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58

2011

DISHONORABLE DISPOSAL

reduce costs and protect the marine environment during fleet training exercises. Regardless of alternative target availability, the Navy still sunk 3 naval vessels as targets during RIMPAC 2010.

SINKEX is currently considered ocean dumping under the MPRSA and has been authorized under a general permit issued as an exception to the normal rules as long as appropriate measures are taken “to remove to the maximum

extent practicable all degrade the marine

materials which may environment.” As a

dumping

event,

the

London

Convention

prohibits the dumping of PCBs in any levels above trace amounts. Thus SINKEX is illegal under the London Convention.

Further, even by the terms of the general permit, the EPA’s allowance of solid-matrix PCB containing material with concentrations above 50 ppm can hardly be consistent with the remediation requirement of maximum extent practicable; and as the EPA explicitly states, the

Navy is only required

detachable

solid

PCB

to remove items”.166

“readily Readily

detachable or readily removable means items can be removed in a cost effective and efficient manner without the use of heat, chemical stripping, scraping and abrasive blasting or similar processes.167

In fact, the SINKEX general permit issued under 40 CFR 229 states “The Navy may leave in place wire cables, felt gaskets and other felt materials that are bonded in bolted flanges or mounted under heavy equipment, paints, adhesives, rubber mounts and gaskets and other objects in which the Navy has found PCBs…” This does not constitute removal to the maximum extent practicable. For the reasons cited above, the general permit should be revoked under MPRSA section 104(d), where EPA is to periodically review and revise permits

166 167

Navy Frequently Asked Questions, SINKEX

http://www.marad.dot.gov/documents/April2001ShipDisposalRe portToCongress.pdf

BASEL ACTION NETWORK

issued under the MPRSA. EPA has the authority to alter or revoke partially or entirely the terms of permits where it finds, based on monitoring data from the dump site and surrounding area that such materials cannot be dumped consistently with the criteria and other factors required to be applied in

evaluating a permit application Memorandum of Agreement).”

(1999

The EPA Office of Water, Wetlands and Watersheds stated that they were “prepared to revise the Navy permit, or revoke it, in the event that the results of further studies demonstrate an unexpected unacceptable risk to human health or the environment from SINKEX.” 168

The recent data from the Ex-ORISKANY sinking shows significant leaching of PCBs into the marine environment and provides the opportunity to revoke the general permit based on a government sponsored biological study.

The Navy is using inflatable and biodegradable balloons called killer tomatoes, as low cost targets for gunnery exercises during RIMPAC 2010. Unlike sunken naval vessels, biodegradable balloons are not known to leach toxic materials into the marine environment. Image Source: www.commons.wikimedia.org/wiki/Category:Killer_tomatoes

168 Official letter from Carol Browner, EPA Administrator, to Richard Danzig, Secretary of the Navy, September 13, 1999.

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