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  Draft National Guidance: Best Management Practices for
    Preparing Vessels Intended to Create Artificial Reefs
                         June 24, 2004
U.S. Environmental Protection Agency      U.S. Maritime Administration
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                           ACKNOWLEDGEMENTS

The U.S. Environmental Protection Agency's Oceans and Coastal Protection Division within the
Office of Water developed this document with direct support from the Department of
Transportation's Maritime Administration.  To assist in document development, an interagency
workgroup was established.  The following agencies actively participated on this workgroup:

                   •   Department of Transportation's Maritime Administration
                   •   National Oceanic and Atmospheric Administration
                   •   United States Army Corps of Engineers
                   •   United States Fish and Wildlife Service
                   •   United States Coast Guard
                   •   United States Department of the Navy
                   •   United States Environmental Protection Agency
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                            TABLE OF CONTENTS

Executive Summary       	   5

Introduction              	   7

Siting of Artificial Reefs   	   11

Guidance for Preparing Vessels to Create Artificial Reef Habitat
      Oil and Fuel
            Narrative Clean-up Goal	  15
             Environmental Impacts      	   15
            What are oil and fuel?	   15
            Where are oils and fuels found in a ship?    	   16
            Vessel Preparation   	   16
      Asbestos
            Narrative Clean-up Goal	  21
             Environmental Impacts	   21
            What is asbestos?	   21
             Where is asbestos found on a ship?	   22
             Vessel Preparation	  23
      Polychlorinated Biphenyls (PCBs)
            Narrative Clean-up Goal	  25
             Environmental Impacts	   25
             What are PCBs?	   25
             Where are PCBs found on a ship?	   25
             Vessel Preparation	   26
      Paint
             Narrative Clean-up Goal	28
             Environmental Impacts	   28
             What types of paint and anti-fouling systems are used
                   on ships and where are they found?	   28
             Vessel Preparation	   28
      Solids/Debris/Floatables
            Narrative Clean-up Goal	30
             Environmental Impacts	   30
             What are solids/debris/floatables?	  30
             Where are solids/debris/floatables found on ships? .  ...  31
             Vessel Preparation	  31
      Other Materials of Environmental Concern
             Narrative Clean-up Goal	32
             Environmental Impacts	   32
             What are other materials of environmental concern?  ...  32
             Where are other materials  of environmental concern
                   found on ships?	   32
             Vessel Preparation	  32


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Considerations for In-water Uses of Obsolete Vessels
       Diving Opportunities	   35
       Breakwaters/Barriers	   36
Exhibit 1:  Summary of Narrative Clean-up Goals for
      Materials of Concern	6
Appendix A: National Defense Authorization Act, Fiscal Year 2003,
       Section 3504	   37

Appendix B: Some Legal Authorities that May Apply to Vessel to
       Reef Projects	   40

Appendix C: Information Related to Materials Found on Scuttled Vessels
       that may have Potentially Hazardous Effects on the
       Marine Environment	43

Appendix D: Developing Workplans for Vessel Preparation
       Prior to Reefing	47

Appendix E: General  Principles for a Vessel Clean-up Operation	49

Appendix F: Suggested Cleaning Methods for Oil and Fuel	50

References	53
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                               EXECUTIVE SUMMARY

This guidance document was developed in response to the Maritime Administration's (MARAD)
request for the U.S. Environmental Protection Agency (EPA) to provide national
environmentally-based best management practices for the preparation of vessels to be sunk with
the intention of creating artificial reefs in permitted artificial reef construction areas.  It also
satisfies the mandate of Section 3516 of the National Defense Authorization Act for Fiscal Year
2004, which requires that MARAD and EPA jointly develop guidance recommending
environmental best management practices to be used in the preparation of vessels for use as
artificial reefs.

Options for managing obsolete and decommissioned military and commercial vessels include re-
use of the vessel or parts of the vessel, recycling or scrapping, creating artificial reefs, and
disposal on land  or at sea. This document discusses the preparation of vessels when employing
the vessel management option of artificial reefing.  Artificial reefs should be developed such that
they enhance marine resources and benefit the marine environment. Strategically sited artificial
reefs can not only enhance aquatic habitat, but also provide an additional option for conserving,
managing, and/or developing fishery resources.

Although the best management practices presented in this document are intended for use when
preparing vessels to serve as artificial reef habitat, the best management practices may have
applicability to other in-water uses of vessels, such as the creation of recreational diving
opportunities and placement as breakwaters or other types of barriers.  It is recommended that
these best management practices be implemented for all in-water uses of vessels, with the caveat
that further vessel preparation beyond mat employed for artificial reef habitat may be needed.
When preparing  a vessel for other permitted in-water  uses, consideration should be given to
vessel stability and integrity prior to and after final placement.

This guidance identifies materials or categories of materials of concern that may be found aboard
vessels and specifically identifies where they may be found.  For each material  or category of
material, this document provides a general clean-up performance goal and information on
methods for achieving those goals in preparation of the vessel prior to sinking.  Materials of
concern include, but are not limited to: oil and fuel, asbestos, poly chlorinated biphenyls (PCBs),
paint, solids/debris/floatables, and other materials of environmental concern. Exhibit 1 provides
a summary of the narrative clean-up goals for materials of concern.

This guidance does not substitute for any statute or regulation, nor is it a regulation itself. It does
not impose legally binding requirements on any Federal agency, States, other regulatory
authorities or the regulated community, and may not apply to a particular situation based upon
the circumstances. Regulatory decision makers, both  Federal and State, retain the discretion to
adopt approaches on a case-by-case basis that differ from this guidance where appropriate. EPA
may change this  guidance in the future.
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        Exhibit 1. Summary of Narrative Clean-up Goals for Materials of Concern
Material of Concern
Oil And Fuel
Asbestos
Polychlorinated
Biphenyls (PCBs)
Paint
Solids/Debris/
Floatables
Other Materials of
Environmental Concern
':>-',' * ^«*»th»€IeM*«.€&«P, /*.-lr'/\r*i
Remove liquid hydrocarbons (fuels, oils) and semi-solids (greases) so that:
no visible sheen is remaining on the tank surfaces (this includes all interior
fittings, piping, structural members) or on the water surface when the
equipment is flooded after sinking; no film or visible accumulation (i.e.,
spills on decking or rugs) is remaining on any vessel structure or component.
Remove any loose asbestos and asbestos that may become loose during
vessel sinking; remove or seal accessible friable asbestos.
Remove all solid material containing PCBs greater than or equal to (^:) 50
parts per million (ppm) unless a disposal permit has been granted under 40
CFR 761.62(c); remove all liquid materials containing PCBs.
Remove harmful exterior hull antifouling systems that are determined to be
active; remove exfoliating and exfoliated paint.
Remove loose debris, including materials or equipment that are not
permanently attached to the vessel that could be transported into the water
column during a sinking event.
Remove other materials that may negatively impact the biological, physical,
or chemical characteristics of the marine environment.
There are statutory requirements and associated regulations, as well as permit processes
applicable to the process of preparing a vessel for reefing that are not highlighted in this
document The narrative clean-up goals for the materials of concern highlighted in this guidance
should be achieved while preparing a vessel for all in-water uses as earlier mentioned.
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                                  INTRODUCTION

Several options exist for managing obsolete and decommissioned military and commercial
vessels. These options include re-use of the vessel or parts of the vessel, recycling or scrapping,
creating artificial reefs, and disposal on land or at sea.  This document discusses the vessel
management option of artificial reefing. This guidance document was developed in response to
the Maritime Administration's (MARAD) request for the U.S. Environmental Protection Agency
(EPA) to assist in identifying potential management options for their decommissioned vessel
fleet  It also satisfies the mandate of Section 3516 of the National Defense Authorization Act for
Fiscal Year 2004, which requests that MARAD and EPA jointly develop guidance
recommending environmental best management practices to be used in the preparation of vessels
for use as artificial reefs.

