A comparison of responses to contamination of Australian Defence bases by the NSW and NT Environmental Protection Agencies

James Courtney

Perfluorooctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA) are chemicals that have been detected contaminating land and waterways surrounding a number of Department of Defence sites around Australia. These chemicals pose a threat to human health and the environment.

In Europe, PFOA is classified as a reproductive toxin and is required to be labelled "may damage the unborn child." The Science Advisory Board of the United States Environmental Protection Agency has assessed PFOS and PFOA as "likely to be carcinogenic to humans." These chemicals were historically used in fire fighting foams.

A 2003 Australian Department of Defence report contained a clear warning on the danger posed by the chemicals: "PFOS and PFOA are toxic to humans, and both have been implicated with a variety of cancers."1

NSW EPA Response

Defence announced on 3 September 2015 that PFOS and PFOA had been detected in groundwater at Williamtown RAAF Base, Newcastle Airport and in seafood taken from Tilligerry Creek and Fullerton Cove.2

On 21 October 2015 NSW EPA released a report containing sampling data.3 Test results were considered serious enough for the NSW EPA to immediately apply the precautionary principal, issue health advisories against drinking water from bores and close fisheries in a large area around Williamtown.

Within three months of the initial announcement on the 23 December 2015, NSW EPA had released an interim report, written by an independent expert.

After six months they have released a set of comprehensive reports, containing all sampling data on seafood contamination, dietary exposures, groundwater and surface water tests.4

Findings include:

  • "For people who may consume large amounts of seafood from the areas, there is a potential to exceed the health based guidance values."
  • "some species of fish and crustacea have the potential to significantly contribute to a person exposure to PFOS."
  • "Williamtown Expert Panel has identified need for further analysis of a wider selection of seafood, as part of the Human Health Risk Assessment."
  • "The results demonstrate that some species of fish and crustacea do contribute significantly to the exposure people may have to PFOS and warrant further investigation to ensure sufficient information is available for the comprehensive human health risk assessment."

NT EPA Response

A media report in 2008 suggests that contamination was first detected at Darwin Airport in 2003: "Darwin firefighter Steve Osborne said PFOS was "showing up" in environmental tests when the NT fire authorities decided to stop using it five years ago."5

The issue was not raised again until October 2015 when a Darwin community group raised concerns. Shortly afterwards on December 23 the NT News reported that Defence would be investigating contamination at Darwin and Tindal.6 The Department of Defence will investigate pollution caused by toxic firefighting foams at Darwin and Tindal RAAF bases, as fears grow about the possible impacts of the potentially carcinogenic chemicals.

It is important to note there has been no public evidence of Defence investigations. The first report by Defence to the Senate Inquiry in April details its national investigation of military facilities but contains no references to Darwin or Tindal.7

In an email communication with the author of this report, the NT EPA revealed that it conducted tests of Rapid Creek and Ludmilla Creek on February 16 2016. They won't say what the results are, only that they are "below Interim Draft Guidelines." The direct question, is it safe to swim in or eat seafood from Rapid and Ludmilla Creeks was left unanswered by the NT EPA.

The detection of PFOS and PFOA in waterways and questions being raised in a Senate inquiry8 hearing on April 7 triggered the announcement on April 8 by the NT EPA that an investigation would begin.

Northern Territory Environment Protection Authority and the Department of Health have joined forces to undertake preliminary investigations into the presence of fire-fighting foams at more than 20 locations in the Darwin City area.9

Defence is not listed as a partner in the investigation, but it is stated that the investigation is being undertaken "in consultation with Department of Defence and Darwin International Airport."

The differences between the NSW and NT responses are stark. The NT EPA are trying to say that the reason for their delayed response is that the issue just came to their attention with the February testings. PFOS and PFOA contamination issues at airports have been known since 2003. How much contaminated seafood has been eaten since then?

Health impacts will be very difficult to measure given Darwin's small, highly transient population, but the NSW EPA recommendations have been clear ‒ it is the families of recreational and professional fisherman that eat the most seafood and are at the greatest risk of exposure to dangerous levels of PFOS and PFOA.

