Defence National
Environmental
Standard
Standard for the Prevention and Management of
Pollution from Aqueous Film Forming Foam
Quality information
DNES Approver
DNES Exemption
Approver
This DNES takes effect from the Date of Issue
Document number
Revision
DNES Owner
Date of Issue
Date of Next Revision
DNES Endorsers
Terms, definitions and acronyms
Standard definitions for key terms (including acronyms where applicable) are included in the
table below.
Table 1
Key terms, definitions and acronyms
Term
Acronym (if
applicable)
Definition
Aqueous Film
Forming Foam
AFFF
Fluorinated water based hydrocarbon designed to suppress combustion and used in
fighting aircraft and class B fires
Base Support
Manager
BSM
Under the Base Accountabilities Model, a BSM is the DSRG representative accountable
for delivery of base support management and services, including integrated delivery of
agreed support services, for a given base.
Defence
Environmental
Management
System
EMS
The Defence EMS operates in support of the Defence Environmental Strategic Plan
2010-2014 and aims to deliver environmental services in an integrated and systematic
manner to support ADF capability.
Defence Estate
Land owned, leased or used by the Department of Defence.
Defence
National
Environmental
Standard
DNES
A set of quality or performance conditions specifying Defence’s minimum acceptable level
of environmental management for an environmental factor, activity or process.
Directorate of
Energy
Efficiency and
Resource
Management
DEERM
Directorate within Environment and Engineering (E&E) branch of DSRG Infrastructure
Division, responsible for policy and technical advice relating to energy efficiency and
resource management, including pollution prevention.
Directorate of
Environmental
Remediation
Programs
DERP
Directorate within Environment and Engineering (E&E) branch of DSRG Infrastructure
Division, responsible for policy and technical advice relating to management and
remediation of contaminated sites.
Environment
Environmental
Clearance
Certificate
Surroundings in which Defence personnel and its contractors operate, including air,
water, land, natural resources, heritage, flora, fauna, humans, and their interrelation.
ECC
Document that details a planned activity, mitigation measures relevant to the planned
activity and sets out conditions to minimise the likelihood of significant environmental
impacts arising. ECCs are used by exception in instances where the planned activity is
not fully covered by existing operational controls.
Estate
Maintenance
and Operations
All services delivered by the Base Services Contractors and subcontractors. Includes
design, planning and activities associated with Estate Appraisal and Risk Managed
works.
Health Based
Value
A specified concentration of AFFF in water designed to ensure protection of human
health to a 95% statistical confidence level
Health Risk Limit
A specific concentration of AFFF in water above which is likely to cause harm
Incident
Any occurrence that can result in an impact or impacts on the environment. This includes
incidents, complaints, near misses, observations and non-conformances.
Incident Form
Electronic Form linked to the Incident Register, where information on the incident and
associated actions are recorded. The Incident Form comprises three parts:
-
Part A: First stop form completed by Originator to capture initial information about
an incident;
-
-
Part B: Review and verification of initial information; and
Part C: Form used to guide and document the findings of an investigation into an
incident and prescribe subsequent actions.
Nonconformance
An action or omission that did not meet Defence’s environmental operational controls
including Defence Instructions, Defence Environmental Standards, Environmental
Clearance Certificate conditions, Range Standing Orders, Standard Operating
Procedures; or an action or omission that did not meet external conditions placed on
Defence.
Operational
control
(environmental)
Measures applied to activities, products and services to prevent, or reduce the extent of,
environmental impact.
Acronym (if
applicable)
Term
Personnel
Definition
Members of the Australian Defence Force (ADF), members of the Australian Public
Service (APS) employed by Defence, contractors/subcontractors and/or consultants
performing work or providing services for Defence, and third parties or other visitors to
the Defence Estate.
Regional
Environment
Officer
REO
Supports and represents the Senior Environment Manager at bases and groups of bases.
Senior ADF
Officer
SADFO
Under the Base Accountabilities Model, the role of SADFO is an additional role for an
appointed senior military officer on a given base. SADFOs are required to provide broad
leadership to all military staff on the base, consistent with the Chief of Defence Force’s
expectations of all senior ADF officers.
Senior
Environment
Manager
SEM
Senior professional advisor for environmental matters in a DSRG region, advising
Defence personnel including senior Commanders and managers. Leads the
environmental team and manages the regional implementation of national strategic
programs.
Standard
Operating
Procedures
SOP
Operational control that specifies how a standard activity should be undertaken. This may
include specific requirements to minimise WHS and environmental risks. Initial incident
responses may also be detailed for certain activities.
Standing Orders
Technical
Authority
Operational control that provides enforceable instructions relevant to a Defence Property.
Traditionally, environmental instructions are included as Chapter 13 in Range Standing
Orders. Standing Orders may sometimes be referred to as Standing Instructions by some
services.
TA
Primary source of technical guidance for a given subject matter area.
Purpose
1.