An interagency workgroup, chaired by EPA, was established to develop national
environmentally-based best management practices for the preparation of vessels to be sunk with
the intention of creating artificial reefs in permitted artificial reef construction areas. The
workgroup was comprised of representatives from the EPA, U.S. Coast Guard, U.S. Navy,
MARAD, U.S. Army Corps of Engineers, National Oceanic and Atmospheric Administration,
and the U.S. Fish and Wildlife Service.

Although these best management practices are intended for use when preparing vessels to serve
as artificial reef habitat, such best management practices may have applicability to other in-water
uses of vessels, such as the creation of recreational diving opportunities and placement as
breakwaters or other types of barriers.  The best management practices presented in this
document should be implemented for all permitted in-water uses of vessels; further vessel
preparation may be needed based on the intended in-water use, such as breakwaters.
Objectives of the Guidance Document

This guidance satisfies the mandate of Section 3516 of the National Defense Authorization Act
for Fiscal Year 2004, which amends existing law to require that MARAD and EPA jointly
develop guidance recommending environmental best management practices (BMPs) to be used
in the preparation of vessels for use as artificial reefs. These BMPs are to serve as national
guidance for Federal agencies for the preparation of vessels for use as artificial reefs. Section
3516 provides that the BMPs are to (1) ensure that vessels prepared for use as artificial reefs
"will be environmentally sound in their use as artificial reefs"; (2) "promote consistent use of
such practices nationwide"; (3) "provide a basis for estimating the costs associated with the
preparation of vessels for use as artificial reefs"; and (4) include measures that will "enhance the
utility of the Artificial Reefing Program of the Maritime Administration as an option for the
disposal of obsolete vessels." Appendix A provides further detail on Section 3516, and below is
a description on how this document addresses the four requirements of the statute.

   •   The use of this guidance will ensure that vessels prepared for use as artificial reefs "will
       be environmentally sound in their use as artificial reefs." Best management practices are
       provided through performance goals that are directed at the level of cleaning and/or
       removing materials of concern aboard vessels. The preparation of vessels in this manner

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       will ensure that their use as artificial reefs is environmentally sound. The purpose of
       creating an artificial reef is to benefit the environment by enhancing aquatic habitat and
       marine resources, as well as providing an additional option for conserving, managing,
       and/or developing fisheries resources. This document describes appropriate vessel
       preparation that could achieve such benefits as an artificial reef and avoid negatively
       impacting the environment with pollutants. The performance goals provided in this
       document, if implemented and complemented with strategic siting, will maximize the
       opportunity for these vessels to benefit the environment as artificial reefs.

   •   The use of this guidance document will "promote consistent use of such practices
       nationwide" and in turn will also provide measures that will "enhance the utility of the
       Artificial Reefing Program of the Maritime Administration as an option for the disposal
       of obsolete vessels." The best management practices described in this  document will
       serve as national guidance for the preparation of vessels for use as artificial reefs. As the
       use of vessels as artificial reefs is becoming a more common management option for
       obsolete MARAD vessels, the development of this guidance document is timely.
       Currently, no guidance of this kind is available.  The use of this-guidance document can
       enhance the utility of MARAD's Artificial Reefing Program by establishing a national
       approach to clean and prepare candidate obsolete vessels, while also promoting consistent
       use of such practices for vessel-to-reef projects.

   •   The use of this document will "provide a basis for estimating the costs associated with
       the preparation of vessels for  use as artificial reefs." Neither worker safety issues nor
       specific costs associated with clean-up procedures are discussed in this document; this
       document only addresses environmental impact and protection issues.  Although the best
       management practices were developed independent of worker safety issues and specific
       costs associated with clean-up, the guidance in this document can be used as a tool in
       estimating the cost for appropriate vessel preparation.  The methods, approach, and level
       of effort for clean-up, as well as worker safety concerns, are directly dependent on the
       vessel's condition and the amount of materials of environmental concern that are found
       aboard.  Vessels that pose potential safety risks would be expensive to clean and
       therefore may not be good candidates for reefing.

       Some portions of a candidate vessel may be economically salvageable.  Salvage
       operations should occur first, in a manner that will minimize debris and contamination
       with oils or other products that have to be cleaned up at a later date.  This activity should
       allow for improved access for subsequent clean-up efforts, and the salvage proceeds may
       help offset the costs for vessel preparation.

Operations associated with salvage, clean-up, and diver access have the potential to adversely
impact vessel stability.  Failure to consider the impact of these activities on vessel stability
before and during scuttling operations could result in premature and uncontrolled capsizing
and/or sinking of the vessel. Therefore, vessel stability  considerations should  be an integral part
of the salvage, clean-up, modification (for diver access), transport, and sinking plans of a ship to
reef project.

In the process of preparing a vessel for reefing, there are requirements and regulations, as well as

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permit processes, to consider that are not highlighted in this document. The final preparation
plan for any particular artificial reef project is case specific, and will depend on the
characteristics of the vessel and final permitted artificial reef construction site, as well as
regulatory considerations.  Some legal authorities that may apply to vessel-to-reef projects are
briefly described in Appendix B.

This guidance identifies materials or categories of materials of concern that may be present
aboard vessels, indicates where these materials may be found, and describes their potential
adverse impacts if released into the marine environment (Appendix C provides related
information).  The materials of concern include, but are not limited to: fuels and oil, asbestos,
polychlorinated biphenyls (PCBs), paints, debris (e.g., vessel debris, floatables, introduced
material), and other materials of environmental concern (e.g., mercury, refrigerants). With the
exception of materials containing PCBs, it is not within the purview of this document to discuss
Federal, State, or local regulations,  although those requirements that are directly applicable to
vessel preparation must also be met prior to vessel  sinking and placement. Because the best
management practices described in this document are directed at the environmental concerns
associated with using vessels as artificial reefs, other sources of information should also be used
with regard to preparation of the vessel from a diver safety perspective or for any other potential
in-water uses (e.g., breakwaters or other types of barriers).

A detailed description and characterization of the potential sources of contamination from a
vessel intended for use as an artificial reef should be conducted and a plan developed.  The
purpose of this plan is to assure that materials potentially contributing to pollution of the marine
environment are addressed. Appendix D of this document presents information regarding the
development of workplans; Appendix E provides information regarding general principles for
clean-up operations.

This guidance does not substitute for any statute or regulation, nor is it a regulation itself. It does
not impose legally binding requirements on any Federal agency, States, other regulatory
authorities  or the regulated community, and may not apply to a particular situation based upon
the circumstances. Regulatory decision makers, both Federal and State, retain the discretion to
adopt approaches on a case-by-case basis that differ from this guidance where appropriate. EPA
may change this guidance in the future.
Organization of this Guidance Document

This document describes guidelines for the preparation of vessels in a manner that will ensure
that the marine environment will benefit from their use as an artificial reef. Strategic siting is an
essential component of a successful artificial reef project. Before the discussion of vessel
preparation is presented, reef siting is briefly discussed.

For each material or category of material of concern identified above, this document provides a
general performance goal and information on methods for addressing those goals in preparation
of the vessel prior to sinking.  Additional information for each material includes a description of
its shipboard use and where it may  be found on a vessel, as well as its expected impacts if
released into the marine environment.

