminants on and extending beyond the boundary of the premises

3.2.1 On-Site

Section 4.2 (Stage 1: Containment) of the CUP (CFA, 2014a) describes works associated with containing contaminated surface water on-site as follows:

- Diversion of Beremboke Creek around Lake Fiskville;

- Installation of bunds to increase the capacity of the dams and Lake Fiskville;

- Enhancing the drainage systems around the PAD so that training waste water is effectively captured and contained on-site in the dams and Lake Fiskville; and

- Establishing a wetland to filter stormwater.

Section 4.5 (Stage 4: Remediation) of the CUP (CFA, 2014a) describes works associated with remediation as follows:

- Upgrade water treatment infrastructure (water treatment, supply and storage);

- Remediate surface waters in Dams 1 – 4 and Lake Fiskville;

- Remediate perched water in scoria in proximity to the dams (Dam 1 and Dam 2) and at the southern end of Lake Fiskville;

- Remediate sediments in Dams 1 – 4 and Lake Fiskville; and

- Remediate former landfills areas at the Site.



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3.2.1.1 Surface Water and Sediment

Section 4.5.3 of the CUP (CFA, 2014a) provides an outline of the scope of work for surface water and sediment remediation activities. The options that are recommended or likely to be assessed further are discussed in Section 4.0 of this report.

3.2.1.2 Perched Water

In Section 4.5 of the CUP (CFA, 2014a), it is noted that following further assessment to delineate the extent of contaminated perched groundwater in the scoria between the dams (Dam 1 and Dam 2) and at the south end of Lake Fiskville will be subject to remediation. It is proposed that the remediation technology will be the same as for the surface water remediation. The remedial option considered by CFA to be most likely to be implemented for the remediation of contaminated water is discussed in Section 4.0 of this report.

3.2.1.3 Landfills

Section 4.5.3 of the CUP (CFA, 2014a) provides a scope of work for proposed remediation activities at former landfills LF1 and LF2. The recommended options are discussed in Section 4.0 of this report.

3.2.2 Off-Site

Based on the findings of the s53V Audit report (AECOM, 2014a), there is no requirement for the removal of waste and removal or remediation of contaminants beyond the boundary of the premises (other than the prevention of the further flow of contaminated surface water off-site).


The information provided in Sections 4.2 (Stage 1:Containment) and 4.5 (Stage 4: Remediation) is considered to be in compliance with the requirements of the Notices in relation to removal of waste and removal or remediation of contaminants on and extending beyond the boundary of the premises.

Due to the relative widespread presence of contamination (PFCs) in surface soils away from the PAD area, all works involving soil movement (eg. bunding, construction of channels, landfill capping) should include an assessment of soils for PFCs (including the potential for PFCs in soil to leach into surface water) to ensure the proposed works will not result in adverse impacts.

Based on the assessment of contamination and risk posed by the contamination identified at the site to date, as well as the preliminary assessment of proposed remedial activities, the Auditor is satisfied that remediation of impacted surface water and sediments within Dams 1 – 4 and Lake Fiskville is necessary. Further, the proposed remediation of impacted perched water in proximity to Dams 1 and 2 and at the southern extent of Lake Fiskville is considered appropriate.

As noted in Section 4.5 (Stage 4: Remediation) of the CUP (CFA, 2014a), engagement with EPA and the Auditor is required for:

- Establishment of appropriate quality criteria for the discharge of treated water to the environment; and

- Waste classification of dewatered sediment.

The Auditor notes that Section 4.5 (Stage 4: Remediation) of the CUP (CFA, 2014a) provides an outline of generic technology based on the feasibility assessment that may be implemented at the Site to remediate surface water (and perched groundwater) and sediments. The actual technology to be implemented has not as yet been confirmed and trials for effectiveness have not been undertaken. As noted in the CUP (CFA, 2014a), the design of the water treatment system will be informed by the required discharge water quality criteria. Further, CFA (2014a) notes that the waste classification of dewatered sediment will also be used to inform the treatment technology adopted to remediate dewatered sediments (including on-site containment / off-site disposal).

Specific scopes relating to the remediation of surface water (and perched groundwater) and sediments will be subject to further review, agreement on criteria (discharge to waters, waste sediments), effectiveness of pilot trials, refinement of the proposed technologies and approvals.



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3.3 Clean up to restore beneficial uses to segments where wastes or contaminants are identified

AECOM, 2014a concluded that the beneficial uses of the following segments were precluded:

- Land: Aesthetics (Former Landfills)

- Surface Water (including sediments)(On-Site): Ecological (Maintenance of Modified and Highly Modified Ecosystems)

3.3.1 Land

Section 4.5 (Stage 4: Remediation) of the CUP (CFA, 2014a) describes the proposed capping of former landfills LF1 and LF2. The proposed capping at LF1 and LF2 is considered appropriate to restore the beneficial use Aesthetics.

