No Ship at Avoca

Lisa Corbyn
Director General
Department of Environment, Climate Change and Water
P.O. Box A290  SYDNEY SOUTH
N.S.W.  1232

Dear Ms Corbyn,

I am writing as a concerned resident of Avoca Beach on the N.S.W. Central Coast.

Earlier this year, as you may have been aware, there was an attempt by the N.S.W. State Government to scuttle the Ex-HMAS Adelaide 1.7km off Avoca Beach.

There have been other decommissioned warships scuttled around Australia, but none as close as this to a populated community and beach.

The community raised concerns about the presence of polychlorinated biphenyls (PCBs) and lead paint but were assured that these toxins were not present on the ship. Nevertheless, there was enough doubt to postpone the scuttling.

The hearing at the Administrative Appeals Tribunal (AAT) revealed the ship contains PCBs of unknown quantities (due to limited testing methods), and approximately 23 000 square metres of lead based paint. Curiously, four experts had signed off that the ship was free of lead paint in order to obtain a scuttling certificate.

The PCBs were mostly in the insulation of electrical cabling but also existed in gaskets, switchboards and fibreglass insulation.

The final ruling of the AAT was to remove further cabling and fibreglass to minimise the threat of PCBs but, unfortunately, will allow most of the lead paint to remain. It ruled to only remove any “exfoliating or exfoliated” lead based paint. Based on observation during a ship visit not much of the paint is in this condition so the majority will stay on the ship.

The State Government successfully claimed that the lead paint will not contaminate the marine environment.

Now this directly contravenes the Stockholm Convention. The Sea Dumping permit refers directly to this Stockholm Convention.

As a medical doctor I am seriously concerned about lead in the environment. The ramifications of lead toxicity in people, especially the developing nervous system of children, is catastrophic.

I don’t agree with the judgement that the lead will not contaminate the marine environment but more importantly, I believe the lead paint will directly contaminate the beach. This action is by the ship gradually disintegrating from the effect of the slow, oxidising elements of the ocean.

This could take one hundred years or much less because of the proximity to the oxygenated surf of the beach. Small particles of lead based paint will definitely make it to the sand of the beach, especially after large storms. Small children/toddlers are always eating sand, hence my concern.

At this very moment is the opportunity to clean the ship properly. Once it is scuttled, the only thing to do is to monitor lead levels, which is obviously too late. So I am asking you, are you happy with 23 000 square metres of lead paint being dumped at a popular iconic beach?

Can you do something about it?

Also, as the PCB discovery came after the removal of most of the electrical cables, I believe the PCBs in the cable insulation may have been dumped illegally. What has become apparent, in the ex-HMAS Adelaide case, is the lack of knowledge and concern of PCBs and their health consequences.

The insulated cables were recycled for their copper content, with PCB enriched waste as a by-product. Where did this waste end up? What about the safety of the handlers? There should be a paper trail throughout the handling of PCB contaminated material. Where is it? How did they handle the material once they knew PCBs were present (post March 27, 2010)? There should be a paper trail for that too.

PCBs can only be destroyed at 1100’C with only two accredited known furnaces in Australia able to do this. It is more than likely that the insulation was burnt off at a much lower temperature, with the remaining copper to be recycled. We know that over 72 tonnes of electrical cabling was removed, this represents a significant amount of PCB waste.

So, in conclusion, it would be medically negligent of me not to do something about the lead paint and PCB waste. I trust you will be able to achieve a positive outcome and prevent this environmental and health disaster.

Yours sincerely,
Dr David Steenbergen
Avoca Beach