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Although the best management practices presented in this document are intended for use when
preparing a vessel to serve as artificial reef habitat, it is recommended that these best
management practices be implemented for other in-water uses of vessels. Two such additional
in-water uses include the sinking of vessels for recreational diving, and for placement as
breakwaters or other types of barriers. These potential obsolete vessel management options are
briefly described in this document.
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SITING OF ARTIFICIAL REEFS

Artificial reefs can enhance marine resources and in turn benefit the marine environment;
however, creating a successful reef entails more than randomly placing miscellaneous materials
in ocean, estuarine, or other aquatic environments.  Planning (including siting), long-term
monitoring, and evaluation are necessary components of each project to ensure that the
anticipated benefits of artificial reefs are attained.  Improperly planned, constructed, or managed
reefs may be ineffective, may  cause conflict among competing user groups of the reef site, may
increase the potential to over harvest targeted species, or may damage natural habitats.  In such
cases, the anticipated benefits  of an artificial reef project may be negated.

Artificial reefs should not cause harm to existing living marine resources and habitats.  Properly
prepared and strategically sited artificial reefs can enhance fish habitat, provide more access to
quality fishing grounds, and provide managers with another option for conserving, managing
and/or developing fishery resources.

Placement of a vessel to create an artificial reef should:

    •   enhance and conserve  fishery resources to the maximum extent practicable;

    •   facilitate access and use by recreational and/or commercial fishermen;

    •   facilitate, as appropriate, access and use by recreational divers;

    •   minimize conflicts among competing uses of water and water resources;

    •   minimize environmental risks and risks to personal and public health and property;

    •   be consistent with international law and national fishing law and not create an obstruction
       to navigation;

    •   use the best scientific information available; and

    •   conform to any Federal, State, or local  requirements or policies for artificial reefs.

Artificial reef project planners should identify  the habitat type and/or species targeted for
enhancement and determine which biological,  physical, and chemical site conditions will be
most conducive to  meeting the reef objectives. Once these siting conditions including
community settlement and recruitment dynamics are determined, they should be used in
identifying potential construction sites.  Existing communities (e.g., infaunal, epifaunal, benthic,
demersal, mid-water, surface-oriented) in the area where the artificial reef is to be placed should
be considered prior to placement — this should include monitoring to establish baselines for the
fishing resources.

Caution should be exercised when developing  artificial reefs in nearshore areas due to the
increased potential for resource competition as well as competition for niche space. Improperly
sited reefs might enhance a recreational fish resource at the expense of other species or habitat; it
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may also alter the ecological balance of the area.  For example, sandy estuarine habitat often
provides critical nursery grounds for the juveniles of many species of bottom fish. During this
life stage, the primary predator protection for these juvenile fish is the absence of large fish —
which are favored by recreational anglers.  Often times, sandy estuarine locations tend to be
popular choices for siting artificial reefs to attract large fish for recreational fishing, thereby
altering existing predatory/prey interactions and creating resource competition. Strategic project
planning can minimize these conflicts.

Artificial reefs should not be constructed such that they are placed on or threaten the integrity of
natural habitats such as:

    •  existing coral reefs;

    •  significant beds of aquatic grasses or macroalgae;

    •  oyster reefs;

    •  scallop, mussel, or clam beds; or

    •  existing live bottom (i.e., marine areas supporting growth of sponges, sea fans, corals,
       and other sessile invertebrates generally associated with rock outcrops).

The goals and priorities of an artificial reef project should direct overall site selection. Within
the identified target area, existing natural and artificial reefs and known bottom obstructions
should be identified. Exclusion areas for potential artificial reef projects should include, but are
not limited to:

     •   shipping lanes;

     •   restricted military areas;

     •   areas of poor water quality (e.g., low dissolved oxygen, dredged material disposal sites);

     •   traditional trawling grounds;

     •   unstable bottoms;

     *   areas with extreme currents, or high wave energy;

     •   existing right-of-ways (e.g., oil and gas pipelines and telecommunication cables);

     •   sites for purposes that are incompatible with artificial reef development;  and

     •   areas designated as habitat areas of particular concern or special aquatic sites.
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The bottom composition and configuration at an artificial reef site affects reef stability and
longevity and should be carefully evaluated in the site selection process. In most cases, soft
sediments such as clays, silts, and loosely packed sands should be avoided. Over time, artificial
reef materials may sink into these sediments or become partially covered.

Caution should also be exercised where coastal physical processes can greatly influence a
potential artificial reef site.  Artificial reef planners should be aware that bottom sediments shift
and may change significantly during storms, hurricanes, and geologic events. Materials that
present large amounts of surface area may scour deeply into almost any bottom type, depending
upon storm events, currents, or wave action.

The principle hydrographic factors to be considered in selecting sites for artificial reef placement
include water depth, potential wave height, currents, and tides.  Water depth is a significant
siting criterion. Artificial reefs should be placed in water at sufficient depths in order to avoid
creating a hazard to navigation - minimum clearance above the reef should accommodate the
draft of the vessels expected to operate in the vicinity. Water depth at the site may critically
affect artificial reef material stability and long-term structural integrity. In this case, average
wave energy in large, open bodies of water as a function of water depth is the major concern.
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Guidance for Preparing Vessels to Create Artificial Reef Habitat
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OIL AND FUEL

       Narrative Clean-up Goal:  Remove liquid hydrocarbons (fuels, oils) and serai-solids
       (greases) so that: no visible sheen is remaining on the tank surfaces (this includes all
       interior fittings, piping, structural members) or on the water surface when the equipment
       is flooded after sinking; no film or visible accumulation (e.g., spills on decking or carpet)
       is remaining on any vessel structure or component.
       Environmental Impacts

The impacts of fuel and/or oil introduced into the marine environment are influenced by a variety
of factors, including the physical properties of the oil, whether the oil is petroleum based or non-
petroleum based, and the hydrodynamic properties of the receiving waters. Each type of oil has
distinct physical properties that affect the way it disperses and breaks down, the hazard it may
pose to ecosystems, and the likelihood that it will pose a threat to manmade resources.  For
example, the rate at which surface dispersion occurs will help to determine the effect of an oil
spill on the environment.  Most oils spread horizontally into a smooth and continuous layer,
called a "slick," on the water surface.

Petroleum based and non-petroleum based oils can have both immediate and long-term adverse
effects on the environment. These oils can be dangerous, or even deadly to wildlife.  Light
refined petroleum products, such as gasoline and kerosene, spread on water surfaces. The risk of
fire and toxic exposure is high, but the products evaporate quickly and leave little residue.
Alternatively, heavier petroleum based refined oil products may pose lesser fire and toxic
hazards and do not spread on water  as readily.  However, heavier oils are more persistent in the
environment, and may present a greater clean-up challenge.

Many non-petroleum oils have physical properties similar to those of petroleum based oils.  For
example, their solubility in water is  limited, they both create slicks on the water surface, and they
both form emulsions and sludge.  In addition, non-petroleum oils tend to be persistent, remaining
in the environment for long periods of time.

Oil spills can harm the environment in several ways, including the physical damage that directly
impacts wildlife and their habitats, and the toxicity of the oil and its constituents, which can
poison exposed organisms. Spilled  oil in the environment immediately  begins to disperse and
degrade, with concomitant changes  in physical and chemical properties. As these processes
occur, the oil threatens natural resources, including birds and mammals  as well as a wide range
of marine organisms linked in a complex food web. Some organisms can be seriously injured
(non-lethal effects) or killed (lethal  effects) very soon after contact with the oil in a spill (acute
effects), however; non-lethal  toxic effects are often more subtle and often longer lasting (chronic
tests).
       What are oil and fuel?

For purposes of this guidance, the term oil includes crude oil; petroleum and petroleum-refined
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products (e.g., diesel fuel, gasoline, kerosene, and bunkers); and non-petroleum oils such as
synthetic oils (e.g., silicone fluids), tung oils, wood-derivative oils (e.g., resin/rosin oils), animal
fats and oil, and edible and inedible seed oils from plants.