3.3.2 Surface Water and Sediment

Section 4.5 (Stage 4: Remediation) of the CUP (CFA, 2014a) describes measures to remediate on-Site surface water and sediments in Dams 1 – 4 and Lake Fiskville.

The remediation of surface water and sediments is considered necessary to restore the beneficial use of Ecological (Maintenance of Modified and Highly Modified Ecosystems) on-Site.

As discussed in Section 4 of this report, the technologies recommended in the feasibility assessment (Cardno Lane Piper, 2013a) are yet to be considered or tested in detail. Specific scopes relating to the remediation of surface water and sediments will be subject to further review, agreement on criteria (discharge to waters, waste sediments), effectiveness of pilot trials, refinement of the proposed technologies and approvals.

3.3.3 Groundwater

3.3.3.1 Perched Water

As described in Table 4-8 of the CUP (CFA, 2014a), further assessment of the potential for perched water to discharge to surface water (including stormwater drains) is proposed.

Section 4.5 (Stage 4: Remediation) of the CUP (CFA, 2014a) notes that perched water residing in scoria in proximity to Dams 1 and 2 and at the southern end Lake Fiskville is to be remediated at the time that the dams (1 and 2) are to be remediated. The remediation of the contaminated perched water is subject to the more detailed assessment of remedial technologies discussed in Section 4.

3.3.3.2 Regional Aquifer

Based on regional aquifer investigations completed to date, no impacts to beneficial uses of groundwater have been identified. As such, there is currently no provision in the CUP (CFA, 2014a) for works associated with regional aquifer clean up to restore beneficial uses.

However, as described in Section 4.3 (Stage 2: Site Assessments) of the CUP (CFA, 2014a), additional works are proposed to further investigate the potential for live fire training to have impacted regional groundwater. As outlined in Section 4.3.4 of the CUP (CFA, 2014a), should the results of further investigation result in the need for remediation or management, analysis of the most appropriate remediation technology would be conducted. This would allow the preparation of detailed remediation documentation (eg. RAP) for Auditor review.


The information provided in Section 4.5 (Stage 4: Remediation) is considered to be in compliance with the requirements of the Notices in relation to Clean up to restore beneficial uses to segments where wastes or contaminants are identified.

The CUP (CFA, 2014a) includes measures to clean up to restore beneficial uses to segments where wastes or contaminants are identified. As discussed in Section 4 of this report, the technologies recommended in the feasibility assessment (Cardno Lane Piper, 2013a) are yet to be considered or tested in detail. Specific scopes relating to the remediation of surface water and sediments will be subject to further review, agreement on criteria (discharge to waters, waste sediments), effectiveness of pilot trials, refinement of the proposed technologies and approvals.



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Further soil, surface water, sediment and groundwater investigations are proposed as described in Section 4.3 (Stage 2: Site Assessments) of the CUP (CFA, 2014a). The Auditor notes that based on the findings of this proposed further work, clean up measures in addition to those described by the CUP (CFA, 2014a) may be required to restore beneficial uses to segments where wastes or contaminants are identified.

3.4 Details of mitigation measures and associated monitoring programs and reporting dates

3.4.1 Mitigation Measures

Section 4.6 (Stage 5: Plans & Procedures) of the CUP (CFA, 2014a) provides a scope of work for the implementation of a number of mitigation measures as follows:

- No extractions from Lake Fiskville or Stocking of Fish;

- Independent Chemical Validation of Foam Products;

- Inclusion of information on Buried Drums in the Site Contamination Management Plan (SCMP);

- Implement Landfill Environmental Management Plan (LEMP);

- Store Chemicals, etc. on Sealed and Bunded Surface;

- Procedure for Managing Leaks/Ruptures of Fuel Pipelines;

- VUT to Manage Liquid Effluent Independently; and

- VUT Environmental Management Plan.

In addition, Section 4.4 (Stage 3: Offsite Works) of the CUP (CFA, 2014a) describes measures proposed to address Recommendation 9 of the s53V Audit Report (AECOM, 2014a). Timeframes for the implementation of plans and procedures are provided in Table 4-22 of the CUP (CFA, 2014a).

3.4.2 Monitoring Programs

Section 4.7 (Stage 6: Monitoring) of the CUP (CFA, 2014a) refers to the implementation of a water monitoring program in accordance with CFA (CFA, 2014b). The existing Water Quality Management Plan (WQMP) is to be updated to include the monitoring program and monitoring locations.

Timeframes for the implementation of monitoring programs are provided in Table 4-24 of the CUP (CFA, 2014a). It is noted that on-going surface water monitoring is proposed to commence in Q2 2014 (prior to the WQMP being updated). This is understood to be to enable monitoring of the effectiveness of the containment measures undertaken to date (i.e. Beremboke Creek diversion, bunding, stormwater diversion and wetland) in the short term.

