- PFAS Remediation of Former Fire Training Ground at Launceston Airport, Tasmania
Airservices Australia
2.1Airservices Australia seeks approval from the Committee to proceed with its proposed Per- and Poly-Fluoroalkyl Substances (PFAS) remediation of the former fire training ground at Launceston Airport in Tasmania.
2.2The project will remediate contamination resulting from historic fire-fighting training operations involving PFAS substances. The remediation will reduce PFAS levels, minimising the risks the substances pose to the environment and human health.
2.3The works will remediate 90 per cent of the estimated PFAS mass in the soil and sediment at Launceston Airport. This soil and sediment remediation is expected to improve groundwater and surface water PFAS levels, reducing the overall risk of ongoing contamination migration on the site and beyond. PFAS-impacted infrastructure will also be removed.
2.4The estimated cost of delivery of the works is $24.01 million (excluding GST) which includes a contingency of $4,884,054.
2.5The project was referred to the Committee on 14 November 2023.
Conduct of the inquiry
2.6Following referral, the inquiry was publicised on the Committee’s website and via media release.
2.7The Committee received four submissions and one confidential supplementary submission. A list of submissions can be found at Appendix A.
2.8On 9 February 2024, the Committee conducted a private briefing, and a public and in-camera hearing. A transcript of the public hearing is available on the Committee’s website.
Need for the works
2.9Launceston Airport, which is a regional airport on the outskirts of Launceston, is Tasmania’s second busiest airport after Hobart Airport. Its historical use as a firefighting training ground has resulted in the current PFAS contamination.
2.10PFAS are a group of over 4,000 human-made chemicals, used for a range of industrial and domestic applications. They have been found to be harmful to the environment and human health in high quantities. Until approximately 2010-11, aviation rescue and firefighting services provided at airports used PFAS-containing aqueous firefighting foam.
2.11A detailed site investigation, as well as previous studies commissioned by Airservices Australia and others, identified PFAS in soil, sediment and groundwater, with concentrations above relevant guidelines.
2.12The Airport Environment Officer of the Department of Infrastructure, Transport, Regional Development, Communications and the Arts (DITRDCA), the regulatory officer for leased federal airports, considers the proposed works essential to prevent continued migration of PFAS. Without PFAS removal, the contamination will continue to migrate from the source area to the broader airport precinct, neighbouring properties, and nearby waterways. PFAS contamination has already spread several kilometres from the site, with significantly elevated concentrations detected in surface waters and eel flesh. PFAS in soil on private property adjacent to the site have been detected at levels above the remediation criteria which were applied to airport land.
2.13The remedial actions of the works will address the Environmental Remediation Order (ERO) issued on 30 March 2023 by the Airport Environment Officer under the Airports (Environment Protection) Regulations 1997. Specifically, the works will:
- Reduce risk from PFAS impacts to personnel and airport users
- Reduce risk to the environment on site and nearby, including flora and fauna
- Manage and mitigate future PFAS surface and/or groundwater migration
- The proposed work will also reduce the ongoing costs of managing and developing contaminated land currently incurred by the airport lessee (Australia Pacific Airports Corporation) and the landowner (the Commonwealth).
Options considered
2.15Airservices Australia prepared an options assessment in accordance with the following national guideline documents: the National Remediation Framework and the PFAS National Environmental Management Plan Version 2.0. The options factored in the availability of remediation technologies, the value for money in achieving the remediation objectives and the sustainability of options. The options were:
- Do nothing: This option would be inconsistent with guidance to take precautionary risk-based management actions and it would not achieve the requirements of the ERO.
- Soil remediation: This option was the preferred choice to achieve the remediation objectives.
- Groundwater remediation: Active remediation of groundwater was not considered to be a viable option due to the currently available remediation technologies and the context of the site. Soil remediation is however expected to result in a consequential improvement in groundwater.
Scope of the works
2.16The proposed project will remove and/or manage soil and sediment and PFAS-impacted infrastructure.
2.17The works will remediate 90 per cent of the estimated PFAS mass residing in the soil and sediment on the site. The estimated excavation requirement is approximately 18000m3 of soil. Modelling estimates that 397.6 kg of PFAS mass resides in the remediation area to a depth of 5.0 metres below ground level, and approximately 87.6 per cent of this mass resides in the top 1.6 metres. Removal of the bulk of PFAS mass residing on site is expected to lead to improvements in groundwater and surface water conditions, reducing the overall risk of ongoing contamination migration on and from the site.