       Some common refined petroleum products and their characterisics are as follows:
          •   No, 2 Fuel Oil is a lightweight substance that flows easily, spreads rapidly, and
              disperses readily.  It is neither volatile nor likely to form emulsions.

          •   No. 4 Fuel Oil is a medium weight substance that flows easily and is readily
              dispersed if treated promptly. It has a low volatility and moderate flash point.

          •   No. S Fuel Oil (Bunker B) is a medium to heavyweight substance with a low
              volatility and moderate flash point. Dispersion is very difficult and potentially
              impossible.

          •   No. 6 Fuel Oil (Bunker Q is a thick substance that is difficult to pump and
              requires preheating for use. No. 6 fuel oil may be heavier than water. It is not
              likely to dissolve, and is likely to form tar balls, lumps, or emulsions.  No. 6 fuel
              oil is very difficult or impossible to disperse. It has a low volatility and moderate
              flash point and is especially persistent in the environment.
       Where are oils and fuels found in a snip?

Diesel fuel and fuel oil may be contained in various tanks throughout ?. ship. For example,
lubricating oil is found in engine sumps, drums of unused lubricating oil in ship storerooms or
engineering spaces, and sludge in fuel and cargo tanks.  Hydraulic sysiems and components also
contain oils.

The vessel's piping and tank arrangements generally will contain som« oil, fuel, sludge, and
associated residues. Fuel oil may be found in both  integrated and freestanding tanks throughout
the ship.  Lubricating oils may be found in a variety of tanks depending on their individual use.
System oils are generally located in engine room sump tanks, while cylinder oils and lubrication
oils will be stored in tanks dedicated for a specific purpose.

"Used oil" ~ any oil that has been refined from crude oil or any synthetic oil that has been used
and, as a result of such use, is contaminated by physical or chemical impurities — also may be
found on ships.  Used oil includes spent lubricating fluids that have been removed from engine
crankcases, transmissions, and gearboxes; industrial oils such as compressor, turbine, and
bearing oil; metal working oil; and refrigeration oil.
       Vessel Preparation

The aim of hydrocarbon clean-up is to remove liquid hydrocarbons (fuels, oils). Although it is
impossible to remove all hydrocarbon contaminants, a very thorough clean-up is achievable.  In
general, all liquid hydrocarbons and semi-solids (greases) should be drained, flushed, and
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cleaned from fuel/lube and fluid system equipment (including piping, interior fittings, and
structural members) so that no visible sheen remains on the tanks or other associated fluid
system structures or on the water surface when the equipment is flooded after sinking.  The
opening and cleaning of pipes varies according to the type of hydrocarbon product that was in
the lines. No visual evidence of hydrocarbon weeping (oozing or releasing drops of liquid)
should exist at openings.  Suggested cleaning methods for liquid hydrocarbons (fuels, oils, and
semi-solids) are found in Appendix F.

If structural tanks are flooded, oil absorbent pads and excess loose oil absorbent material should
be removed and liquid hydrocarbons should be cleaned from the tanks so that no visible sheen is
present on the water surface. An alternative and very effective option for hydrocarbon clean-up
is removal of the equipment and piping.

During vessel preparation, an economical way of managing used oil is recycling. It should be
noted that additional used oil might be generated during the final preparation of the vessel prior
to sinking.  Such used oil should be removed from the vessel before sinking. It may be
acceptable to leave old oil and grease in place if it is determined visually to be dried/solidified
and therefore is not likely to cause a sheen.

Fuel and Oil Tanks
All fuels and lubricants should be drained from the tanks and the tanks flushed.  Merely sealing
tanks, whether as the sole means of fuel and oil tank preparation or in combination with partial
tank draining, is insufficient. Over time, the integrity of the sealed tanks will  eventually be
compromised as marine growth density increases and the  ship's underlying structural
components decay. The placement of the Liberty  ship Joseph L. Meek, sunk off Escambia
County, Florida in 1976, demonstrated that corrosion of the ship's metal will eventually release
residual fuel sealed in tanks into the environment. Although sealing the tanks without removing
the contents is not sufficient for managing fuel and oil on a vessel intended to serve as an
artificial reef, fuel/lube and fluid system equipment and piping intended to stay on the vessel
should be sealed as necessary for the purpose of towing stability once the fuel/oil has been
removed. Because these systems need to be opened during vessel preparation for draining and
flushing the systems clean, sealing these systems may be necessary to help maintain vessel
stability during transit to the designated artificial reef site.

There are several accepted and widely used methods to clean fuel and oil tanks. The appropriate
method will be determined by the type of hydrocarbons in the tank, the amount of residue in the
tank, and the extent of any hard or persistent deposits or residues. In general, lower quality fuels
and heavy oils will require more cleaning effort.  Similarly, tanks for dirty or water-contaminated
oils will require more cleaning effort.

When cleaning tanks, the following factors should be considered: worker access and safety
issues, machinery and resources available, and the methods or facilities available to deal with the
cleaning residues. It may be necessary to experiment with several cleaning methods to see which
best suits the particular circumstance.

Some methods for cleaning tanks are detailed in Appendix E. Regardless of the selected tank
cleaning method, the effluent and water must be collected, treated, and disposed of in

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       DRAFT       DRAFT       DRAFT        DRAFT       DRAFT       DRAFT
compliance with applicable regulations.  Large volumes will require the: services of a pumper
truck or barge, while smaller quantities should be collected and stored h drums. Caution should
be used during all transfer operations to avoid spills.  If transferring large quantities of oil or oil
contaminated liquid, a containment boom around the vessel should be used to minimize the
extent or spreading of an accidental release.

Structural and Non-structural Tanks
All structural and non-structural tanks are assumed to be contaminated by hydrocarbons until
proven otherwise. Structural tanks include, but are not limited to:  fuel
slorage/settiing/service/day tanks, cargo tanks, oil tanks, structural hydraulic tanks, fresh water
tanks, ballast tanks, stabilizer tanks, black and gray water tanks, voids, and cofferdams.

Tank interiors including deckheads should be cleaned of all hydrocarbons. No visible
hydrocarbons should remain on the tank surfaces (this includes all interior fittings, piping,
structural members), or on the water surface when flooded after sinking. No emulsified oil, as
determined by visual inspection, should remain.  Oil absorbent pads and excess loose oil
absorbent material should be removed before sinking.

Gauges and Gauge Lines
Pressure gauges and gauge lines are assumed contaminated with the product that they were
intended to measure.  Fluid filled gauges should be removed. Pressure gauges and gauge lines
should also be removed to prevent oil seepage from these lines. Lines that remain in place
should be flushed, and the lines cleaned.

Special care should be exercised with mercury thermometers and pressure (typically  vacuum)
measuring devices. These should be removed intact from the vessel. Temperature gauges that
do not contain any hazardous material can remain in its position.  Other measuring instruments
should be removed from the vessel or opened for cleaning, examination, and possible removal.

Combustion Engines
Combustion engines include any reciprocating engine in which fuel is consumed (diesel,
gasoline, gases), Stirling cycle engines, and gas turbines. The entire fuel/oil system should be
drained and flushed. Any items (e.g., oil filters and strainer elements) that can not be flushed
should be removed.

Combustion engines and associated manifolds should be thoroughly drained, flushed, and
cleaned.  Machinery need not be removed if it is completely drained and the sumps flushed and
cleaned.  Sometimes, engines are removed for reuse or to assure that all oil is removed before
reefing.  In some cases, it might be less expensive to remove and dispose of the engines than to
clean the oil from them.  Some methods for cleaning combustion engines are detailed in
Appendix E.