In addition to the monitoring programs outlined in the CUP (CFA, 2014a), the Auditor notes that ongoing monitoring / management measures for the landfill capping (during and after placement) are provided in the LEMP (attached to the CUP (CFA, 2014a) as Appendix F).


The information provided in Sections 4.6 (Stage 5: Plans & Procedures) and 4.7 (Stage 6: Monitoring) is considered to be in compliance with the requirements of the Notices in relation to details of mitigation measures and associated monitoring programs and reporting dates.

The proposed mitigation measures and monitoring programs identified in the CUP (CFA, 2014a) are generally appropriate to manage risks identified by the Section 53V Audit (AECOM, 2014a). The following is noted:

- With regard to the implementation of the independent chemical validation of foam products, the Auditor notes the proposed scope of work and methodology provided in Section 4.6.3 of the CUP (CFA, 2014a). Prior to completion of the Section 53X Audit, the Auditor would need to see evidence of the implementation of procedures for the independent chemical validation of foams;

- The updated WQMP should identify monitoring locations, frequency, parameters, and specific triggers and contingencies and reporting dates.

- Stage 1: Containment includes establishment of a wetland to filter “clean” stormwater generated in the vicinity of the PAD (excluding the Flammable Liquid PAD and several other training areas specified in



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Section 4.2.3 of the CUP [CFA, 2014a]). Based on the potential storm water to have contact with contaminated soils in the PAD area, routine water quality monitoring undertaken in accordance with the WQMP should include the proposed wetland (refer Section 4.2, Stage 1: Containment [CFA, 2014a]).

- Monitoring of water levels in Lake Fiskville, trigger level, contingency of suspending live fire training should be described in detail in the WQMP (CFA, 2014b).

- The quality of water in Beremboke Creek on-site (including the diversion channel and at the downstream site boundary) should be included in the WQMP.

3.5 Reduction of risk identified in the 53V environmental audit report

The activities described in Section 4.2 (Stage 1: Containment) of the CUP (CFA, 2014a) have been completed to contain waste water generated from live fire training on-Site and to reduce the risk of off-Site flow of contaminated surface water. Further, the Auditor notes that the proposed remediation of surface water and sediments summarised in Section 4.5 (Stage 4: Remediation) of the CUP (CFA, 2014a) is likely to reduce concentrations of PFCs within Dams 1 – 4 and Lake Fiskville. The completion of works within Stage 1: Containment and Stage 4: Remediation are likely to reduce on-going ecological risks at the Site.

The proposed capping of former landfills LF1 and LF2 described in Section 4.5 (Stage 4: Remediation) is considered appropriate to reduce the potential risk of exposure to waste materials and reduce infiltration of rainfall into the waste (resulting in the generation of leachate). On-going management of the cap and former landfill areas outlined in the LEMP (Cardno Lane Piper, 2014a) is considered to be appropriate to reduce the risks identified in the s53V Audit report.

Section 4.4 (Stage 3: Offsite Works) of the CUP (CFA, 2014a) is considered appropriate to reduce the potential risk associated with the human consumption (i.e. drinking) of water sourced downstream of Lake Fiskville and Beremboke Creek (off-Site). The Auditor notes that according to Cardno Lane Piper (2014b), there is no direct evidence of water from Beremboke and Eclipse Creeks (downstream of the site) being used for drinking water. Cardno Lane Piper (2014b) understands that drinking water “would principally be sourced from rain water tanks”.

The combination of further soil, surface water, sediment and groundwater assessment, in conjunction with the proposed and/or completed containment, remediation, engineering and procedural controls included in the CUP (CFA, 2014a) are considered appropriate to reduce the risks identified in the Section 53V Audit report (AECOM, 2014a).

3.6 Details of clean up measures required to support the s53X audit

The works described by Stage 4 of the CUP (CFA, 2014a) provide details of clean up measures to support the Section 53X Audit.

The works described by Stage 2: Site Assessment will provide the information needed to determine the details of any clean up measures required to support the Section 53X Audit. The works described by Stage 5: Plans and Procedures include management measures (i.e. LEMP and SCMP) that will support the Section 53X Audit.

It is noted that pending the completion of further investigations as detailed in Section 4.3 (Stage 2: Assessments) of the CUP (CFA, 2014a), additional investigation and clean up measures may be required to support the Section 53X Audit.

3.7 Timeframes specified in Clean Up Plan

The CUP (CFA, 2014a) specifies the dates for the completion of activities as provided in the work plan tables for each stage of works and is summarised in Appendix C of the CUP (CFA, 2014a).