The purpose of this DNES is to establish the minimum performance
requirements for the prevention and management of pollution caused by
Aqueous Film Forming Foam (AFFF) on the Defence Estate
Scope
2.
This DNES applies to all Defence Establishments where fixed and mobile AFFF
firefighting systems are present. This DNES also applies to all establishments
containing fire training grounds, AFFF storage and distribution sites and sites
involved in the transport of AFFF substances.
3.
This DNES does not apply to AFFF wastewater retention ponds or existing
areas of AFFF pollution/contamination (inclusive of soil, surface water and
groundwater) for which the responsible authority is the Defence Environmental
Remediation Program (DERP).
Related Defence Standards
4.
Stormwater DNES.
5.
Wastewater DNES.
6.
DNES – EP3: Environmental Incident Management.
7.
Refer to the DNES Register on the Defence EMS Website for a list of all DNES
and their current development status.
Performance Requirements
8.
In accordance with policy management principle 1, performance requirements
for AFFF pollution prevention are governed by the principle of zero
environmental release and must follow the precept of Prevention,
Preparedness, Response and Recovery (P2R2). All AFFF pollution
prevention measures must aim to meet the requirement for zero environmental
release before applying the P2R2 hierarchy.
9.
For the purposes of defining AFFF pollution, Defence has adopted the
Minnesota Department of Health (MDH) Health Risk Limits (HRL) and Health
Based Values (HBV) for PFOS, PFOA, PFBA and PFBS in water.
10. For soil environments, Defence has adopted the soil reference values set by the
Minnesota Pollution Control Agency.
11. The key performance requirement is that all establishments actively work to
reduce the requirements to store and use AFFF to as low as reasonably
practicable. All minimum performance levels are targeted to reduce the
possibility of AFFF pollution from Defence activities to as low as reasonably
practicable.
COMMERCIAL-IN-CONFIDENCE
Minimum Performance Levels – Prevention
12. In accordance with policy management principle 1, every opportunity to reduce
or eliminate the requirement for fixed or mobile AFFF systems must be
identified so as to reduce potential sources of AFFF pollution to as low as
reasonably practicable (ALARP). Refer to the Defence Manual of Fire
Protection Engineering for further guidance on engineering controls.
13. Areas where AFFF is stored or used must be registered as a potential pollution
source in the base stormwater pollution source register.
14. In accordance with policy management principle 2, AFFF system testing
(including mobile vehicles) must be conducted using water only unless system
testing requirements specify the use of AFFF. Whether or not AFFF is
specifically required for system operability testing, in order to prevent water
contamination with residual AFFF in the system, such testing must take place in
an area where the release will be contained.
15. In the case of a fixed system which requires charging with AFFF to meet test
objectives, all drainage lines in the vicinity of the system must be closed,
blocked or otherwise isolated to prevent AFFF ingress during the test. Upon
completion, the Immediate Actions for AFFF Pollution Response must be
implemented.
16. The system test must at a minimum be notified to the establishment REO and
be accompanied by an Environmental Clearance Certificate (ECC) confirming
that that AFFF pollution controls are in place. The ECC must document any
quantities of AFFF used and the quantity of water used in the test (whether it
contains AFFF or not).
17. Testing of mobile systems must only take place in a concrete area which has no
connection to any stormwater drain, drainage channel or natural water course
so as not to cause a pollution event.
18. Water used during system testing, unless specifically confirmed to not contain
AFFF exceeding the adopted guidelines, is to be contained and stored onsite in
an AFFF wastewater retention pond (if present) or liquid waste storage area for
later disposal.
19. The technical integrity of fixed systems must be audited in accordance with the
system requirements to ensure the likelihood of an accidental release is
minimized.
20. In accordance with policy management principle 4, non-approved and
superseded AFFF inventory must not be used under any circumstances.
21. In accordance with policy management principle 5, AFFF must only be used for
fighting class B fires and must not be used in training environments unless
required by a specific training objective.
COMMERCIAL-IN-CONFIDENCE
6
COMMERCIAL-IN-CONFIDENCE
Minimum Performance Levels – Preparedness
22. In accordance with policy management principle 1, the following performance
levels will ensure the zero release principle is maintained:
a. Users of AFFF mobile and portable systems must be trained in the safe
and environmentally appropriate use of the systems. This training must
include the environmental impacts of AFFF, its toxicity, persistence and
presence as an existing pollutant on the Defence Estate. The training
must also include measures for containment and clean-up of AFFF.
