Ship Decommissioning Industries S.A.S - 48, rue de la Bienfaisance - 75008 PARIS
Tel : +33 145 621 563 - Fax : +33 145 621 318
info@sdi-holding.com
R.C.S PARIS : 485 313 902 00010 - Code APE : 900G

Paris, July 16th, 2006

Secretary of Ministry of Environment

Dr. Pradipto Ghosh
Secretary
Government of India, Ministry of Environment and Forests
Paryavaran Bhavan,
CGO Complex, Lodhi Road,
New Delhi 110 003
Tel: +91 11 24360605
+91 11 2436 1147
e-mail: envisect@nic.in

Ref. S/S Norway; ex France to be broken-up at Alang shipbreaking yards

Dear Honourable Sir,

We allow us to write you in the matter of the scrapping of the S/T Norway and the contemplated intention of the new ship owners of taking the ship to Alang shipbreaking yard.

Our technical team has carefully inspected and surveyed the subject vessel in Bremerhaven / Germany before the ship was towed to Malaysia and ultimately to India. Based on the survey report further enquiries were made on the ship documents and on the best process to be set-up for a safe hazardous wastes removal on board of this very particular ship.

The former owners M/S Star Cruises were possibly aware of the fact that a sound and safe de-pollution of the ship would have requested an important budget and that only very well trained and experienced team could properly handle this large quantity of asbestos and this variety of hazardous substances being on board. This assertion is based on the various green recycling projects we have been handling within last years including the Aircraft Carrier Clemenceau project.

The situation of the ship is in deed very worrying in the way that she may contain around 1.200 metric tons asbestos -as per builders estimations- (significant portion of this asbestos being directly friable) and that due to an explosion in the engine room, part of this asbestos has been released in the atmosphere spoiling the air and actively polluting several decks. On the top of that our team could identify the following hazardous substances: Cadmium, Azocolourants, Azodyes, Chromium compounds, Mercury compounds, Polybrominated Dephenyl Ethers (PBDE), Polybrominated Biphenyls (PBB’s), Polycloinated Bephenyls (PCB), Tributyls, Heavy Metals, Hydraulic and Lubricating oils and various other hazardous substances and materials.

We do not want to interfere at all in your investigations and analyses in this matter. However we feel concerned for two main reasons:

- We know quite precisely what type of hazardous materials and substances are still on board and about the active asbestos pollution. We feel it is our duty to share with you our concerns.

- Nowadays ship scrapping has experienced to be an industry enjoying unfortunately a very bad reputation as no care is really taken of the safe de-pollution of ship to be scrapped. We are convinced that a large pollution may result if the de-pollution is not properly handled jeopardising human life of workers. This would be a disaster for the workers but also for the credibility and image of this industry. As such this would have collateral damages to all companies involved in this industry.

We therefore kindly request you Honourable members of the SCMC to make sure that a real de-pollution scheme shall be set-up including the use of all necessary equipments and technologies by a qualified and experienced team of dedicated workers. We are ready to get to India to testify before your learnt and Honourable committee.

We shall pay a deep attention to this project and of course would use all legal means in India and before the Basel convention and IMO in order to make sure that this project will not damage the reputation and credibility of this industry.

Yours Faithfully,
Ship Decommissioning Industries SAS

Briac BEILVERT
Chief Executive Officer