These timelines are predicated on requirement 3.4 of Notice 90004570 to complete clean up to treat, remove or contain all contaminated soil, waste, waters and groundwater that represents an unacceptable risk of harm to the environment. In some cases (eg. remediation of surface water, perched water and sediments), the timelines proposed in the CUP (CFA, 2014a) may be challenging (see Section 4.5). The identification of contamination in proposed investigations requiring further investigation and remediation may challenge the proposed timelines further.



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4.0 Proposed Technology

4.1 Introduction

Section 4.2 (Stage 1: Containment) and Section 4.5 (Stage 4: Remediation) of the CUP (CFA, 2014a) describes the “technologies” to be implemented at the Site. These sections of the CUP (CFA, 2014a) are supported by Cardno Lane Piper, 2013a (feasibility assessment).

4.2 Implementation

The proposed implementation schedule is provided in Appendix C of the CUP (CFA, 2014a). It is noted that works associated with Stage 1: Containment are largely complete.

4.3 Technology Background

4.3.1 Containment

Works completed as part of Stage 1: Containment include the diversion of Beremboke Creek around Lake Fiskville, upgrade of drainage systems around the PAD, bunding to increase in the capacity of Dams 1 - 4 and Lake Fiskville, establishment of a wetland to filter stormwater and blocking of drains from the VUT building. As described in Section 4.2 (Stage 1: Containment) of the CUP (CFA, 2014a), the intent of Stage 1: Containment works is to contain CFA’s training waste water on-Site and reduce the risk of it flowing off-Site. The works (already undertaken) are civil works involving design and construction / engineering solution that does not specifically remove or remediate (eg. by reducing contaminant mass) contaminants.

4.3.2 Remediation

Works to be completed as part of Stage 4: Remediation are described in Section 4.5 (Stage 4: Remediation) of the CUP (CFA, 2014a). Stage 4: Remediation includes the implementation of water treatment facilities suitable for treating waste water generated during hot fire training and the remediation of surface water and sediment in Dams 1 – 4 and Lake Fiskville. In addition, it is proposed that perched water residing in scoria in proximity to Dams 1 and 2 and at the southern end of Lake Fiskville be remediated. Stage 4: Remediation also includes the capping of former landfills LF1 and LF2.

4.3.2.1 Water Treatment

Section 4.5.3 of the CUP (CFA, 2014a) notes that CFA will implement water treatment facilities suitable for the ongoing treatment of water sourced from live fire training activities. An appraisal of possible water treatment technologies is detailed in Cardno Lane Piper (2013a).

According to the CUP (CFA, 2014a) , the most likely approach to water treatment will be a modular system comprising coagulation, flocculation and sedimentation followed by lamella plate settlers, to control pH and reduce biochemical oxygen demand (BOD) and chemical oxygen demand (COD) and suspended solids, followed by activated carbon to absorb oils and total petroleum hydrocarbons (TPH). This would be followed by Ultrafiltration (UF) and Reverse Osmosis (RO) to remove PFCs and other firefighting foam residues and disinfection (by chlorine and ultraviolet (UV) treatment) to enable recirculation and reuse.

There is currently no specific water treatment plant design identified in the CUP (CFA, 2014a). The CUP (CFA, 2014a) states that CFA will seek expressions of interest on the open market to identify and assess the full range of potential solution technologies available. Treatment trials will be conducted to prove the final technology selected effectively treats the water to a standard appropriate for discharge to the environment or for recycling and reuse. As a result, the specific remediation technology to be implemented at the Site is to be determined.

4.3.2.2 Surface Water and Sediment Remediation

Section 4.5.3 of the CUP (CFA, 2014a) notes that surface water will be remediated using the water treatment system for the live fire training activities (as described in Section 4.3.2.1of this report).

Section 4.5.3 of the CUP (CFA, 2014a) describes the recommended sediment remediation involving removal via floating dredge and subsequent dewatering using GeotubeTM containers. Following treatment, it is proposed that sediments be contained on-Site under a clay cap or Type 2 landfill cell.



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CFA notes that recommended sediment remediation techniques will require further sediment analysis and preparation of a remedial plan and Auditor approval prior to final determination. Further, the waste classification of dewatered sediments will be subject to consultation with EPA and the Auditor. This may affect the treatment requirements and selection of remedial technologies for sediment. As a result, the sediment remediation technology to be implemented at the Site is to be determined.

4.3.2.3 Perched Water Remediation

Section 4.5.3 of the CUP (CFA, 2014a) notes that perched water residing in scoria in proximity to Dams 1 and 2 and at the southern end of Lake Fiskville will be remediated using the water treatment system for the live fire training activities (described in Section 4.3.2.1 of this report).