Non-combustion Engines, Shafting, Gearing and Stern  Glands
Main gear boxes and associated clutches should be drained of all lubricating oils. Internal gear
sprayers, lubricating lines, and other components should be removed, or drained.  External
pedestal and thrust bearings should be drained.
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       DRAFT       DRAFT        DRAFT       DRAFT       DRAFT        DRAFT
Stern tubes and seals, if of the oil bath type, should be drained of oil. Note that draining the stem
tubes and seals may require extraordinary measures to preserve the watertight integrity of the
vessel during the clean-up and salvage operation.

Vessels that are equipped with thrusters, Z-drives, or other methods of unconventional
propulsion systems will be addressed on a case-by-case basis. The objective is that no
hydrocarbons remain in the propulsion system.

Steering Gear
Hydraulic pumps and associated piping and fittings should either be removed or drained and
flushed clean.  Hydraulic telemotor systems should be treated similarly. Grease lines and
reservoirs for rudder heads should be removed from the ship, or opened and cleaned.  Vessels
with combined propulsion and steering systems should be addressed in the same manner as that
which is provided under the above mentioned "non-combustion engines, shafting, gearing, and
stem glands" subsection.

Auxiliary Machinery
Auxiliary machinery that has a liquid hydrocarbon as its working fluid should be completely
drained and flushed clean.  Auxiliary machinery refers to machinery and components that are not
an integral part of the main propulsion system of the vessel. The term can include but is not
limited to:  pumps, motors, compressors, galley equipment, capstans, elevators, and cargo
handling machinery.  Many pieces of auxiliary machinery have a lubricating oil system or are in
direct contact with liquid hydrocarbons.

All lubricating oil system components should be stripped from auxiliary machinery, drained and
cleaned. Lubricating oil sumps should be drained and cleaned.

Hydraulics
Unless there is acceptable proof to the contrary, all hydraulic systems should be assumed to have
employed a hydrocarbon based fluid. Hydraulic lines should be removed from the vessel, or
opened and blown through with air until clear. Hydraulic fittings (valves and valve blocks of all
types, cylinders, pumps, accumulators, filters, coolers) should be removed from the ship or
drained clean. Hydraulic sumps should be opened and drained clean.   "

Grease
All grease reservoirs should be  removed from the ship, or opened and cleaned. Grease lines
should be removed or blown through until clear and all visible grease accumulations should be
removed so that no visible sheen is remaining on the water surface when these structures are
flooded after sinking. Machinery that employs grease-packed gearboxes (common on deck
machinery), as well as grease packed couplings,  stuffing boxes,  chain sprockets, and worm
drives should be opened and cleaned of grease. Grease on chains and sprockets should be
removed.  Greased cables should be cleaned or removed from the vessel so that no visible sheen
is remaining on the water surface when these structures are flooded after sinking.

Sealed rolling element bearings that contain grease can be left in-situ. Grease in other fittings
such as stuffing boxes and glands can be left in situ if the seals are intact and the quantities are
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       DRAFT       DRAFT       DRAFT        DRAFT        DRAFT       DRAFT
small (for example, less than 100 milliliters evenly distributed throughout the component). Any
grease on the outside of the sealed bearings should be removed.

Bilge Areas
The bilge area includes all areas that would be subject to contact with oily water, or may be a
catch area for spills from cargoholds or storerooms, and interior surfaces which may have been
subject to hydrocarbon contamination through sprays, spills, or disposal. Bilge areas also
include the plating and all surfaces of attached stiffeners and fittings. Bilge areas should be free
of visible oils, greases, and sludge. Oil or grease films evident to the touch should be removed.
Any  debris contaminated with hydrocarbons should be removed. Any cleaning fluids used to
clean the bilge should be removed from the vessel. Accumulations of loose oil absorbent
material should be limited to those amounts that cannot reasonably be picked up with brooms
and vacuums.

Cleaning bilges is frequently complicated by poor access caused by piping, gratings, and
equipment.  In many cases, it is cheaper and easier to remove the dirty or contaminated items
that limit access than to clean the items as well as the bilge.  Once clean, bilges are very
vulnerable to recontamination. Note the following recontamination issues:

   •  Piping, valves, and fittings in hydrocarbon systems will continue to drip for some time
       after initial draining.  Over a short period of time, these drips can lead to a major rework
       cleaning effort. Therefore, drips should be captured whenever possible; drip pans should
       be emptied frequently.

   •  Containers used for clean-up are vulnerable to tipping and spilling, especially in
       conditions - such as poor lighting - that are often found in vessels undergoing sinking
       preparation.  Remove containers used for clean-up when they are full.

   •  Water should not be allowed to enter bilges unless it is part of a planned clean-up effort.
       Water that otherwise enters the bilge should be handled as oily vvastewater.

In general, the approach and methods recommended for cleaning bilges are the same as for
cleaning tanks.

Decks and Floor Coverings
Oil and grease films on deck coverings should be cleaned.  Decks and floor coverings include
ceramic tile, linoleum and linoleum tile, carpet, and continuous floor coverings. In
compartments subject to hydrocarbon spills during the vessel's life (e.g., workshops,
compartments with fuel or oil tank overflows or tank covers), the deck covering and
underlayment should be examined for oil saturation. Floor coverings or underlayment that has
been saturated with hydrocarbons should be removed from the vessel.

Bulkheads and Deckheads
Bulkheads and deckheads should be cleaned of oil and grease films.  Where it is evident that a
spill  or accumulation resulting from leaks has occurred, coverings should be removed to reveal
the full extent of the spill or accumulation.


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ASBESTOS

       Narrative Clean-up Goal: Remove any loose asbestos and asbestos that may become
       loose during vessel sinking; remove or seal accessible friable asbestos.
       Environmental impacts

Asbestos is a naturally occurring mineral.  The environmental impacts caused by asbestos are
dependent upon 1) whether asbestos is reduced to fibers or is in a non-friable form; and 2)
whether the asbestos is air-borne or water-borne.

Even though adverse impacts from asbestos are largely from inhalation — which is not expected
to be an issue in the marine environment — vessel preparation should eliminate the possibility of
pieces of asbestos breaking free  from the vessel during the sinking operation or asbestos
materials losing surface integrity after the vessel has been placed as an artificial reef.  Loose
asbestos pieces can lead to rafting and may be capable of washing ashore. These asbestos pieces
could dry up, break apart, and be reintroduced into the atmosphere. Exposure to airborne
asbestos can negatively impact human health via inhalation.

Once a vessel has settled on the  ocean floor, asbestos remaining on the vessel (e.g., intact and
undisturbed asbestos insulation) will be covered with bacteria over time. This in turn will cause
the asbestos fibers to sink and remain contained within the reef matrix, minimizing any potential
direct impacts to the marine environment,  (see Appendix C)
       What is asbestos?

Asbestos refers to a group of minerals that occur naturally as masses of long silky fibers. There
are three main types of asbestos fibers:

    •  Chrysotile fibers (white asbestos) are fine, silky flexible white fibers. They are pliable
       and cylindrical, and arranged in bundles. This was the most commonly used asbestos in
       the United States.

    •  Amosite fibers (brown asbestos) are straight, brittle fibers that are light grey to pale
       brown.  This was the most commonly used asbestos in thermal system insulation.

    •  Crocidolite fibers (blue asbestos) are straight blue fibers that are like tiny needles.

There are three other types of asbestos fibers: anthophyllite, tremolite, and actinolite. Unlike
most minerals, which turn into dust particles when crushed, asbestos breaks up into fine fibers
that may be too small to be seen by the human eye.

Individual asbestos fibers are often mixed with a material that binds them together, forming what
is commonly called asbestos-containing material (ACM). There are two kinds of ACM: Friable

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and non-friable.

   •   Friable ACM is any material containing more than 1% asbestos that, when dry, may be
       crumbled, pulverized, or reduced to powder by hand pressure.

