In February, Friends of the Earth sent a Freedom of Information request to Gippsland Water for information pertaining to PFAS and pesticides detections in drinking water and PFAS detections at Gippsland Regional Organics facility at Dutson Downs. FoE received information back from Gippsland Water in early April 2025. 234 documents were refused access! (The drinking water information will be published in another blog).

Dutson Downs is a 8,500 hectare site located in Gippsland in close proximity to the Gippsland Lakes (approximately 3km south of Lake Coleman). The site is managed by Gippsland Water and is a waste management and agribusiness facility. 5,000 hectares of Dutson Downs consists of native vegetation. Dutson Downs has a 70% share of all waste produced in the Gippsland Region.

Lake Coleman (now a Wildlife Reserve), received wastewater from Dutson Downs for three decades between the early 1960's and 1992. Since 1992 however, all effluent from Dutson Downs has been piped into Bass Strait, via a pipeline that enters the ocean at Delray Beach (~5km south east of Dutson Downs). The outfall is located 1.3km offshore. The effluent consists of domestic sewage, industrial waste, including pulp mill waste from Australia's largest pulp mill at Maryvale* and formation water from offshore oil platforms. (*In 1986 the EPA amended APM's  Maryvale's discharge licence (including dioxins) which effectively meant Maryvale could no longer discharge into the Latrobe Valley Outfall Sewer. The community had also objected to APM's plan to discharge pulp mill water into the Latrobe River). 

Another pipeline, commissioned in 1983 also exists at McGaurans Beach for saline waste water from AGL's Loy Lang Power Station.  Dutson Downs also receives millions of litres per year of saline formation waters from the oil and gas processing facility at Longford which were originally disposed of by evaporation but are now also disposed via the Delray Beach pipeline. Formation waters consist of mainly saline water mixed with oil. A majority of this formation water was disposed of at sea, but some is piped from oil rigs to be treated at Longford.

The Federal Department of Defence has management responsibilities for a large portion of Lake Coleman which has been used as an Air Weapons Range. The Department of Defence has spent tens of millions of dollars on consultant reports and PFAS clean up efforts at Sale RAAF base which is 18 kms away from Dutson Downs. Why has there not been similar monitoring and clean up operations to monitor and contain PFAS contamination from Dutson Downs? Shouldn't both the Federal and State Government's initiate such funding?

Google Earth view of the Dutson Downs facility. Gippsland Regional Organics site can be seen in the top left of image.

PFAS Ecological Guideline Values (μg/L refers to parts per billion)

PFAS in waste water at Dutson Downs between April 2023 and February 2025 was dominated by PFOS, which accounted for 67% of the total amount of PFAS in waste water. It is assumed that the waste water was eventually released off Ninety Mile Beach via the Delray Beach outfall. Almost every sample of the 82 test regimes conducted by Gippsland Water contained PFOS, PFOA, PFHxS, PFHxA and PFHpA. 

Dutson Downs in March 2021, and what appears to be a significant algal bloom

Groundwater

PFAS detections from over 70 testing regimes between March 2017 and September 2023 shows increasing levels of PFAS in groundwater at Dutson Downs with PFHxA dominating detection volumes. All testing regimes detected PFAS. The most frequently detected PFAS chemicals being PFHxS, PFOA, PFBS, PFHxA and PFOS. PFHxA (Perfluorohexanoic acid) can be created through breakdown of other short chain fluorinated polymers. It is unclear from the data provided by Gippsland Water where the groundwater samples were taken from and from what depth. It is also impossible to know the extent of the PFAS pollution and in which direction the groundwater is flowing. There is likely to be perched groundwater underlying Dutson Downs with deeper groundwater in the underlying Boisdale Aquifer. 

