Chapter 4 Proposed contamination remediation works, former fire training area, RAAF
Base Williams, Point Cook, Victoria
The proposed remediation on RAAF Base Williams at Point Cook, Victoria, by
the Department of Defence (Defence) aims to remove soil contamination in two
main areas of the former fire training area, preventing harm to human health
and further pollution of Port Phillip Bay. The areas to be treated are known as
Pit A and Pit B; other contaminated areas on site will be addressed in future. These
future works do not form part of this proposal. The estimated cost of the
project is $27.3 million.
The proposal was referred to the Committee on 16 June 2011.
Conduct of the inquiry
The Committee received three submissions, one supplementary submission,
and one confidential supplementary submission detailing the project costs. The
published supplementary submission includes three documents: two lists of
chemicals found on the site, and Defence’s responses to questions raised by Parks
Victoria (submission 2). A list of submissions can be found at Appendix A.
The Committee undertook a site inspection, public hearing and an in-camera
hearing on the project costs on 26 July 2011 in Point Cook, Victoria.
The transcript of the public hearing as well as the submissions to the
inquiry are available on the Committee’s website.
Plans for the proposed works are detailed in Submission 1: Department of Defence.
Need for works
The Defence submission states that the works are needed in order to
address a historical contamination that resulted from the previous use of the
site, by Defence, as a fire-fighting training area. According to its
investigations, the site contains approximately 950,000 litres of toxic liquid
waste, known as Dense Non-Aqueous Phase Liquid or DNAPL.
Defence provided a list of some 120 chemicals found to be in this substance, included
in Defence’s supplementary submission, published on the Committee’s website.
While the DNAPL has so far remained on site (not directly in contact
with the water of Port Phillip Bay), groundwater moving through the soil
has dissolved some chemicals which are discharging into the Bay.
A list of these 12 ‘contaminants of concern’ was provided by Defence, included
in Defence’s supplementary submission and available on the Committee’s website.
As shown to the Committee during its site inspection, the present
physical barrier between the DNAPL and the Bay is getting smaller, due
primarily to coastal erosion. While Defence has installed an underground metal
barrier to prevent the DNAPL continuing to move towards the Bay, it is
imperative that the contamination be removed as soon as possible.
While the contamination is on Commonwealth land, the Victorian
Government’s Environment Protection Authority (EPA) will be conducting a full
audit of the decontamination works. This is not a legal requirement, because
Defence intends to retain the land, but Defence has indicated that it will use
the EPA audit process to provide certainty that the remediation has been fully
The Committee finds that there is a compelling and pressing need for the
Scope of works
The proposed scope of the works is detailed in Submission 1: Department
of Defence. The main technique used
to remove contamination involves the removal of soil, heating it and then
capturing the elements of DNAPL as they vaporise.
This will all be done within the RAAF Base Williams site, on Defence-owned
land. The project includes the following elements:
- ‘dewatering’ to allow
excavation of contaminated soil and DNAPL;
- treatment of
groundwater extracted during the dewatering process;
- excavation of
contaminated soil and DNAPL;
- preconditioning of
contaminated soil and DNAPL prior to treatment;
- treatment of the
contaminated soil and DNAPL using ‘thermal desorption technology’;
- testing of the
treated material to ensure complete remediation;
- backfilling of
excavations using the treated material;
- importation of clean
soil (if required); and
- rehabilitation and
revegetation of the areas of the site affected by the works.
The project would commence in February 2012 and be completed by the end
of April 2013.
The Committee finds that the proposed scope of works is suitable to meet
the needs of the project.
Cost of works
The total estimated out-turn cost for this project is $27.3 million
(excluding GST). The Committee received a confidential supplementary submission
detailing the project costs and held an in-camera hearing with Defence on those
The Committee notes that there are a significant number of Defence sites
around Australia that are contaminated and will require treatment. The
Committee expects that the vast majority of these sites will be much less
costly to remediate than the present project. Defence must ensure that it has
properly assessed the overall remediation tasks on its Estate, and that it has
budgeted accordingly to ensure that complete remediation can be undertaken on
The Committee is satisfied that the costings for the project provided to
it are adequate.