2.18Remediation will focus on soil excavation, stabilisation, reinstatement, disposal and thermal destruction. Groundwater PFAS levels will be monitored pre- and post-soil remediation in order to determine the potential need for any future groundwater remediation.
2.19The project scope includes:
- Installation of temporary boundary fencing to enable safe site access without impacting airport or neighbour access or safety
- Demolition and removal of FFTG [former fire training ground] concrete pad, FFTG low-level roof, drainage infrastructure, treatment, and disposal off-site
- Removal (excavation) and stockpiling of soil within the lease site boundary
- Testing and validation of the treated material
- Implementation of on-site wastewater treatment including sediment containment, removal and disposal
- Implementation of on-site soil and/or sediment treatment where feasible using ex-situ stabilisation following the sampling and analysis plan specified in the Validation Sampling Plan which will be prepared prior to commencement of remediation works
- Transportation of soil and/or sediment with PFOS + PFHxS concentration > 50 mg/kg from site interstate for thermal treatment and disposal
- Backfilling excavation site/s with stabilised, validated product, and/or imported clean fill (as required) to achieve final landform elevations specified in Remediation Action Plan
- Installation of a low permeable compacted clay capping layer (or similar, for example bituminous layer) to reduce potential future infiltration
- Final surface contouring to direct run-off away from the remediation area to existing airport related drainage systems to prevent water infiltration and/or surface water run-off
- Pre- and post-remediation surface water mass flux studies
- Baseline groundwater mass flux assessments conducted as soon as practical following completion of soil remediation activities
- Rehabilitation and revegetation of the areas of the Site affected by the works.
- Temporary transportable facilities, plant and equipment (such as fencing, haul roads and sheet piling) will be installed, operated and maintained for the duration of the works.
- Decommissioned infrastructure will be segregated and recycled to the extent that is practical. The remaining material will be disposed of as construction and demolition waste according to Environmental Protection Agency guidelines.
Potential impacts
2.22Airservices Australia anticipates minimal negative impacts of the works on the local community. The potential impact on traffic flow will be mitigated though a Traffic Management Plan which will be established prior to the works commencing.
2.23As PFAS are known to cause risks to human health, the Committee questioned Airservices Australia about the potential impact of PFAS exposure to those individuals carrying out remediation works, as well as airport staff. Airservices Australia stated they will follow the standards established by the PFAS Environmental Management Plan Version 2.0 to minimise human health risks. Specifically, Airservices Australia will reduce negative health impacts by implementing the measures below:
The primary exposure pathway for PFAS is via ingestion, not inhalation or dermally—through the skin. It is about ingestion. During the actual remediation works, to protect the workers, PPE and good hygiene practices will all be built into the environmental controls associated with the conduct of the work.
2.24In addition, worker exposure to PFAS will be monitored to the standards set out in the PFAS Environmental Management Plan Version 2.0. Airservices Australia provided the following information at the public hearing:
The exposure standards…have a number of assumptions about exposure and underpin the derivation of those numbers. They talk about the period of time that a worker would be at the site and talk about the exposure pathways that they would have at a site. The short-term nature of these works that we’re proposing here would mean that those guidelines are actually very conservative with regard to workers who are engaged in the remediation program.
2.25Airservices Australia will also ensure minimal further PFAS contamination during the remediation process itself by implementing contamination control processes:
Material will be excavated from the ground and will be segregated based on the concentrations of PFAS in that material. To be protected for future site users, material that has higher PFAS concentrations, which exceed that 20 milligrams per kilogram, will actually be sent offsite…Typically, the soil is excavated nominally in 50- to 100-cubic-metre lots. That soil is extracted and placed on a treatment pad. That treatment pad will be constructed as part of these works, as temporary infrastructure. It has environmental controls around it and will have the ability to capture rainwater when there is incidence of rain. That material is extracted from the ground, stockpiled, segregated and tested to confirm the concentrations, and therefore tested to confirm the fate of that material.
Our proposal for the material from Launceston is that it will actually be sent via barge to the mainland under appropriate documentation and appropriate agreements. It will be sent to disposal facilities in Melbourne, of which there are a very limited number—two or three—available in Australia. That material is then, effectively, destroyed thermally at high temperature. That breaks down the PFAS and destroys it.
For material that is at a lower concentration class, there are a number of landfills that are licensed in Australia to accept PFAS impacted material, provided that that material can achieve a number of acceptance criteria. Typically those acceptance criteria are around the leachability, the mobility, of the PFAS.