The major concern at Dutson Downs is groundwater pollution. If PFAS pollution into the Gippsland Lakes is coming from Dutson Downs, the major conduit will most likely be groundwater and a PFAS plume. It could be expected that groundwater would drain in a northerly and eastern direction from Dutson Downs, meaning that Lake Coleman and Lake Reeves could be impacted. Is the PFAS plume increasing and is it already impacting on Lake Coleman and Lake Reeves? Groundwater may also flow in a south easterly direction (similar to groundwater under Exxon's Longford facility). This would mean more PFAS impacts on Lake Reeves. These questions could not be answered in the FoI application as the location of Gippsland Water groundwater bores where the levels were detected was not provided.

PFAS levels in groundwater appear to be increasing. On September 9 2023 groundwater was tested at 6 undisclosed locations. The highest PFAS loads occurred at one of these locations including a detection of PFHxA of 7.1μg/L. This was almost 18 times higher than the average PFHxA detection over the six year period.

Groundwater was also tested for at Dutson Downs IP in 2023. It is unclear if IP stands for Irrigation Ponds. Detections were all from four dates in 2023 and six unspecified locations. These average detection appear less than groundwater in general. Again, locations of the groundwater testing sites was not provided in the FoI response.

Dutson Downs appears to be located on sandy soils (Go:Sd) Gormandale Dunefield/Stockdale Undulating Plain. Sandy soils can be highly permeable, meaning that water can flow through them quickly. The soils north of Dutson Downs and Lake Coleman are (Ck). Crooke Alluvial Terrace. Are alluvium aquifers located under Dutson Downs?

Groundwater depth near Dutson Downs also appears to be very shallow 0.9-5mAHD (metres Australian Height Datum). Image source

Perched groundwater under the ExxonMobil Gas Plant, ~11km west of the main ponds at Dutson Downs, was found to be contaminated with PFAS in 2017. Groundwater, in the Boisdale Formation Aquifer (20m - 34 m deep) was also found to be polluted with PFAS from the Exxon Mobil Plant in 2017. Groundwater in the Boisdale Formation at Longford was assumed to move in a south easterly direction.

Overview of Gippsland region. Exclamation pin = Dutson Downs, 1 = Longford Gas Plant, 2 = Lake Coleman Air Weapons Range, 3 = RAAF facility at Sale, 4 = Maryvale Pulp Mill, 5 = Loy Yang Power Station. The blue pins represent to the locations of the 2 outfalls. The pin near Golden Beach is the main outfall at Delray Beach, the pin south of Seaspray is the saline outfall at McGaurans Beach which pipes saline water from (5) Loy Yang Power Station. Lake Coleman lies just south of Lake Wellington at the eastern edge of the Gippsland Lakes. Lake Reeve lies to the east of Dutson Downs and is not marked on the map.

Surface Water

PFAS detections in Dutson Downs water between 2017-2024 were dominated by PFOS. What percentage of PFAS detected in surface water is 'migrating' into groundwater? Are the ponds at Dutson Downs lined? The 99% ecological guideline level for PFOS is 0.00023μg/L.

PFOS detections in Dutson Downs water between 2017-2024 appear to have peaked in 2018. The highest detection on PFOS was on 20/2/18 at 90μg/L. 

PFOS levels between 2023-2024, whilst much lower than 2017-2018 are still significant and average 0.607μg/L. 

1= Exxon/Mobil Longford Gas Plant, A=Western Storage Pond, B=Saline Holding Pond, Bluepin=location of Golden/Delray Beach Main Outfall. Formation water is piped to Longford from offshore oil rigs where it is 'processed' at Longford. Saline water is then piped to Gippsland Water holding ponds, with some saline water piped out at Delray Beach. It appears that the formation water is not just saline water but it can be contaminated with PFAS chemicals (see graph below). 

Dutson Downs West Surface Water (A on map), PFAS average levels over 6 dates 2023/2024. PFHxA (Perfluorohexanoic Acid), does not appear to persistently bioaccumulate, as do PFHxS, PFOS and PFOA. This surface water appears to be most likely Exxon/Mobil  formation water. How did the PFAS end up in the formation/saline water? How long have PFAS chemicals been found in formation water and 'saline' pipelines?