4.3.2.4 Capping of Former Landfills

Section 4.5.3 of the CUP (CFA, 2014a) outlines the proposed capping of former landfills LF1 and LF2. The landfill capping design is detailed in Section 4.2 of the LEMP attached to the CUP (CFA, 2014a) in Appendix F. As detailed in Cardno Lane Piper (2014a), the capping of former landfills LF1 and LF2 is to be undertaken with reference to guidance in EPA Publication 788.1 (2010) Best Practise Environmental Management Siting, Design, Operation and Rehabilitation of Landfills (BPEM). Cardno Lane Piper (2014a) assessed the landfills as being a low risk rural landfill (in accordance with Section 6.12 of the BPEM). The proposed capping is consistent with a “Type 3” cap as described in Table 8-1 of the BPEM.

4.4 Practicality of Approach

In assessing the practicality of the proposed approaches to remediation described in the CUP (CFA, 2014a), the Auditor has considered the following:

- Is the approach practical?

- Is the technology proven or experimental?

- What is the likelihood of success, and are pilot studies required?

- What are the underlying principles/ theories of the technology?

- What contingencies need to be considered?

- What type of monitoring program is required?

4.4.1 Containment

While the approach to contain contaminated water on-Site has not been proven (by means of testing, modelling or monitoring), it is considered to be practical in that the designed concept physically separates the fire water management system (Dams 1 to 4 and Lake Fiskville) from Beremboke Creek enabling the creek to flow through the Site unaffected by contaminated firewater in Dams 1 to 4 and Lake Fiskville (and connecting channels).

There is however potential for contaminated soil to enter diverted water, fog spray (during live fire training) to contaminate diversion channels and for stormwater from the PAD to contain contaminants that may affect surface water quality.

The feasibility assessment (Cardno Lane Piper, 2013a) considers the diversion of stormwater from the flammable liquids PAD (FL PAD) to the wetland and Beremboke Creek. The CUP (CFA, 2014a) specifically excludes this option. The CUP (CFA, 2014a) includes measures to divert “clean” stormwater generated in the vicinity of the PAD from the fire water system (Dams 1-4 and Lake Fiskville) to a wetland before discharging to Beremboke Creek. Technical drawing C2002 shows a cut-off drain to divert high “clean” stormwater flows from the PAD area around the wetland and discharges directly to the Beremboke Creek diversion channel. There is potential for storm water to have contact with contaminated soils in the PAD area.

The effectiveness of containment measures can be assessed by regular surface water quality monitoring to determine whether surface water flowing off-Site meets the required surface water quality criteria. Off-Site monitoring locations are identified in the CUP (CFA, 2104a), these (and on-Site locations) are to be detailed in the WQMP (CFA, 2014b). Triggers and contingencies relating to water quality should be detailed in the WQMP (CFA, 2014b).



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4.4.2 Water Treatment

The Auditor has prepared the following text with advice from Mr Richard Irwin of AECOM (Technical Director - Water & Wastewater Treatment).

All of the water treatment processes considered in the CUP (CFA, 2014a) to be most likely to be implemented are proven technologies for removing impurities from wastewaters.

The initial stage of chemically enhanced primary treatment (CEPT) is a well-proven technology for removing nutrients (BOD and COD) and suspended solids from wastewaters. This is a necessary first step in the clean-up process as these constituents can cause blockages and/or excessive biofilm growth in the subsequent polishing stages. Granular activated carbon (GAC) absorption is another well-proven technology for the removal of trace organics from waste streams. However, GAC alone cannot achieve the removal of all residues to the levels likely to be required, hence the need for further treatment.

UF followed by RO is a recognised wastewater treatment process for the production of high quality recycled water for industrial reuse. The removal efficiencies of PFCs for RO membranes are typically better than 99% (laboratory trials). Recovery efficiencies for UF/RO systems are typically 70-80% and therefore there is a significant concentrated waste stream for disposal via evaporation pond(s) to a controlled landfill.

The disinfection processes proposed have been demonstrated to achieve the required water quality for re-use.

Many contaminants present in wastewater, such as suspended solids, oils, COD, etc., can interfere with the removal efficiency of PFCs. These interactions in the particular wastewater from the Site need to be tested and understood if the correct technological solution is to be selected and therefore pilot studies are considered to be essential. However, all the technologies proposed are well proven and once the appropriate combination of processes has been selected, the likelihood of success is high.

It should be noted however that the selection of appropriate technologies is dependent on the required water quality objectives for discharge to surface waters (yet to be determined).

The underlying principles of the technology are a combination of chemical treatment, gravity settlement, adsorption and molecular filtration. The first stage of chemical pre-treatment by coagulation/flocculation uses a combination of inorganic and organic chemicals to react with the dissolved organic contaminants and suspended matter in the raw wastewater to cause them to clump together to form suspended particles known collectively as floc. These floc particles are separated from the wastewater by settlement onto a series of inclined plates in a tank known as a lamella plate separator. The collected floc particles, known as sludge, settles to the bottom of the tank and is removed periodically for further treatment such drying, before disposal to landfill.