   •   Non-friable ACM is any material containing more than 1% asbestos that, when dry,
       cannot be crumbled, pulverized, or reduced to powder by hand pressure.  Non-friable
       ACM is divided into two categories.

          1. Category I non-friable ACM includes asbestos-containing resilient floor
             coverings, packings, and gaskets.

          2. Category II non-friable ACM includes all other non-friable ACM that is not
             included in Category I.

Asbestos is resistant to abrasion and corrosion, inert to acid and alkaline solutions, and stable at
high temperatures.  It is strong yet flexible, non-combustible, conducts electricity poorly, and is
an effective thermal insulator.
       Where is asbestos found on a ship?

Asbestos on ships may be found in many materials, including, but not limited to:

   »   Bulkhead and pipe thermal insulation
   •   Bulkhead fire shields/fireproofing
   •   Uptake space insulation
   •   Exhaust duct insulation
   *   Electrical cable materials
   •   Brake linings
   •   Floor tiles and deck underlay
   •   Overhead and panel sheeting (cement and cellulose based)
   •   Steam, water, and vent flange gaskets
   •   Adhesives and adhesive-like glues (e.g., mastics) and fillers
   •   Sound damping
   •   Molded plastic products (e.g., switch handles, clutch facings)
   •   Sealing Putty
   •   Packing in shafts and valves
   *   Packing in electrical bulkhead penetrations
   *   Asbestos arc chutes in circuit breakers
   •   Pipe hanger inserts
   •   Weld  shop protectors and burn covers, blankets, and any fire-fighting clothing or
       equipment
   •   Any other type of thermal insulating material

   NOTE: Asbestos-containing material may be found underneath materials that do not contain
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       DRAFT       DRAFT        DRAFT       DRAFT        DRAFT       DRAFT
   asbestos.  Thermal system insulation and surfacing material found in vessels and vessel
   sections constructed after 1980 may be presumed to be free of asbestos containing material.
       Vessel Preparation

Asbestos can be found throughout ships, from the bridge to the bottom of the bilge. Identifying
the locations and types of asbestos onboard are essential for vessel preparation and should be
considered early in the clean-up process.  Once the type and location of asbestos and asbestos
containing materials are identified, a determination should be made whether to remove,
encapsulate, or leave the asbestos undisturbed.

The method of demolition is particularly important to the effective management of asbestos on
board ships. If the sinking method for the vessel includes the use of explosives, asbestos-
containing material that may become disturbed during detonation should be removed from the
vessel.

In addition, any asbestos that is moved or disturbed (including during clean-up operations) or can
potentially get dislodged as the vessel sinks should be removed from the vessel. Friable asbestos.
should be sealed as a precautionary measure to prevent releases of asbestos in high
concentrations during the sinking event Intact and undisturbed asbestos insulation need not be
removed.

Engine Room and Engine Compartments
Removal or encapsulation of exposed, disturbed and deteriorated asbestos should be considered
since it is likely that the asbestos will break free and create debris during sinking.  If the asbestos
is to be encapsulated, its integrity should not be impacted by the preparation for sinking as well
as the sinking itself.

The primary source of friable asbestos is found  on pipe wrappings around the main boilers and
steam fittings. On most vessels the asbestos coating, which is 1 to 3 inches thick, is covered with
canvas and is usually painted. If work needs to be done around the piping and the covering,
causing the asbestos to be disturbed, the disturbed material should be removed. If the covering is
deteriorated and it is likely that the asbestos will break free during sinking, then removal  or
encapsulation with an epoxy or other non-water soluble and non-toxic sealer should be
considered.

Certain boilers and piping are covered with a very friable asbestos paste. Throughout the engine
room there are numerous asbestos gaskets connecting piping and ductwork. If left intact, these
gaskets usually will not release asbestos fibers.  However, if the ductwork or piping needs to be
cut or removed and vessel debris is created as a result, gaskets should be removed or
encapsulated if possible.

In some engine rooms asbestos/cellulose sheets are found behind power and electrical panels or
in the overhead where electrical service passes.  Undisturbed, this material is not friable.
However, once the sheets are exposed to the marine  environment, the sheets loose their integrity
and can break up and raft.  Where possible, these sheets should be removed. Note that asbestos

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cement sheets may also be used as panels on the vessel.  However, these sheets are not water-
soluble and therefore should not break apart when exposed to the marina environment. These
sheets can stay in place unless cut, drilled or disturbed. Friable asbestos; may also be found
between bulkheads; this asbestos may remain in place because the asbestos is contained within
the bulkheads. If, however, the bulkheads are drilled, cut, or disturbed, the friable asbestos that
is now exposed should be encapsulated or removed.

Ship Interior and Living Spaces
Asbestos was also used in some hatch gaskets mixed with rubber throughout ships, especially in
watertight spaces.  Under normal circumstances this will only present a problem if grinders or
torches are used. In such cases, the gaskets should be removed prior to disturbance.
Asbestos/asphalt floor tile was common from the 1940's to the mid 1970's. This form of asbestos
is manufactured with the asbestos encapsulated. If preparation of the vessel requires the tile to
be disturbed via grinding, cutting, or burning, those pieces of tile should be removed. Asbestos
sheets both with cement and cellulose may be found especially in the combat information center,
the radio room and other spaces where electrical equipment may be found. Cellulose/asbestos
panels  should be removed but cement panels are safe. As an example, while inspecting an old
Navy tug planned for reefing off the coast of Virginia, it was determined that the entire interior
of the wheel house was paneled with cellulose/asbestos panels and had to be removed.

Exterior Spaces
There are a few areas on the exterior of ships where asbestos was used. Asbestos may have been
mixed with paint and applied as a coating near some vents and hatches. Also, some hatches may
have gaskets that contain asbestos. In either case, the material does not need to be removed
unless these exterior areas require grinding or cutting.
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      DRAFT        DRAFT        DRAFT        DRAFT       DRAFT       DRAFT
POLYCHLORINATED BIPHENYLS (PCBs)

      Narrative Clean-up Goal:  Remove all solid material containing PCBs greater than or
      equal to (>) 50 parts per million (ppm) unless a disposal permit has been granted under
      40 CFR 761.62(c); remove all liquid materials containing PCBs.
       Environmental Impacts

PCBs are persistent and bio-accumulative. PCBs bio-accumulate in fatty or lipid rich tissues.
PCBs have a limited solubility in aqueous solutions and it is suspected that PCBs can leach into a
marine or aqueous environment (sediment and water column) where they can be taken up by
organisms in the food web. PCBs bioaccumulate in fish and other animals; PCBs also bind to
sediments. As a result, people who ingest fish may be exposed to PCBs that have been released
into the environment.

There is a risk of human exposure during vessel preparation and after sinking the vessel.  During
vessel preparation, typical routes of human exposure include inhalation, accidental ingestion, or
dermal contact. After sinking, exposure routes may be limited to accidental ingestion of or
contact with contaminated water or ingestion of contaminated fish, shellfish, or crustaceans, (see
Appendix C)
       What are PCBs?

PCBs belong to a broad family of man-made organic chemicals known as chlorinated
hydrocarbons.  PCBs, which were domestically manufactured from 1929 until their manufacture
was banned in  1979, have a range in toxicity and vary in consistency from thin light-colored
liquids to yellow or black waxy solids. Due to their non-flammability, chemical stability, high
boiling point, and electrical insulating properties, PCBs were used in hundreds of industrial and
commercial applications including electrical, heat transfer, and hydraulic equipment; as
plasticizers in paints, plastics, and rubber products; in pigments, dyes, and carbonless copy
paper; and many other industrial applications.
       Where are PCBs found on a ship?

