This chapter will provide a brief background to the inquiry. One of the focuses
of the inquiry related to when government agencies and other stakeholders became
aware of the nature of the PFOS/PFOA contamination at RAAF Base Williamtown and
how they responded. A summarised timeline of these events is included.
PFOS and PFOA
Perfluorooctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA) are
two types of man-made perfluorinated compounds (PFCs) or perfluorinated alkylated
These compounds have been used in a range of industrial, commercial and
domestic products for decades, due to their ability to repel oil, grease, and
water. In particular, high concentrations of PFOS and PFOA have been used to
make aqueous film forming foam (AFFF), a component of firefighting foams. These
firefighting foams have been used for nearly 50 years on Defence and civilian facilities
in Australia due to their effectiveness in extinguishing liquid fuel fires.
PFCs, including PFOS/PFOA, are chemically and biologically stable in the
environment and resist typical environmental degradation processes. As a
result, these chemicals are extremely persistent in the environment. PFOS/PFOA
are water-soluble and can migrate readily from soil to groundwater, where they
can be transported long distances. Studies have shown that
PFOS/PFOA also bioaccumulate and biomagnify in wildlife and enter the human
Due to these characteristics, PFOS/PFOA are regarded as 'emerging
contaminants' or pollutants which are potentially a threat to human health or
PFOS and PFOA are eliminated slowly from the human body, and concentrations of
the chemicals in the body can increase over time if they are continuously
consumed in food or water. They have been shown to have effects, particularly
in the liver, at low doses in animal tests but the scientific literature on the
effect of PFOS/PFOA in humans does not give clear, unambiguous results.
PFOS was added to Annex B of the Stockholm Convention on Persistent
Organic Pollutants (Stockholm Convention) in May 2009. This convention aims to
protect human health and the environment from the effects of persistent organic
pollutants (POPSs). Australia is a party to the Stockholm Convention, but has
not ratified this particular amendment. PFOA is currently being considered for
listing under the Stockholm Convention.
As evidence of the health and environment risks has emerged, global
manufacturers and other users have moved to replace long-chain PFCs (such as
PFOS/PFOA) with shorter-chain PFCs which are currently considered less toxic
and less bioaccumulative. However, PFOS/PFOA continues to be used in some
From the 1970s until the mid-2000s, the main AFFF product used by
Defence at its facilities was 3M Lightwater which contains PFAS, including PFOS/PFOA.
3M Lightwater was gradually phased out and replaced by 'Ansulite', which
contains significantly lower concentrations of PFOS/PFOA.
In December 2011, Defence added PFOS/PFOA to its routine environmental
monitoring, particularly at facilities where firefighting foams may have been
used. In 2012, Defence detected PFOS/PFOA at RAAF Base Williamtown, near
Newcastle in New South Wales (NSW).
RAAF Base Williamtown is headquarters to Australia's Air Combat Group
and shares its runway facilities with the civilian Newcastle Airport. It is
located approximately 15 km north of the city of Newcastle in a semi-rural
setting with agricultural land, water catchment reserve and State Conservation
Areas surrounding the base.
It has been used as a military air base since its establishment in 1941. The
base is a significant employer in the Port Stephens region and supports a
number of related private sector operators and defence contractors.
Approximately 3,500 fulltime personnel work onsite.
Summarised timeline of events
The following is a summarised timeline of events giving a brief
background as to how government agencies became aware of the PFOS/PFOA
contamination at RAAF Base Williamtown. It is not a complete list of all events
and other timelines have been provided to the inquiry by Defence and New South
Wales Environmental Protection Authority (NSW EPA).
During the 1970s to the mid-2000s, firefighting foam containing PFOS/
PFOA produced by the 3M company was used by Defence at RAAF Base Williamtown
and other ADF facilities.
In May 2000, the 3M company, the primary manufacturer of PFOS, announced
a voluntary phase out following negotiations with the US Environment Protection
Agency (US EPA). This was the result of emerging scientific evidence about its
persistence in the environment and long-term health and environmental effects.
Following this decision, in July 2000, the Organisation for Economic Cooperation
and Development (OECD) Task Force on Existing Chemicals member countries
(including Australia) agreed to informally work together to collect information
on the environmental and human health hazards of PFOS to produce a hazard
The 3M Company, completed a voluntary phase-out of PFOS production in
In 2002, reports of fish-kills are observed by Defence environment management
officers 'following the accidental, incidental or deliberate release of fire fighting
foam [on Defence sites] into aquatic environments'.