The partially treated wastewater still contains organic contaminants that did not react with the coagulants as they are only partially soluble in water. These compounds, such as oils and hydrocarbons can block the subsequent membrane systems (UF and RO) and therefore must be removed. The proposed process is adsorption onto GAC which is widely used in the production of drinking water to remove this type of contaminant. The hydrophobic regions of the organic molecules are attracted to the surface of the activated carbon where they remain attached. Eventually, the GAC becomes saturated with adsorbed organics and has to be replaced with new material. The spent carbon can be disposed of to landfill, or regenerated by heating at 500–900°C to destroy the adsorbed organics followed by reactivation under steam at elevated temperatures (800°C).

The preceding steps are only partially successful at removing PFCs. In order to achieve the water quality objectives for discharge to the surface waters, membrane filtration is required. The membranes are porous and by pressurising one side of the membrane, filtered water will pass through the membrane leaving a concentrated waste stream behind. As suggested by Cardno Lane Piper (2013a), this is generally a two stage process; the first step involves ultrafiltration to remove all particles down to the size of bacteria and some viruses that would otherwise quickly block the subsequent reverse osmosis stage. RO is similar to UF and is widely used for the desalination of seawater to produce drinking water. Much higher pressures are employed and the membrane pore size is very much smaller than for UF to enable it to remove molecules and large atoms from water. The process removes the PFCs from the “permeate” stream leaving a “reject” stream containing the concentrated contaminants. The reject streams from the UF and RO processes will require collection and safe disposal.

All the processes proposed are well proven for wastewater treatment and have the greatest chance of success in removing PFCs.



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One of the most significant considerations is the disposal of the contaminated waste streams. Cardno Lane Piper, (2013a), proposes an evaporation pond for the RO reject stream and transportation of the residue to a licensed disposal site. This route would also presumably be used for the UF waste stream together with the sludge from the lamella and spent GAC. Details relating to the evaporation pond (capacity, design, potential effectiveness and environmental impacts) are not provided in Cardno Lane Piper (2013a).

Pilot trials are necessary to assess and monitor the effectiveness of the selected technologies for the Site. Pilot trials to be undertaken will depend on the selected treatment option.

In summary:

- The likely approach to remediating contaminated surface water (and future fire training water) is considered practical in that it is one of a few technologies that are known to be able to successfully treat fire water to concentrations that may enable discharge to the environment or re-use as fire training water;

- The quality that the water will be required to be treated to is yet to be determined;

- Pilot studies are yet to be undertaken to prove the technology for the Site; and

- The generation and treatment / management of waste streams by the likely technologies is an important consideration that requires further detailed assessment.

4.4.3 Surface Water and Sediment Remediation

The CUP (CFA, 2014a) proposes to remediate contaminated surface water using the likely water treatment technology discussed in Section 4.4.2. As such, the comments provided in Section 4.4.2 are also applicable to surface water remediation.

The proposed approach to remediating contaminated sediments involves the physical removal of the contaminated sediments from the surface water environment and placement in a location where environmental impacts can be contained and managed. The approach may be considered to be practical; however, there are a number of uncertainties regarding the proposed sediment remediation technology as follows:

- Further sediment analysis and preparation of a remedial plan and Auditor approval prior to final determination of sediment remediation technology is required;

- The floating dredge proposed to be used to remove contaminated sediments may result in the exposure of underlying soils to contaminated water. This should be considered when completing the final remedial design;

- Waste classification of dewatered sediments will be informed by further detailed assessment of sediment quality and potential mobility of contaminants in the environment and is subject to consultation with EPA and the Auditor;

- Pilot trials are required to assess the likelihood of success of using GeotubeTM containers to dewater the sediments;

- Containment (to prevent contamination of surrounding soil and surface water) and remediation / disposal of water generated during sediment dewatering requires further consideration; and

- The suitability for dewatered sediments to be placed under a under a clay cap or Type 2 landfill cell is yet to be determined.

Should dewatered sediments be contained on-Site, a management plan should be implemented (similar to the LEMP) to maintain the clay cap or Type 2 landfill cell and minimise exposure to the contaminated sediments located under the cap. The containment area would have to be managed in perpetuity.

The GeotubeTM technology is considered to be proven as it is known to be used for containment and dewatering of municipal sludge, industrial waste and contaminated sediments. The underlying principles are that the waste is pumped into the tubes as a liquid (from the floating dredge), and effluent drains from pores in the tubes until the waste is sufficiently dry to place in a containment cell. Chemical conditioning (eg. the addition of polymers) can be used to optimise dewatering. The effluent is required to be contained, collected and treated / disposed. Pilot tests are likely to be required to assess the effluent quality and dewatered volume of the waste.