Although no longer commercially produced currently in the United States, PCBs are present in
vessels deployed before the 1979 PCB ban.  PCBs are found in both the solid (waxy) and liquid
(oily) forms in equipment and materials on ships that were built leading up to the ban.  The
equipment and materials that may contain PCBs in concentrations of at least 50 ppm include:

    •   Cable insulation
    •   Rubber and felt gaskets
    •   Thermal insulation material including fiberglass, felt, foam, and cork
    *   Transformers, capacitors, and electronic equipment with capacitors and transformers
       inside
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       DRAFT       DRAFT       DRAFT       DRAFT       DRAFT       DRAFT
   •   Voltage regulators, switches, reclosers, bushings, and electromagnets
   •   Electronic equipment, switchboards, and consoles
   •   Adhesives and tapes
   •   Oil used in electrical  equipment and motors, anchor windlasses, hydraulic systems, and
       leaks and  spills
   •   Surface contamination of machinery and other solid surfaces
   •   Oil-based paint
   »   Caulking
   •   Rubber isolation mounts
   •   Foundation mounts
   *   Pipe hangers
   *   Fluorescent light ballasts
   •   Any plasticizers

Items containing PCBs may be found throughout a ship and are not easily identifiable or
accessible. PCBs may be found in a variety of shipboard materials, but the location and
concentration may vary from item to item and within classes of items. PCB containing materials
can also vary from ship to ship, and even ships in the same class can contain differing amounts
of PCB containing materials.  While these materials may be found throughout a ship, several
areas on ships may have an increased likelihood of containing PCB bearing materials: areas or
rooms subject to high heat or fire situations such as boiler rooms, engine rooms, electrical/radio
rooms, or weapons storage areas.
       Vessel Preparation

Even though it is not the intent of this document to focus on regulatory requirements, PCBs are
regulated for disposal under 40 CFR Part 761, and will be discussed in this context. The
regulations require that materials containing PCBs > 50 ppm cannot be disposed in the marine
environment.  Although the ship itself is being "reused" or "recycled" as an artificial reef, the
PCBs have reached the end of their useful life and must be removed and disposed.  Disposal
requirements are referenced below (also see Appendix B).

Where there is reason to suspect that equipment or components may contain PCBs > 50 ppm,
either remove the equipment or component from the vessel, provide proof that the equipment or
component is free of PCBs, or apply to EPA for a PCB disposal permit. Thermally removing
PCB containing materials is prohibited, as PCBs may volatize or form dioxin or dioxin-like
compounds.  Because PCB sampling and analytical procedures can be expensive and time
consuming, there may be situations when the cost of sampling and analysis far exceed the cost
for removal and disposal.  In such cases, previous ship to reef projects have shown that removal
of all  electrical cables and wires suspected of containing some level of PCBs is more
economical.

Liquid Materials Containing PCBs
Remove all liquid filled electrical equipment suspected of containing PCBs or PCB contaminated
dielectric fluid.  Materials such as lubricating oils and greases used for winches and cargo-
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handling machinery, hydraulic fluids, heat transfer fluids, and waste oils should be removed from
the vessel as presented in the "Oil and Fuel" Section of this document.

Solid Materials Containing PCBs (non-liquid PCBs)
Remove all solid materials containing PCBs 2:50 ppm, which includes but is not limited to felt
gasket and faying material, cables, paints, rubber gaskets as well as battle lanterns and
fluorescent light ballasts. EPA recognizes that non-liquid PCBs may be difficult to locate and
remove and that removal may jeopardize the integrity of the ship. If non-liquid PCBs i> 50 ppm
are to remain in the vessel, then 40 CFR Part 761 requires you to obtain a PCB disposal permit
under 40 CFR 761.62(c).
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PAINT

       Narrative Clean-up Goal± Remove harmful exterior hull antifouling systems that are
       determined to be active; remove exfoliating and exfoliated painl.
       Environmental Impacts

Scientific investigations by governments and international organizations have shown that certain
anti-fouling systems (AFS) used on vessels pose a substantial risk of both acute and chronic
toxicity and other adverse impacts to ecologically and economically important non-target marine
organisms.  Because this document addresses vessels that would be sunk for the creation of
artificial reef habitat, the presence of biocides and other anti-fouling systems that inhibit marine
growth are antithetical to this purpose. Furthermore, because anti-fouling systems can be
reactivated via physical disturbance and/or biological degradation (e.g., scouring during a storm
event or burrowing caused by marine organisms) over time, anti-fouling systems that retain
potency may become harmful or be reactivated following the sinking,  (see Appendix C)
       What types of paint and anti-fouling systems are used on ships, and where are they
      found?

Paint and preservative coatings can be found on both interior and exterior surfaces of a ship.
Particularly on older ships, paint may be flammable or may contain toxic compounds, such as
polychlorinated biphenyls (PCBs), heavy metals (e.g., lead, barium, cadmium, chromium, and
zinc), and biocides. Lead compounds, such as red lead tetraoxide (PbsO^O and lead chromate,
have been used extensively in marine paint. Other paints containing biocides, such as organotin
(including compounds such as tributyl tin), have been used on the hull:; of ships to prevent the
buildup of marine organisms (e.g., bacteria, protozoa, barnacles, and algae).

Paints
Paint above the water line (topside paint) is not designed to leach because these paints are
designed to protect topside surfaces from physical degradation and do not typically contain
antifoulant biocides like that of anti-fouling coatings. However, these paints may contain
biocides added as in-can preservatives.

Anti-fouling System
For most types of candidate vessels for reefing, the paint-related contaminants of concern are
limited to exterior hull coatings below the water line. These hull coatings consist primarily of
anti fouling (AF)  agents (biocides) such as copper, organotin compounds, and zinc.
       Vessel Preparation

Anti-fouling Underwater Hull Coatings
If there is minimal active biocide remaining on the vessel, no preparation to the underwater hull
area is necessary.  It can be assumed that biocide activity is minimal if the anti-fouling coating
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on a candidate vessel is more than twelve years old and essentially all the underwater hull area is
covered with marine growth.

When assessing the efficacy of the anti-fouling system (AFS), existing documentation relating to
the anti-fouling properties of the hull coating could provide supporting information when
determining if such coatings should be removed. Sources for such supporting information
include, but are not limited to the following:  a document search on the type and age of the
existing AFS, the most recent repainting or dry-dock cycle, the most recent underwater hull
cleaning, and when necessary, a physical, underwater hull examination by trained divers or
remote operating vehicles.  Repair and maintenance records for the vessel should provide the
dates when the vessel was last removed from the water for hull maintenance.

If anti-fouling coatings on candidate vessels are at least twelve years old, the AF coatings can be
left in place without further evaluation, as they are likely to be no longer harmful.  If satisfactory
evidence relating to underwater hull coating types and coating application dates is not available,
and if the AF coating seems to be inhibiting fouling growth according to established AF paint
efficacy, further evaluations should be carried out to ascertain the current anti-fouling properties
of the coating.

If there is a lack of documentation, lack of fouling presence, or a reason to believe that the AFS
is active, further evaluation of the AFS should be conducted. If it is determined that the AFS is
active,  the system should be removed to prevent the release of the AFS's harmful biocides.

Interior and Exterior, Above the Waterline Paints
In some cases, interior and exterior paints onboard vessels may contribute to debris/floatable
materials or contain other contaminants of concern.  Interior paint and paint above the waterline
should be evaluated according to the practices presented under the PCB and Debris sections
when appropriate. If paint is found to contain PCBs, then the protocols found in the "PCB"
section of this document should be followed. If paint exhibits physical damage such as
blistering, peeling, or pitting that contributes to vessel debris (such as paint chips or flakes) that
might float or could be transported into the water column during a sinking event, then the
protocols under the "Solids/debris/floatables" section of this document should be followed.
Exfoliating paint (paint that is blistering, peeling, and pitting) and exfoliated paint  (paint chips
and flakes) should be removed.
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SOLIDS/DEBRIS/FLOATABLES

       Narrative Clean-up Goal: Remove loose debris, including materials or equipment not
       permanently attached to the vessel, which could be transported into the water column
       during a sinking event.
       Environmental Impacts

Marine debris consists of solid materials of human origin discarded at sea. Floatable
material/debris is any unsecured foreign matter that floats, remains suspended in the water
column, or washes up on shore. Floatable materials can travel long distances in the ocean and be
deposited far from their source.