Surface Water at Dutson West was only measured for PFAS on 5 dates between 2023/24. 79% of the total PFAS occurred on 23/1/23. Almost 17% of total PFAS occurred in detections on 21/5/24. How long was testing undertaken after formation water was piped from Longford? Have there been sporadically high releases of PFAS into saline water at Longford?

Information gleaned from another FoI application to Gippsland Water in 2021, located one round of testing at the Dutson Inlet to the Saline Treatment Pond (B on Map) in March 2017. Again the source of water that enters the Saline Treatment Pond is the pipeline from the Exxon/Mobil Longford Gas Plant. It appears from two FoI applications that this is the only test results from the Saline Treatment Pond. Both the Western Storage Pond and Saline Treatment Pond may have been contaminated with PFAS chemicals for decades.

Testing at Dutson Downs decommissioned pond in August 2024, revealed much higher levels of long chain PFAS chemicals PFOS and PFHxS. Is the decommissioned pond also a major PFAS source into groundwater?

Gippsland Regional Organics (GRO)

The Gippsland Regional Organics (GRO) facility. 234 documents in the Freedom of Information request were refused access by Gippsland Water - many of these documents probably related to GRO.

Nine groundwater sampling regimes were conducted under the GRO site between 2020-2023. PFAS was detected only on 3/1/22, with PFHxA detected at 0.005μg/L. GRO was commissioned 17 years ago in 2008. At this stage groundwater issues appear to be more related other unspecified locations on the 8,500ha Dutson Downs property. PFAS is definately at the GRO site having been detected in soil, puddles and drains.

Unverified soil (not biosolid) samples showing mixed measurements on some of the spreadsheets provided by Gippsland Water. Some were measured in ug/L others in mg/kg. The data on the graph is interpreted to be mg/kg. This could mean that PFAS average levels fall within NEMP Biosolids Threshold Restricted Use, however the samples provided appear to be taken after the soils has been mixed in. The ‘restricted use’ biosolids scenario in the HHERA (Human Health and Ecological Risk Assessment) assume that biosolids are land applied and incorporated into the soil for agricultural use. This means that biosolids have soil added to them to lessen levels of PFAS. Soil samples therefore leaving the GRO site will most likely contain traces of PFAS. 

PFAS detections at 6 locations at the GRO site in December 2023. Drain 1 (site location not specified in the FOI data) revealed excessively high PFAS detections, dominated by PFHxA at 23μg/L. 

PFAS was also detected in ponds in the GRO site in August 2024. Detections are dominated by short chain PFHxS.

Gippsland Water manage 10,000 hectares of farms across Gippsland (including the 8,500ha Dutson Downs site). The other 1500ha of farms are located at Drouin, Warragul, Mirboo North, Trafalgar, Moe, Morwell, Moondarra, Heyfield, Maffra, Stratford and Seaspray. Gippsland Water recycle 100% of their 19,690 tonnes of biosolids, plus an additional 6,300 tonnes from external water corporations and turn it into compost at the Gippsland Regional Organics Facility. These biosolids are then combined with 72,000 tonnes of green waste from Melbourne and surrounds to produce a compost which is then tested to Australian Standard (AS4454)* and sent to farms throughout Victoria.

Overview of Gippsland region. Exclamation pin = Dutson Downs, 1 = Longford Gas Plant, 2 = Lake Coleman Air Weapons Range, 3 = RAAF facility at Sale. Lake Coleman lies about 3km north of the main water ponds at Dutson Downs. Lake Coleman is a variably freshwater wetland (including salt marsh/estuarine scrub) that periodically dries out. Lake Wellington (surface area 148 sq km) is the shallowest of the Gippsland Lakes and has become increasingly saline over the years, due mainly to saltwater entering via the McLennan Strait near Seacombe. Lake Wellington and its fringing wetlands are the largest component of the RAMSAR site are is listed as being Nationally important. Lake Wellington Wetlands provide habitat for 45 threatened fauna species. 185 species of birds have been recorded in the area, including 87 wader species.