Community and stakeholder consultation
2.26Airservices Australia states that the following key stakeholders have participated in regular roundtables throughout the Detailed Site Investigation process:
- Australia Pacific Airports Launceston
- Airport Environment Officer, Department of Infrastructure, Transport, Regional Development, Communications, and the Arts
- Tasmanian agencies including:
- Environmental Protection Authority
- Department of Natural Resources and Environment Tasmania
- Department of Health
- Aboriginal Heritage Tasmania.
- At the public hearing, Airservices Australia stated that in addition to consultation with the above entities, it has have also engaged in consultation with adjacent landholders:
We have undertaken some initial assessments around the extent to which PFAS has migrated off site, and we confirm that it has migrated off site. So we are engaged with landholders who own that land on which the PFAS has migrated, and we’ll be continuing to investigate that as part of a detailed site investigation….We are engaged, consulting those landholders to understand that we’ve entered into appropriate agreements with them to access their properties and undertake sampling. There's obviously a level of concern from those property owners with regard to that migration of PFAS from our former fire training ground, and we’re working with them, but we’re not at a point where we can say with any certainty exactly what those levels are and what solutions or controls would be appropriate to put in place there.
Cost of the works
2.28The cost of the proposed works is $24.014 million, which includes a contingency of $4,884,054.
2.29The cost estimate was prepared by a quantity surveyor and is at a P80 level of confidence.
2.30The nature of PFAS contamination, for example its persistence in the environment and ability to spread over large distances through surface and ground water, often dictates removal and/or remediation of large volumes of soil, management of water flows and/or water treatment. These works are generally costly and complex. DITRDCA has reviewed the proposed works and considers the submission by Airservices Australia to represent a reasonable scope and cost of works.
2.31The Australia Pacific Airports Corporation considers the prospective value of the works to be significantly higher than the $24 million costing. The value could, potentially be in the hundreds of millions of dollars when including externalities like the significant benefits to the local community of managing contamination risk and the reduction of ongoing costs and liabilities from managing the contaminated area.
Public value
2.32By addressing the source area contaminated by the historical use of PFAS containing firefighting foams, the migration of PFAS contamination to surrounding Tasmanian land and waterways should be reduced. The scale of this investment is large, representing one of the most comprehensive contaminated land remediation projects undertaken in Tasmania. However, the need to protect human and environmental health from the risks posed by exposure to concentrated levels of PFAS justifies the investment.
Committee comment
2.33The Committee is satisfied the project has merit in terms of need, public value, and cost.
2.34The Committee understands it may take many years of ongoing monitoring for mass load flux reduction of PFAS in the receiving environment to become evident. The Committee suggests Airservices Australia continue its PFAS monitoring throughout this period and make the results available to key Tasmanian stakeholders.
2.35The Committee understands that the PFAS contamination is not constrained to airport land and extends to adjacent private property. Although the un-remediated PFAS mass may continue to leach into receiving ground and surface waters, the risk is low due to the low levels of PFAS found in the adjacent area. The Committee urges Airservices Australia to continue PFAS soil and water testing for a number of years following the completion of this remediation work to ensure any further leaching onto adjacent land is also remediated if required.
2.36The Commonwealth and all states and territories are signatories to the Intergovernmental Agreement on a National Framework for Responding to PFAS Contamination (the Agreement). A key principle of the Agreement (para. 14(b)) is that governments will cooperate to ‘deliver a more effective, proportionate and efficient response, especially where contamination crosses jurisdictional boundaries.’ The Committee suggests Airservices Australia continue to engage with key Tasmanian stakeholders, particularly state and local government, throughout the remediation period and beyond to ensure the remedial works reduce risk to the surrounding land.
2.37To ensure the success of future PFAS remediation works, the Committee encourages Airservices Australia to conduct a lessons-learned process at the completion of the project and share the results within Airservices Australia and with other relevant Commonwealth agencies.
2.38Having regard to its role and responsibilities contained in thePublic Works Committee Act 1969, the Committee is of the view that this project signifies value for money for the Commonwealth and constitutes a project which is fit-for-purpose, having regard to the established need.
2.39The Committee recommends that the House of Representatives resolve, pursuant to section 18(7) of the Public Works Committee Act 1969, that it is expedient to carry out the following proposed works: Airservices Australia—PFAS Remediation of Former Fire Training Ground (FFTG) at Launceston Airport, Tasmania.
2.40Proponent entities must notify the Committee of any changes to the project, scope, time, cost, function, or design. The Committee also requires that a post-implementation report be provided within three months of project completion. A report template can be found on the Committee’s website.