The initial OECD report on PFOS was finalised in November 2002. In
particular, it described PFOS as 'persistent, bioaccumulative and toxic to
mammalian species' and recommended further research to 'predict risk to humans'.
On 30 April 2003, the Department of Health's National Industrial
Chemicals Notification and Assessment Scheme (NICNAS) released an alert
recommending that PFOS/PFOA firefighting products such as AFFF be restricted to
essential use only, and that AFFF should not be used for fire training/testing
In May 2003, Defence's Environmental Stewardship, Environment, Heritage
and Risk Branch prepared an internal report titled 'Environmental Issues
Associated with Defence use of AFFF'. The key findings of this report include:
Defence uses [AFFF] product produced by the 3M company. This
AFFF product contains non-biodegradable fluorosurfactants (specifically [PFOS
and PFOA]) that are environmentally persistent, bioaccumulative and toxic to
animals and humans. Both PFOS and PFOA have been implicated with a variety of
cancers and toxic health effects in humans that have had long term exposure to
products containing PFOS/PFOA. 3M are ceasing the production of this AFFF
product in 2003, and Defence will have to source an alternative product.
Appropriate drainage, containment and disposal of foam waste-water will still
be required for any replacement foam product.
Current Defence AFFF use and waste management practices are inconsistent
and generally fall below the best practice of other national and
Across many Defence facilities AFFF waste-water is not
appropriately collected or disposed of. Based on these past and current
practices there is a risk that PFOS/PFOA has contaminated Defence land as well
as neighbouring properties, creeks, dams, and reservoirs.
The Stockholm Convention on Persistent Organic Pollutants came into
force on 17 May 2004, with Australia ratifying the Convention on 20 May 2004
and becoming a Party on 18 August 2004.
In 2004, Defence investigated alternative AFFF products to replace the
3M company product.
Defence published Environmental Guidelines for Management of Fire
Fighting Aqueous Film Forming Foam (AFFF) Products which acknowledged the
potential adverse impacts associated with historical AFFF products and noted
that 3M Lightwater must not be procured.
In May 2009, the Conference of the Parties to the Stockholm Convention
on Persistent Organic Pollutants decided to amend the Convention Annexes to add
nine new chemicals including PFOS.
The decision was communicated to Parties on 26 August 2009. The
Stockholm Convention characterises PFOS as 'extremely persistent and has
substantial bioaccumulating properties...[i]t has a capacity to undergo
long-range transport and also fulfils the toxicity criteria of the Stockholm
Convention'. However, it provides for the production of PFOS in firefighting
foam as an 'acceptable purpose'.
In October 2009, Hunter Water sampled Pump Station 9 near RAAF Base
Williamtown and conducted analysis for PFOS/PFOA. PFOA was found to be below
the limit of detection. PFOS was found to be at a concentration of 0.03
micrograms per litre – marginally above the limit of detection (0.02 micrograms
The then Department of Sustainability, Environment, Water, Population
and Communities commenced consultations with interested stakeholders including state
and territory government agencies, and affected industry, environment and
public health groups in December 2010 regarding ratification of the
amendment to the Stockholm Convention.
In 2011, Defence included monitoring for PFOS and PFOA in its environmental
activities. Routine monitoring in December 2011 finds two elevated detections
on RAAF Base Williamtown.
In February 2012, NSW Government established the NSW EPA as an independent
In March 2012, results from routine monitoring by Defence find elevated
levels of PFOS/PFOA at 8 out of 12 locations on RAAF Base Williamtown and
elevated levels in surface water leaving the base.
On 2 May 2012, Defence contacts the NSW EPA to advise of surface water
detections off-site at RAAF Base Williamtown and requests a meeting. On 10 May
2012. NSW EPA received confidential briefing that there is on-site PFOS
contamination in soil and surface water leaving RAAF Base Williamtown and that
a detailed Stage 1 contamination investigation is to be undertaken.
NSW EPA requested data and reports and urges Defence to 'urgently notify Hunter
Water, Port Stephens Council, the media, the community and other stakeholders'.
Also in May 2012 Defence advised Hunter Water that firefighting foams
containing PFOS/PFOA were used on the base and there was the potential for
contamination. In response to this advice, Hunter Water tested all of its bores
in the Tomago Borefield for PFOS/PFOA on 22 May 2012. All samples, including
the sample from Pump Station 9, returned nil detects for PFOS/PFOA.
In January 2013, the NSW EPA receives advice from Defence regarding
groundwater PFOS/PFOA contamination on part of RAAF Base Williamtown.