In Darwin, Ludmilla Creek has been a significant source of food for the Indigenous communities of Bagot and Kululuk. This should be acknowledged and investigated.

As it has been in NSW, the precautionary principle should be applied and fishing banned in Rapid, Ludmilla and Buffalo Creeks pending investigations. The NT Government should urgently assess the capacity and resourcing of the NT EPA to determine its ability to conduct the investigation required.

The reality is that the EPA is under resourced, under skilled and lacking the strength and political independence required of an effective regulator. This is a commonly held opinion within the environment sector of the NT public service.

The NT Department of Primary Industry and Fisheries should be contributing to preliminary investigations and testing of fish, crabs and shellfish at Rapid, Ludmilla and Buffalo Creeks.

The Department of Defence should immediately share all historic surface and groundwater monitoring data gathered at RAAF Base Darwin and its vicinity and commit to working with the NT EPA as a direct partner to conduct a full investigation, as is occurring in NSW.

Full and open transparency including the sharing of all data will rapidly progress knowledge.

NT Government: Asleep at the wheel or head in the sand?

A search of NT Government Legislative Assembly hansard for PFOS and PFOA returns zero results.10

The same search of NSW Legislative Assembly hansard returns twenty-one results.

It would appear that in the lead up to Federal and Territory elections an issue as huge as this is just too difficult for either political party to take a stand on.

The Department of Defence is a powerful political and economic force in the Territory, with billions slated for the development of key infrastructure.

RAAF Base Darwin is ageing. Fuel handling infrastructure and ammunition storage facilities are two major assets which probably need replacing if predicted increases in US Air Force and Marine operations come to fruition.

Both facilities are traditionally acknowledged as presenting significant environmental issues, with billions being spent in the United States cleaning up legacy contaminated sites on military bases.

Perhaps this is the real reason for the secrecy around contamination at RAAF Base Darwin and Darwin Airport.

If the full extent of existing contamination issues were revealed, the need to replace existing infrastructure would be obvious. A full measure of costs is likely to be enormous.

But more importantly, how might the people of Darwin respond to a full disclosure of the current risks, let alone those presented by an escalation of military traffic and construction of infrastructure such as new ammunition handling facilities to support the US Air Forces Air Force Global Strike Command.

A community suddenly coming to terms with the real risks associated with having a secretive, unaccountable, growing military industrial complex smack in the middle of the only city in Australia to have ever been bombed by a foreign military force might raise some significant community acceptance challenges for the Department of Defence.

James Courtney works as a freelancer specialising in communications technology, multimedia strategy and content. He is a former community representative on the National Industrial Chemicals Notification and Assessment Scheme Community Engagement Forum. For the past three years James has been investigating the impacts of RAAF Base Darwin and the Darwin International Airport in an effort to determine if it is safe to swim in Rapid Creek.



1. www.defence.gov.au/FOI/Docs/Disclosures/387_1415_Document.pdf

2. http://news.defence.gov.au/2015/09/03/ground-water-contamination-at-raaf...

3. www.epa.nsw.gov.au/MediaInformation/williamtown.htm

4. www.epa.nsw.gov.au/MediaInformation/williamtown.htm

5. Sydney Morning Herald, March 3 2008, www.smh.com.au/national/toxic-foam-drifts-over-darwin-20080303-1wj1.html

6. NT News, December 23, 2015, www.ntnews.com.au/news/northern-territory/department-of-defence-launch-i...

7. www.defence.gov.au/id/_Master/docs/Williamtown/AustralianGovernmentRespo...

8. www.aph.gov.au/Parliamentary_Business/Committees/Senate/Foreign_Affairs_...

9. www.ntepa.nt.gov.au/news/2016/joint-investigation-into-fire-fighting-foa...

10. http://notes.nt.gov.au/lant/hansard/hansard12.nsf/HomePage2/frmDefault?o...

Published in Chain Reaction, national magazine of Friends of the Earth Australia, August 2016

Reprinted from https://medium.com/@jamescourtney/action-and-inaction-transparency-and-s...