22 March 2010
The Hon. Peter Garrett AM MP
Minister for the Environment Protection, Heritage and the Arts
PO Box 6022
Parliament House
CANBERRA ACT 2600

Re: Ex-HMAS Adelaide proposed scuttling off Avoca Beach

Dear Minister,

We are writing to you as a matter of urgency to express our deep concern over the proposed scuttling of the Ex-HMAS Adelaide off Avoca Beach.

Having recently reviewed footage of the ship’s interior it appears that all fittings and sources of pollution have not been removed with seating, circuit boards including wiring, and considerable amounts of plastic and peeling paint still remaining on board.

The public has not been independently reassured that all toxic chemicals all have been removed. We don’t want a toxic time bomb sitting on the ocean floor close to shore as yet another toxic gift to our grandchildren.

While there has been focus on PCBs the follow up to ensure all PCBs were removed was inadequate. Five samples for only 6 congeners were taken from insulation, which is not expected to contain PCBs. Why was there such a small sample and only looking at 6 congeners?

Furthermore, there has been no testing, as far as we can ascertain, for the recently banned persistent organic pollutants (POPs), Pentabromodiphenyl ether (C-PentaBDE) and Octabromodiphenyl ether (OctaBDE) or heavy metals.

It is highly likely that these new POPs chemicals will still be contained in fittings and building materials including foam fillers, insulation boards, foam insulation, piples, wall and floor panels, plastic sheeting, resins, rigid polyurethane, polyurethane foam, elastomer instrument casings, acrylonitrile-butadiene-styrene (ABS), thermoplastics for business machine housings and motor housing; or as a fire retardant in coatings and lacquers.

Penta and OctaBDE became widely available around 1970 and were extremely popular as flame-retardants in planes, boats and homes. The use of PentaBDE in ships is specifically referenced in the Risk Profile document prepared by the UN POPs Review Committee.

The Australian government has an obligation to ensure these POPs chemicals listed under the Stockholm Convention are not left on board where they will leach into the environment.

NTN is also concerned about the asbestos likely to be remaining in the ship’s insulation. As far as we can ascertain there are no publicly available environmental fate studies on the potential erosion of asbestos sheating or insulation in ocean waters. Yet, we are aware of studies demonstrating the contamination of drinking water with asbestos fiber concentrations above 10 million fibers per litre (Millette et al., 1980) due largely to contamination or erosion of the asbestos water pipes.

There appears to have been no monitoring on what happens with the action of sand and water currents on asbestos and any subsequent erosion, despite the detection of asbestos fibres in the ocean waters.

Reports of an unpublished USEPA study (Muir, EPA 2003) of dumped subway cars on an artificial reef off Delaware in 2002 stated that asbestos levels in ocean water did not exceed naturally occurring background levels however, these were not accompanied by samples from the surrounding environment, that is from sand, coral, fish and the investigations were carried out only a few years after the dumping and certainly prior to the rusting of the infrastructure, which would make the asbestos more available for the action of sand and water currents.

Several studies have investigated the effects of asbestos on fish and the findings indicate that asbestos may cause epidermal lesions, epithelial hypertrophy, kidney damage, decreased orientation and swimming ability, degradation of the lateral line, reduced growth, and increased mortality in fish.

The researchers concluded that chrysotile asbestos may represent a significant environmental hazard, especially to young fish, and that asbestos should receive greater attention than it has historically received. While these laboratory studies have demonstrated deleterious effects of waterborne asbestos on individual aquatic organisms, ecosystem-wide effects are largely unknown and there appear to be no studies looking at fish feeding on reefs with dumped asbestos.

Research has also demonstrated that asbestos contamination of household water leads to increased airborne asbestos (Webber et al., 1988) and aerosols often include asbestos, particularly in polluted areas.

Our concern is that if asbestos fibres are released into ocean waters close to shore as in the case of artificial reef building, there is a serious risk of these being incorporated into ocean water aerosols (eg surf). While we acknowledge the time required for erosion and release of the asbestos fibres may take some time, the eventual breakdown into smaller fibres may be inevitable leaving yet another toxic gift to our grandchildren.

We urge you to withhold the authorisation certificate for the Ex HMAS Adelaide until these issues have been fully and independently addressed.

Yours sincerely

JO IMMIG
Coordinator
National Toxics Network
http://ntn.org.au

CC The Hon. Tony Kelly, NSW Minister for Planning, Minister for Infrastructure, Minister for Lands