In March 2013, Defence receives the Stage 1 – Conceptual Site Model
for AFFF Contamination prepared by GHD. The Stage 1 report findings
regarding the contamination on RAAF Base Williamtown include:
Detectable PFOS and PFOA concentrations in groundwater are
widespread on [RAAF Base Williamtown]. The highest concentrations associated
with the fire training pit and fire training pad, trade waste facilities, Lake
Cochran...and the former landfill.
Off-site groundwater samples including those nearby to [Hunter
Water] extraction points reported no detectable PFOS or PFOA.
On-site and off-site surface water and drain sediments at [RAAF
Base Williamtown] were found to contain detectable concentrations of PFOS and
The report identifies a number of 'existing and/or potential future
human receptors of contaminated soil and groundwater offsite'. These include:
consumers of potable water (however it notes, 'there is no
evidence to suggest the [Hunter Water] bores contain PFOS or PFOA at detectable
recreational users of surface water e.g. swimming pools,
recreational users of the receiving waters for groundwater and stormwater;
use of irrigation water or stock-watering water via
consumers of marine biota; and
consumers of terrestrial fauna.
Using a Defence Contamination Risk Assessment Tool, the Stage 1 report
rates nearly all of the investigated sites as 'Very High' risk noting legislative
compliance, reputation, environment and heritage and financial efficiency as
'key risk drivers'. The Stage 1 report outlines a large number of data gaps in
understanding the risk of the contamination and proposes a sampling and
analysis quality plan for further investigations.
Defence engages a contractor to undertake the Stage 2 Environmental
Investigation. However, this contractor goes into business liquidation and was
unable to continue (undated).
On 28 March 2013, the NSW EPA writes to Defence requesting advice on the
management strategy for the contamination.
On 20 May 2013, the Port Stephens Council receives correspondence from
Defence outlining the results of Stage 1 of the investigation.
The letter stated that detectable levels of Perflurooctane
sultanate (PFOS) and Perfluorooctanoic acid (PFOA) were found in on-site and
off-site surface water and drain sediments at RAAF Base Williamtown. It also
stated off-site ground water samples showed no detectable PFOS or PFOA. The
letter alerted Council officers to the issue but indicated that, at that early
stage, further research was needed to understand the possible risks. The
initial advice did not indicate immediate cause for alarm and that further
investigations were underway.
On 22 May 2013, Hunter Water also received notification from Defence
regarding contamination moving off-base.
On 24 May 2013, NSW EPA receives RAAF Williamtown Stage 1 – Conceptual Site
Model for AFFF Contamination from Defence.
On 20 June 2013, NSW EPA brief on groundwater contamination at RAAF Base
Williamtown is received by the Hon Robyn Parker MP, NSW Minister for the
Environment. The brief highlights that data gaps are significant in the
understanding of risks posed by the PFOS/PFOA contamination and the lack of NSW
EPA regulatory control of Defence.
On 18 November 2013, the NSW EPA raised the issue of contamination at
RAAF Base Williamtown with the Department of the Environment. The letter
The EPA wrote to [Defence] on 26 September 2013 requesting an
update on the Stage 2 works and proposing a meeting with all relevant
agencies to outline and discuss the further investigation works. To date the
EPA has received no response to this letter.
As you are no doubt aware, given that [Defence] is a
Commonwealth Government agency the EPA does not has a regulatory role in this
matter. This letter is to formally notify your agency of the current situation
at the Williamtown RAAF Base for any further actions you may consider
In April 2014 Defence engaged a new contractor, URS Australia, for the
Stage 2 Environmental Investigation. Sampling commenced in May 2014.
In September 2014 Defence wrote to stakeholders including Newcastle
Airport Limited, NSW EPA, Hunter Water, Port Stephens Council, NSW Department
of Primary Industries (Office of Water), NSW Health (Hunter New England
District) and NSW Office of Environment and Heritage to advise that the Stage 2
Environmental Investigation had commenced. In September 2014, Hunter Water makes
the decision to embargo the use of Pump Stations 7 and 9 for water supply
purposes based on the risk of drawing PFOS/PFOA contaminants towards borelines.
In November 2014, sampling undertaken on and off-site. These include 185 groundwater
samples; 20 surface water samples; 230 soil samples; 35 sediment samples; 30
vegetation samples; 18 biota samples.
In May 2015, Hunter Water tested water from Pump Station 9 near RAAF
Base Williamtown and detected PFOS/PFOA contaminants.
In May 2015, Defence prepares Defence Contamination Directive #8 –
Interim Screening Criteria, which outlines interim screening levels for
PFOS/PFOA on Defence site.