Emphasis must be placed on the need to use AFFF only if absolutely
necessary.
b. Users of AFFF spill response equipment must be trained to effectively
deploy and manage such equipment.
c. Records of AFFF system integrity tests must be maintained as per
system requirements and defects reported via GEMS.
d. A concrete bund, pad, pit or similar area not serviced by drainage lines
or containing any permeable surface where any planned AFFF release
can be contained.
e. Mobile AFFF containment equipment such as booms, interceptors,
drain blockers, soaker pads, socks and pillows must be located in areas
with fixed systems and present in mobile systems (i.e. fire fighting
trucks).
f. Appropriately bunded bins or storage containers in which impacted
AFFF clean up equipment can be stored safely prior to disposal.
g. All drains in areas where AFFF is stored or used must be colour coded
and marked with where they drain to (in accordance with the
stormwater and wastewater DNES). All such drains must be augmented
with apparatus to prevent AFFF ingress or be fitted with AFFF
interception devices in the event of an AFFF Release. Such interception
equipment must be so fitted to ensure that any release is suitably
contained.
h. All AFFF storage drums must be stored in bunds specifically designed
for AFFF, are fit for purpose and which will contain 110% of the total
quantity of the container.
Minimum Performance Levels – Response
23. To comply with policy management principle 3, every Defence Establishment at
which AFFF fixed and mobile systems are present must have an AFFF
Response and Recovery Plan (RRP) which details the means by which AFFF
releases are contained, managed and cleaned up. The plan must identify
responsibilities for AFFF pollution response, the inventory holdings of pollution
prevention and clean up equipment (and types of equipment required), typical
AFFF inventory holdings, details and locations of fixed and mobile systems and
AFFF inventory and system custodians.
COMMERCIAL-IN-CONFIDENCE
7
COMMERCIAL-IN-CONFIDENCE
24. Whilst there is no standard format, the plan must be so developed to enable the
implementation of the management principles contained in the AFFF Pollution
Prevention Policy and the minimum performance levels contained in this DNES.
25. Establishments where a contained AFFF release has occurred must act to
ensure that AFFF does not enter the natural environment by applying the AFFF
Response and Recovery Plan to contain and clean up the release.
26. Establishments where a pollution event has occurred must complete the
following Immediate Actions for AFFF Response and Recovery:
a. Act to contain the release by preventing its spread, reducing its physical
area, isolating it from sensitive environments or cleaning it up.
b. Containment measures must ensure that rain, wind and weather events
do not appreciably contribute to the further spread of the release, the
principal governing factor being preventing the release entering a
sensitive environment.
27. Clean-up activities must aim to remove 95% or greater of the total AFFF
quantity released. AFFF pollution events must be promptly reported in
accordance with standard Defence environmental incident reporting
procedures. The SEM or REO is to determine whether the incident is required
to be reported to state or Commonwealth environment agencies.
Incident, Emergency and Non-Conformance
28. Incidents and emergencies must be responded to in the manner contained in
the AFFF Pollution Response and Recovery Plan, guided by the Minimum
Performance Levels described above.
29. Non-conformances must be documented and corrective actions implemented to
ensure conformance with the Minimum Performance Levels. This is contained
in the monitoring, audit and review section below.
Monitoring, Audit and Review
30. To ensure that each establishment maintains the capability for responding to
AFFF releases, periodic audit of AFFF pollution prevention equipment must be
carried out. As a minimum, the following must be incorporated into the AFFF
Management Plan:
a. Provision for a yearly muster of all AFFF pollution response equipment
at the establishments, against the identified requirements in the AFFF
Management Plan.
b. A post release muster of AFFF pollution response equipment.
c. Monitoring of the effectiveness of AFFF response and recovery
activities during emergencies and training events. Such monitoring is to
COMMERCIAL-IN-CONFIDENCE
8
COMMERCIAL-IN-CONFIDENCE
focus on the extent of compliance with the Minimum Performance
Levels (to be conducted after each release, regardless of the cause).
31. Auditing of the AFFF Management Plan, Response and Recovery Plan and
post event auditing must be undertaken annually and assessed against the
minimum performance levels specified in this DNES. Audit non and partial
compliances are to be recorded and corrective actions implemented to bring
compliance up to the standards required by this DNES.
Reporting – Post Release
32. All AFFF spills and incidents must be reported in accordance with Defence
pollution reporting guidelines. The SEM or REO is to determine whether the spill
or incident has resulted in a pollution event or presents a risk to a state
regulated environment that requires reporting to an external authority.
33. AFFF pollution events must also be referred to DERP as the technical authority
on the management and remediation of site contamination.
Reporting – Policy and DNES Compliance
34. Establishments are to report on their compliance with the minimum performance
levels listed above. Reporting is to be brief and factual and to consist of the
following:
a. A qualitative estimate of per cent compliance with each minimum
performance requirement.
b. Actions outstanding per performance requirement that are needed to
reach 100% compliance.
c. A short summary of any pollution incidents and their causes.
35. Reporting should be in accordance with existing periodic environmental
reporting practices.
User Feedback
36. Personnel are encouraged to provide feedback on this DNES. Feedback will be
used to inform future versions of this document, which is reviewed at regular
intervals as part of the Defence EMS continual improvement process.
37. Provide
any
feedback
on
this
DNES
via
email
to
environmentandheritage@defence.gov.au. Please include the DNES title in the
subject line of email/feedback.
COMMERCIAL-IN-CONFIDENCE
9