Risks posed by the contamination
According to the Department of Defence, the contamination currently
poses no risk to human health or marine life. Defence ceased using the
site for fire-training in the 1980s, and it has been largely unused since that
time. However, Defence could not provide a date on which the site was made
entirely inaccessible, and it is possible that Defence personnel continued to
use the site for other purposes until relatively recently.
During its site inspection, the Committee could clearly see that Defence
has conducted and continues to conduct considerable testing and monitoring of
the site. In addition to installing a metal barrier in the soil, Defence has
also fortified the existing shore line, in order to prevent further erosion of
the site. However, it is patently clear that remediation works are urgently
needed, to prevent damage in the future.
The site is in close proximity to the Point Cook coastal park and Point
Cooke marine sanctuary, managed by Parks Victoria. Defence gave evidence that
contaminants have reached the bay, and that contaminated groundwater has been
found within five metres of the coastal park. However, the Committee
accepts Defence’s assurances that ‘the levels [of contaminants] that have
reached the bay are not at levels that are unsafe for either use of that area
by the public or the environment’.
Local residents and land users
In its submission to the Committee, Parks Victoria raised a number of
issues about the impact of the contamination and decontamination works on local
land users. Defence has provided
responses to these questions, included in Defence’s supplementary submission,
available on the Committee’s website.
The Committee is satisfied that Defence has managed the contamination
risks adequately, but is concerned that neighbouring land users are not
sufficiently informed of Defence’s planning and management of risks arising
from the contamination. Parks Victoria, for example, sought a ‘copy of detailed
land contamination results ... to gain a full appreciation and understanding of
the potential risks to the environment and visitors to the park’.
Defence must more actively engage with local land users, authorities and
community groups, in order to provide confidence about the current risks posed
by contamination, and its plans to remediate that contamination.
Defence must also provide absolute certainty that the contamination has
been entirely removed. The remediation of sites such as these must be to the
very highest standard, and Defence must ensure that it makes strenuous efforts
to reassure local residents and park users that the site is completely safe.
Members of the public cannot be expected to accept minimum assurances:
it is not enough to merely point to an audit report. Defence must exhaustively
demonstrate that the site poses no continuing risk to human health or the
environment. Failure to do so will jeopardise Defence’s relationship with the
local residents at Point Cook, and potentially around Australia.
The Committee recommends the Department of Defence develop
an information and consultation protocol for use in relation to all
contaminated sites on Defence properties, to inform local residents of the
extent of, and risk posed by, any proposed treatment of such contamination,
regardless of when Defence plans to conduct remediation on each site.
The Committee recommends that the Department of Defence
establish and maintain a website to provide information about each
contaminated site, including the risks posed by the contamination, the
current management of the site, and details about planned remediation.
Further works at Point Cook
As outlined in Defence’s submission, these works (on Pits A and B) are
only the most pressing instances of contamination onsite. Further contamination
has been detected in Pits C, D and E and Mounds F and G. These areas will be
remediated in the future.
Whilst the Committee accepts Defence’s assurances that these other
contaminated areas are of a much lower risk to human health and the
environment, it is important that
Defence provide neighbouring land users with information about the extent of
contamination and its plans for remediation. Any subsequent discovery of
contamination must be immediately investigated to ascertain its extent and the
danger it poses.
Contamination on other sites
As Defence noted during the hearing, there are 180 Defence properties in
Australia where contamination has been detected.
The contamination is clearly widespread throughout the Defence Estate, with
approximately 2300 individual instances of contamination across those 180
The program to address this contamination has been in place since 2003,
and the present project is the remediation project with the highest priority.
Defence must ensure that, as part of the nationwide decontamination program, it
conducts exhaustive consultation and information programs in each site. Local
residents and land users must have absolute certainty that Defence is fully
apprised of the extent of contamination, and transparently managing the risks
posed by the contamination.
The Committee was impressed with the level of investigation that Defence
had undertaken to determine the best solution to remediate this particular
Overall, the Committee is satisfied that this project has merit in terms
of need, scope and cost.
Having examined the purpose, need, use, revenue and public value of the
work, the Committee considers that it is expedient that the proposed works
The 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 work: Proposed
contamination remediation works, former fire training area, RAAF Base
Williams, Point Cook, Victoria.