This technology would require the ability to assess / validate the efficiency of the removal of contaminated sediments by the floating dredge as well as a designed dewatering area that is capable of containing and collecting the effluent.



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4.4.4 Perched Water Remediation

The CUP (CFA, 2014a) proposes to remediate perched water using the water treatment technology discussed in Section 4.4.2. As such, the comments provided in Section 4.4.2 are also applicable to perched water remediation.

4.4.5 Capping of Former Landfills

The proposed capping of former landfills LF1 and LF2 is considered to be a practical approach to manage the risk identified by AECOM, 2014a. The Auditor notes that capping is a proven technology and based on the findings of the landfill risk analysis completed by Cardno Lane Piper, 2014a, the chosen capping design is considered appropriate and is likely to be an effective solution.

The proposed capping design addresses restoration of the beneficial use of aesthetics (refer AECOM, 2014a) by covering surface waste and reduces the potential for infiltration of rainfall into the former landfills (and generation of leachate). The design also incorporates placement of geogrid mesh to act as a physical barrier to burrowing animals.

A program to monitor the integrity of the cap is outlined in Section 5.4 of the LEMP provided in Appendix J of Cardno Lane Piper, 2014a (Appendix F of CUP [CFA, 2014a]).

4.5 Timing

Requirement 3.4 of Notice 90004570 necessitates the completion of clean up to treat, remove or contain all contaminated soil, waters and groundwater that represent an unacceptable risk of harm or detriment to the environment by 28 February 2017.

Within the CUP (CFA, 2014a), timing for completion of various tasks and activities is included in the Work Plan tables associated with each stage of work. The indicative timeline for all works is provided in Appendix C of the CUP (CFA, 2014a).

The Auditor notes that works associated with Stage 1: Containment are complete. However, on-going monitoring is required to ascertain if the works have been successful in containing CFA’s waste water on-Site and reducing the risk of it flowing off-Site.

The proposed likely water treatment plant (Stage 4: Remediation) is relatively complex and the proposed Work Plan set out in Table 4-18 of the CUP (CFA, 2014a) is ambitious. The current schedule indicates that performance trials of the shortlisted processes are proposed to be run in the third and fourth quarter of this year.

The ability to meet the proposed timelines of Appendix C of the CUP (CFA, 2014a) will depend upon:

- On-going monitoring demonstrating that contaminants are contained on-Site;

- Further Site assessments identifying limited contamination requiring further assessment or remediation agreement on criteria for discharge to surface water and waste classification for sediments;

- The agreement on water quality criteria (for discharge to surface waters) and waste classification for dewatered sediment with EPA;

- Timeframes required to perform sufficient pilot trials of the proposed likely water treatment technology;

- The required effectiveness of the proposed treatment technologies being demonstrated during pilot trials; and

- Obtaining the necessary approvals for the treatment and discharge.

4.6 Best Practice

Works completed as part of Stage 1: Containment represent common practice and are considered appropriate to meet the objectives of this work, namely; to contain waste water on-Site and reduce the risk of off-Site migration of contaminated surface water.

The proposed likely water treatment processes (Stage 4: Remediation) are well proven at full scale for use in the treatment of wastewater. Furthermore, the scale-up of these processes from pilot to full scale is well understood. The water treatment train proposed is comprehensive and given the current state of knowledge of the available technologies, probably represents best practice for this application.



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The recommended remediation technology for sediments is considered to be proven for similar applications and is considered to be good practice.

The proposed capping of landfills in accordance with the BPEM is considered good practice and appropriate for the on-going management of the former landfills.

4.7 Other Considerations

4.7.1 Roles and Responsibilities

Although not specifically stated in the text of the CUP (CFA, 2014a), Appendix C of the CUP (Indicative Time line) identifies the parties responsible for various proposed actions. These include CFA, Cardno Lane Piper and the Auditor. The Auditor understands that CFA (as the owner / occupier of the Site) intends to be ultimately responsible for all actions undertaken in accordance with the CUP (CFA, 2014a).

The CUP (CFA, 2014a) does not identify specific roles associated with the CUP (CFA, 2014a). Documents prepared under the CUP (eg. SAQP, WQMP, RAPs) should clearly identify the roles and responsibilities associated with the proposed works.

Section 3 of the LEMP (attached within Appendix F of the CUP [CFA, 2014a]) identifies roles and responsibilities associated with implementation of the LEMP.

4.7.2 Impacts on Third Parties

The containment measures outlined in the CUP (CFA, 2014a) aim to reduce the risk of water in Lake Fiskville flowing off-Site (noting that in wet years the potential remains for off-Site flow from Lake Fiskville). The measures outlined in the CUP are likely to reduce the frequency of contaminated surface water flowing off-Site (until treated), while not completely eliminating that risk.