On 14 May 2015, URS Australia provides verbal overview of preliminary
Stage 2 data to Defence. On 9 June 2015, Defence receives preliminary Stage 2
In June 2015, the European Union submitted a proposal to the Persistent
Organic Pollutants Review Committee to list PFOA and related compounds under
the Annexes of the Stockholm Convention.
On 3 August 2015, Defence received draft Stage 2 report conducted by URS
Australia. The report found:
PFAS are present across a range of environmental media both
within the Base and in several off-Site areas. Investigations of source areas
on-Base showed the presence of PFAS in soil at elevated concentrations
immediately adjacent to these source areas.
Concentrations of PFAS in groundwater exceeding the human
health screening criteria were found in proximity to on-Site source areas and
in several off-Site areas. PFAS concentrations in groundwater in off-Site areas
were generally lower that those within the Base, but also exceeded the
screening criteria in some instances. Off-Site concentrations which exceeded the
screening criteria were mostly confined to the land south of the Base and the
Tilligerry State Conservation Area to the east. Given the likely direction of
flow, the groundwater present in off-Site areas to the south and to the east
was considered most likely to be impacted.
On-Site and off-Site surface water investigations show that
surface water is a migration pathway for PFAS. In particular, PFAS were found
in the drain adjacent to the Fire Training Pad, Lake Cochran, Dawsons Drain,
Moors Drain and Tilligerry Creek. Off-Site migration of dissolved-phase PFAS in
surface water appears likely to have resulted in impacted sediments at
investigation locations downstream from the Base. Aquatic fauna sampled in
these off-Site areas did not report PFAS concentrations exceeding the adopted
ecological screening criteria.
However, the Stage 2 report cautioned that
It should be noted that the presence of concentrations higher
than the adopted screening criteria a does not necessarily indicate an
unacceptable risk. Rather, it indicates that potential exposures to these
chemicals should be evaluated in greater detail, taking into account site-specific
pathways of exposure.
It also highlighted that a number of data gaps are present which require
further investigation. These included findings that:
The nature and extent of off-Site groundwater dissolved-phase
PFAS impacts requires further assessment...;
The hydrogeological pathways between the Base and potential
off-Site human and ecological receptors require more detailed investigation....;and
The nature and extent of off-Site surface water, sediment and
aquatic fauna impacts from the Base boundary to Fullerton Cove and Tilligerry
Creek requires further assessment. 
On 4 August 2015, Defence sent the draft Stage 2 report to stakeholders
NSW EPA, Hunter Water, NSW Department Primary Industries (Office of Water), NSW
Health, Newcastle Airport. On 12 August 2015, Defence held a stakeholder
meeting to go through the Stage 2 report.
On 3 September 2015, the NSW EPA advised Defence it was issuing a media
release announcing precautionary measures that day. The media release stated that
Defence had made NSW EPA aware that 'legacy fire-fighting chemicals had been
found in some surface water, groundwater and in small numbers of fish around
the Williamtown RAAF Base and Newcastle Airport'.
The NSW EPA noted that, while 'at this stage any risk to human health appears
to be low', it was taking a 'precautionary approach to this preliminary advice'.
In keeping with this precautionary approach the NSW
Government is advising potentially impacted residents...to not drink bore water
and to not eat fish caught in the nearby area or eggs from backyard chickens
that have been drinking bore water in the area...
As a precaution, there will be a closure of commercial and
recreational fisheries and oyster harvest for up to one month in both Fullerton
Cove and the Upper Tilligerry Creek.
Potentially affected bores are isolated to an area covering
part of the Tomago and Stockton sandbeds and there is no risk to the
reticulated (town) water supply.
Defence also issued a media release on 3 September 2015. It stated that
'[p]reliminary tests have identified [PFOS] and [PFOA] in ground water south of
Williamtown RAAF Base and Newcastle Airport' and '[t]hese substances have also
been identified in Tilligerry Creek and Fullerton Cove and some aquatic life in
these waterways'. The media release included:
Defence is aware that the NSW Government issued a media
release today recommending that residents in the affected area avoid drinking
bore water, eating fish caught from the Tilligerry Creek or Fullerton Cove or
consuming eggs from backyard chickens on those properties in the area.
The health and safety of people who reside near our bases and
Defence personnel who work, or have worked, at these bases is a high priority
for Defence. Despite extensive research, scientific studies into the possible
human health impacts are inconclusive.
