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Thiess/ former UCAL COI - Rebuttal Submissions

Final submissions to the Commission of Inquiry into the remediation of the Waterways owned former Unin Carbide site to be remediated by Thiess for redevelopment  by Trafalgar Properties and Multiplex:

Submission (Word 94kb)

Annexure with images used to illustrate the submission. (Word 370 kb)

The issues can be divided into two sections - those affecting Homebush Bay and those affecting the nearby residents.

A. Homebush Bay

There are 3 main issues with the scope of works in Homebush Bay

1. Too much dioxin is being left in Homebush Bay. 

The remediation will not meet the National Health and Medical Research Council limits for dioxin intake for keen anglers eating fish from Homebush Bay. The fish will continue to be contaminated, and, through the food chain, contaminating both fish eating birds and fish eating people.  From the table it can be seen that the bay is only proposed to be remediated to 2.33 ppb of dioxin residue. By doubling the area remediated and being more selective in the layout of the remediation area, the Bay could be reduced to 1ppb average by remediating about 12 hectares.  If the average residual dioxin in the Bay was reduced to 1 ppb there would be dramatically increased safety for fish, birds, and resident and non-resident anglers. In fact, based on the submissions to the COI by the proponents, and not disputed by NSW EPA, the fishing ban needs to be extended to cover probably all the river upstream of Homebush Bay, and down to Ryde traffic bridge to protect the thousands of new residents in the redeveloped Meadowbank Employment Area/Shepherds Bay area (particularly the old TEI/Plessey, Ryde council Depot and Hoover sites now under development)

The result is that residents can eat very little if any fish from Homebush Bay and keen non resident anglers would be at risk from regular fishing for consumption from Homebush Bay

2. Areas of the Bay with dioxin hotspots are being left and made more accessible due to the clean material being placed along the foreshore. 

Dr Swane in his written response to questions asked by Mr Hanly said: "The preferred remediation strategy will remove all surface and near surface dioxin contaminated sediments along the north-eastern foreshore of Homebush Bay so that the remediated sediments will have a concentration of dioxin-like substances less than 1mg TEQ/kg; " 
- what this does not acknowledge is that the areas in SE and SC sections of the Bay which will be made more accessible, but are not being remediated have significantly higher than 1 ppb residual dioxin after the remediation is complete and that the bay wide average of dioxin will be about 2.3 times the 1mg TEQ/kg that was originally proposed as the clean up standard.

3. The area of likely greatest human interaction with the sediments near the proposed Point Park and the Balxland Road Boat ramp has not even been tested

The area of likely greatest human interaction with the sediments near the proposed Point Park and the Balxland Road Boat ramp has not even been tested, let alone remediated, and is likely to have more dioxin in it than the proponents/Waterways' own expert acknowledges is the generally accepted standard for ensuring no long term harm. (See right hand side of map above):
Dr Swane in his written response to questions asked by Mr Hanly said: "Health studies undertaken by the WHO in 1988 concluded that the life-time intake of dioxin-like substances from dermal contact with soils (and sediments) at low concentrations (ie. less than 1 mg TEQ/kg) will be minor;"

4. The fishing bans will need extending into the Parramatta River particularly near Meadowbank and the Shepherds Bay developments.

Based on submissions made during the COI it appears that because dioxin tolerable intakes have decreased by over 75% since the ban was originally introduced (WHO 1990 = 10; NHMRC 2002 = 2.3) and because the scop of works of the bay remediation is so limited (it wasn't increased when the dioxin intake limits were reduced) the current total fishing ban in Homebush Bay probably needs to be extended to cover all the River upstream of Ryde Traffic Bridge.

B. Impact on Residents

Read the main submission and annexure (Download using the links at left)

The main issues for existing residents are cumulative impacts of dust noise and odour, particularly for those residents who live in Blaxland Road in the area opposite the boundary of the Meriton and Waterways sites, as they will be affected by two lots of emissions during both construction and remediation.

Purchasers of units proposed for development in Marquet, Gauthorpe and Walker Street are also likely to suffer impacts of noise, dust and odour, (diminishing with distance from the UCAL site) particularly those in the Statewide development on the former Glad factory in Marquet Street and even more particularly for those facing Gauthorpe Street.