Civil works associated with surface water diversion has the potential to generate sediment in run-off to Beremboke Creek and off-Site properties. The Auditor understands that the works included the establishment of vegetation prior to commissioning the diversion to minimise the potential for off-Site sediment run-off. According to Section 4.2.3 of the CUP (CFA, 2014a), Corangamite Catchment Management Authority (CCMA) is to inspect the diversion works prior to commissioning. This is designed to mitigate potential impact to occupiers of off-Site properties.

A task in Stage 1: Containment is to block off the drains from the VUT building so that effluent can no longer discharge onto CFA property. While VUT will be impacted by this action, it is not considered to be an adverse environmental impact.



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5.0 Limitations or Constraints on Endorsement The following limitations or constraints on the endorsement of the CUP (CFA, 2014a):

1. The remedial technologies assessed for water and sediment are those recommended within a feasibility assessment (Cardno Lane Piper, 2013a). No further investigation of the applicability and effectiveness of these technologies for the Site have been undertaken. Trials will be necessary to prove the selected technologies for the Site prior to implementation.

2. Further assessment of soil, surface water, sediment and groundwater to be completed as discussed in Stage 2: Site Assessments of the CUP (CFA, 2014a). The CUP (CFA, 2014a) notes that at the completion of further assessment as detailed in Section 3.1 of this report, there may be a need for the implementation of further remediation and/or management measures to restore beneficial uses of land, surface waters or groundwater. The Auditor notes that if additional remediation and/or management measures require implementation at the Site, an assessment of potential remediation technologies would need to be conducted and a remediation action plan (or similar) be provided to the Auditor for review.

3. The water quality criteria for discharge of treated water to the environment (which will influence the final remedial technology selected) are subject to EPA approval.

4. The waste classification of dewatered sediment (which will influence the final remedial technology selected) will be subject to consultation with EPA and the Auditor.

5. The water and sediment treatment technologies are likely to be subject to EPA approvals (e.g. Works Approval)



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6.0 References AECOM (2014a) Environmental Audit Report – Risk to Land, Surface Water and Groundwater, CFA Fiskville Training College, 4549 Geelong – Ballan Road, Fiskville, Victoria, 11 April 2014

CFA (2014a) Clean Up Plan, CFA Fiskville Training College, 4549 Geelong – Ballan Road, Fiskville, Victoria, 29 May 2014

CFA (2014b) Water Quality Management Plan, Fiskville Training College, March 2014 Ref: 212163.8Report WQMP 01.6

Cardno Lane Piper (2014a) Investigation of Risks at Former Landfills, Fiskville Training College, 4549 Geelong-Ballan Road, Fiskville, Victoria, 21 March 2014 Ref: 212163.13Report01.5

Cardno Lane Piper (2014b) Human Health Risk Assessment – Downstream Users Fiskville Training College 4549 Geelong-Ballan Rd, Fiskville Victoria, 31 March 2014 Ref: 212163.17Report04.5

Cardno Lane Piper (2013a) Feasibility Study of Water System Upgrade, Diversion Work and Remediation, CFA Fiskville Training College, 4549 Geelong-Ballan Rd, Fiskville, Victoria, 17 December 2013 Ref: 212163.22Report01.3

Cardno Lane Piper (2013b) Technical Drawings for Diversion Channel Re-alignment, PAD Training Area Stormwater Diversion, Fiskville Wetland and Diversion Channel Landscaping Plan



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7.0 Limitations AECOM has prepared this report in accordance with the usual care and thoroughness of the consulting profession for the use of CFA and only those third parties who have been authorised in writing by AECOM to rely on the report. It is based on generally accepted practices and standards at the time it was prepared. No other warranty, expressed or implied, is made as to the professional advice included in this report. It is prepared in accordance with the scope of work and for the purpose outlined in the Proposal for Environmental Auditing Services dated 16 January 2013.

The methodology adopted and sources of information used by AECOM are outlined in this report. In forming an opinion, the Auditor has relied on information supplied by CFA and Cardno Lane Piper. AECOM has made no independent verification of this information beyond the agreed scope of works and AECOM assumes no responsibility for any inaccuracies or omissions. There were no indications found during our investigations that information contained in this report as provided to AECOM was false.

This report is based on the information reviewed at the time of preparation of this document over the period 12 May – 28 May 2014. AECOM disclaims responsibility for any changes that may have occurred after this time.

This report should be read in full. No responsibility is accepted for use of any part of this report in any other context or for any other purpose or by third parties. This report does not purport to give legal advice. Legal advice can only be given by qualified legal practitioners.

AECOM Australia Pty Ltd +61 3 9653 1234 tel Level 9 +61 3 9654 … · 2015-05-14 · AECOM...

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