On 16 September 2015, the NSW Government announced two reviews of
the management of contaminated land sites. The first review, led by the NSW
Chief Scientist, Professor Mary O'Kane and an Expert Panel, was formed to advise
the NSW Government on the planned and ongoing management of the RAAF Base Williamtown
contamination. The second review by Professor Mark Taylor of Macquarie
University, would consider the EPA's implementation of the findings of the
Auditor-General's 2014 report into managing contaminated sites.
On 30 September 2015, at the Tomago community consultation event, Air
Commodore Steve Robertson is reported as stating 'Defence polluted here,
Defence pays' in relation to the question of compensation for contamination.
On 1 October 2015, a Williamtown Contamination Investigation Community
Reference Group (CRG) was established to 'support local communities to address
concerns related to the detection of [PFOS] and [PFOA] in nearby surface water,
groundwater and biota in the vicinity of the Williamtown RAAF base'. The CRG is
headed by the Parliamentary Secretary for the Hunter, Mr Scot MacDonald MLC.
On 2 October 2015, the Expert Panel recommended 'lifting a temporary ban
on oyster harvesting' but 'advised that a ban on commercial and recreational
fishing should continue for the time being after some species were found to
contain [PFOS] at levels which cause some concern'.
On 8 October 2015, the Expert Panel, after reviewing preliminary samples
extended the NSW EPA investigative area to the east to the Tilligerry Creek
fisheries closure area.
On 20 October 2015, the EPA released preliminary surface and ground
water investigation results. Bore and surface water sample water were generally
consistent with the reported in the Stage 2 report undertaken by Defence, being
highest near the base and decreasing at distance.
On 26 October 2015, Defence commenced Stage 2B environmental
investigation. Over 900 samples are expected to be collected, along with
completion of a Human Health Risk Assessment and an Ecological Risk Assessment.
On 27 October 2015, the Expert Panel recommended a further eight-month
ban on fishing while human health risk assessment is undertaken. It stated:
The proposed ban on commercial and recreational fishing in
the designated area is recommended to remain in place until 30 June 2016.
Meanwhile, the Expert Panel has restated the need for local residents to heed
other precautionary advice until the human health risk assessment is complete.
As such, residents who live inside the investigation area
- drink or prepare food from private water bores, or water from dams,
ponds, creeks or drains (town water is safe)
- eat eggs from backyard chickens or milk from cows and goats that have
been drinking bore water or surface water in the area; and
- eat fish, prawns or wild oysters caught in the nearby area.
The NSW Department of Primary Industries indicated 'the eight month
fishing ban extension is devastating news for commercial fishers, many of whom
have had no income these past eight weeks'. NSW EPA CEO Mr Barry Buffier
The NSW Government is strongly committed to the "polluter
pays" principle and Defence is the polluter in this case. As such, the EPA
expects Defence to provide appropriate and timely financial assistance to
members of the community and businesses who are adversely impacted due to
pollution from the RAAF base. We are vigorously pursuing this.
On 4 November 2015, the Assistant Minister for Defence announced an
assistance package for commercial fishers affected by NSW Government
precautionary closures of Fullerton Cove and Tilligerry Creek.
On 11 November 2015, the NSW EPA updated its advice that, as a
precaution, residents and young children should not swim in pools filled with
bore water or local creeks, dams, drain or ponds in the investigation area.
On 3 December 2015, the committee held a public hearing for the inquiry at
Parliament House in Canberra.
On 8 December 2015, NSW Premier Mike Baird met with the Prime Minister
and Defence minister to discuss Williamtown.
On 21 December 2015, Hunter Water released the results of tests
confirming that Grahamstown Dam, a major water source for the Newcastle area, was
free of firefighting foam contaminates.
On 22 December 2015, the committee held a public hearing at the
Newcastle City Hall in Newcastle.
On 23 December 2015, the NSW Government announced an assistance package
for Williamtown residents affected by contamination from the RAAF base. This package
includes a program to connect affected developed properties within the
investigation area to town water, an investment in new contamination testing
equipment and the deployment of additional community liaison staff to help
address concerns of the local community.
Also on 23 December 2015, the interim report of Professor Mark Taylor into
management of contamination at RAAF Base Williamtown is released (dated 14 December 2015).
While characterising the actions of the NSW EPA and NSW government agencies (from
August 2015) as 'responsive, timely and appropriate', Professor Taylor's
interim report highlights a lack of clarity in the regulation of contamination
spreading from Defence land to non-Commonwealth owned land.
On 8 January 2016, media reports that Defence is prepared to sign a
trade wastewater agreement with Hunter Water for RAAF Base Williamtown 'which
includes accepting unlimited liability for any damage caused by contaminants
entering the sewer'.
Navigation: Previous Page | Contents | Next Page