Most attention in terms of PFAS contamination of the Gippsland Lakes, has focused on the East Sale RAAF Base costing the Federal Government possibly tens of millions of dollars. Numerous consultant reports, with detailed scientific testing have been published. Soil remediation works at the base were completed in 2024 with approximately 22,000 tonnes of PFAS impacted soil treated. Remediation planning for other locations at Sale is ongoing. There has also been six community engagement sessions held, with the most recent in August 2018.  The Department of Defense found high levels of PFAS in fish, eels and ducks as early as October 2017. PFHxS+PFOS levels on the northern side of the Heart Morass were detected up to 70μg/L in 2020 in surface water. Generally, though PFHxS+PFOS levels 2016-2020 in Heart Morass were between 0.7μg/L to 7μg/L. PFAS has also been found in groundwater in three aquifers (onsite and offsite), the upper alluvium aquifer, lower alluvium aquifer and the Haunted Hills Aquifer.

According to the Department of Defence: "PFAS continues to be present in groundwater immediately Off-site at concentrations exceeding Drinking Water Criteria and ecological criteria . As groundwater is inferred to discharge to The Heart Morass, these impacts are also likely to contribute to the potentially elevated direct toxicity risk posed to ecological receptors within The Heart Morass." Source

In 2018 the EPA warned about carp, eel and ducks in the Heart Morass and Dowd Morass (Dowd Morass is about 12 km north west of Dutson Downs). In 2019 the EPA announced Health Advisories for consumption of water fowl from Heart Morass and Dowd Morass which are located approximately 7km south east of the East Sale RAAF base, a known PFAS contamination site. The EPA recommended that ducks from these locations should not be eaten. Lake Coleman was not included in the EPA study. The EPA also found traces of PFAS chemicals in sediment and water from Lake Wellington. Maximum PFHxS levels in Lake Wellington were 0.043μg/L, PFOA 0.0012ug/L and PFOS 0.004μg/L.

The Exxon Longford Gas plant, 10km west of Dutson Downs was the location of a tragic fire in September 1998. The site had already been known as a PFAS hotspot with farms and cattle being exposed to PFAS. PFAS had been used at the fire training site located adjacent to the plant since the 1960's. As already shown, supposedly saline water from Longford looks likely to also contain PFAS. It would also be interesting to determine if PFAS left the Longford plant and ended up at Dutson Downs from the fire itself or from past fire fighting activities. 

Burranan Dolphin. Image: Gippsland Lakes Environment Report 2021. The Burranan dolphin was first described in 2011. The dolphin inhabits the Gippsland Lakes and Port Phillip. In 2011 the Gippsland Lakes population was estimated to be 94 individuals (out of a total of 250). Remarkably the Burranan Dolphins have recorded the highest amount of PFAS of any dolphin population in the world and have been reported to be decreasing in numbers. What % of this PFAS came from the Sale RAAF Base or Dutson Downs?

Burranan dolphins have been found in close proximity to Lake Coleman near Boddy Bay in Lake Wellington. One animal located close to Lake Coleman was also included in the groundbreaking RMIT study into PFAS levels in Burranan dolphins.

Lake Coleman. What will testing reveal? Testing in 1994 revealed higher levels of dioxins than Dowds and Heart Morass.

Friends of the Earth is urging both the State and Federal Government's to urgently fund a study into PFAS contamination of Lake Coleman and a detailed hydrological study of PFAS contamination of Dutson Downs.

We are also urging people to sign onto this petition requesting a CSIRO audit of the Gippsland Lakes. The petition only takes a few minutes to complete.

For more information contact [email protected]

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