The degradability of floatable materials and marine debris influences the persistence of these
items in the marine environment. Most marine debris is man-made and does not biodegrade
readily. The longer that introduced materials remain in the marine environment, the greater the
threat they pose to the environment.

Some potential impacts of solids/debris/floatables to the marine environment include:
   •   Marine life is endangered by entanglement, ingestion, or both; injury, infection, and death
       may often occur when marine animals encounter debris of this nature;
   *   Alteration of the ecosystem and its processes may occur throughout the water column as
       a result of debris introduced into the marine environment. For example, floating debris
       may act as an attractant for marine animals that would try to use it as shelter or a food
       source, thereby potentially causing injury or death and altering behavior and/or
       distribution of indigenous species.  Debris settling on the bottom would change benthic
       floral and fauna! habitat structure, potentially causing a direct deleterious impact on
       members  of the benthic community (i.e., injury or mortality) or indirect impact to other
       species linked in the benthic food web;
   •   Recurring clean-up costs for coastal communities impacted by the debris; and
   •   Danger to navigation (e.g., hull damage, damage to propellers, and damage to cooling
       and propulsion systems).
       What are solids/debris/floatables?

Solids, debris, and floatables are loose materials that could break free from the vessel during
transportation and placement as an artificial reef, thereby adversely affecting the ecological or
aesthetic value of the marine environment or posing a risk to humans or animals (i.e., land
animals). These materials can consist of vessel debris, introduced debris, and clean-up debris.
Vessel debris refers to material that was once part of the vessel or was generated during vessel
clean-up operations and has been removed or disconnected from its original location on the
vessel. Clean-up related debris is material that was not a part of the vessel, but rather was
brought on the vessel during preparation operations.
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       Where are solids/debris/floatables found on ships?

Solids, debris, and floatables can be found anywhere within the vessel as well as on the decks.
       Vessel {^reparation

Vessel Debris
All material or equipment that is not an integral part of a permanently attached appurtenance and
that could become separated from the vessel during sinking should be removed from the ship
prior to sinking.  Ship's surfaces (e.g., decks, bulkheads, overheads, and surfaces of
appurtenances) should be thoroughly cleaned to remove all dirt, loose scale, trash, exfoliating
paint, paint chips, hazardous materials, and other foreign matter.  Deck drains should be proven
clear of debris.

When assessing vessel debris removal, consideration should be given to the following:

                    •   no vessel debris contaminated with hydrocarbons or hazardous
                        material should remain in the vessel;

                    •   vessel debris that is heavy and/or bulky fitted equipment, and was
                        disconnected or otherwise detached from the structure of the vessel for
                        cleaning or inspection can remain in its original compartment subject
                        to issues of diver safety. Otherwise, vessel debris should be contained
                        in a sealed compartment or structural tank that is below the waterline
                        of the ship and underneath the largest section of the superstructure;

                    •   vessel debris should not be placed in a  compartment or structural tank
                        that will be sealed until both the compartment and the debris have been
                        inspected; and

                    •   vessel debris remaining on the vessel should always be negatively
                        buoyant.

Any vessel debris determined to be acceptable to remain on the vessel for sinking should be
clean in the context of this guidance.

Clean-up Related  Debris
Clean-up debris that was introduced to the vessel solely for cleaning purposes and final
preparation of the vessel should always be removed.  This would  include items such as tools,
generators, warning tape, and temporary wooden covers.

Introduced Debris
Foreign material placed on the vessel solely for disposal is not acceptable. However, introduced
material of a permanent or commemorative nature (e.g., plaques,  markers, clean concrete, or
rock for ballast) is permissible.

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OTHER MATERIALS OF ENVIRONMENTAL CONCERN

       Narrative Clean-up Goal±  Remove other materials that may negatively impact the
       biological, physical, or chemical characteristics of the marine environment
       Environmental Impacts

When placed in the marine environment, materials of environmental concern can have adverse
effects on fish, wildlife, shellfish, recreation, or municipal water supplies. Adverse effects on the
environment include any of the impacts mentioned in the preceding sections of the document.
The magnitude of the impact of these materials on the marine environment will be related to the
nature of the material, the level of toxicity, and the ecological resources that could come in
contact with "other material of environmental concern."
       What are other materials of environmental concern?

Refer to the list provided below.


       Where are other materials of environmental concern found on ships?

Other materials of environmental concern can be found anywhere within the vessel as well as on
the decks.


       Vessel Preparation

Shipboard equipment or materials with constituents that can leach into the water column (e.g.,
petroleum products, batteries, and/or mercury containing switches) should be removed from the
vessel prior to sinking. Fluorescent light tubes and ballasts should be removed. Waste water
resulting from clean-up processes, including but not limited to decontamination, rain water
collection, and water from rinsing of tanks and lines, should be properly collected and disposed.

Antifreeze and Coolants
Antifreeze and coolant mediums, other than untreated sea water, should be drained and removed
from the vessel and the equipment should be flushed.

Batteries
All batteries should be removed from the vessel. This includes batteries that are part of fitted
equipment.

Fire Extinguishing Systems
Fire extinguishing systems should be fully decommissioned.  Except for fire-fighting systems
that employ untreated seawater or fresh water, all fire-fighting compounds should be removed
from the ship. Storage containers, if left in situ, should be cleaned, flushed, and re-closed for
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transit. Any lines that have been charged with any fire-fighting product other than untreated
seawater or fresh water should be treated as for fuel and oil piping.

Refrigerants and Halons
All refrigerants and halons should be removed from the vessel.

Mercury
Ship system components using mercury (e.g., some gyroscopes, vacuum measurement gauges,
some laboratory equipment, some light switches, some older radar displays) should be removed
from the vessel. All portable thermometers and other measuring equipment employing mercury
should be removed intact from the vessel.  Any other extent mercury or items containing
mercury should be removed from the vessel. Note that there is a health hazard associated with
airborne mercury.

Lead
Lead ballast bars, shielding and fittings should be removed from the vessel if the reef site is
located in fresh or brackish water.

Black and Gray Water
Remove black water (sewerage) and gray water (waste water from sinks, showers, galleys,
dishwashers) from the vessel; flush the lines.

Radioactive Materials
Ex-warships, research vessels, and a few other types of vessels may have used equipment
containing low-level radioactive material.  Residual radioactivity and any source of non-naturally
occurring radioactive materials such as luminescent devices should be removed if determined
appropriate. The Navy is more familiar with addressing this material aboard vessels, and as
such, the Navy has guidance and established procedures regarding the removal and disposal of
radioactive materials. For this reason, it is recommended that the procedures for removal and
disposal of radioactive materials follow that provided in DLAINST 4145.8, "Material
Management for Radioactive Items in the DoD" and implementing instructions.  Another
reference that may be useful is the American National Standard Institute's standard N 13.12-
1999, "Surface and Volumetric Radioactivity Standards for Clearance." This document contains
tables of surface contamination criteria developed to allow users of radioactive material to
demonstrate that the material or equipment can be safely released with no further regulatory
control.

Invasive Species
Assess the presence of invasive species that could be transported to and survive at the artificial
reef location on the hull of the ship or from other locations on or in the vessel such as ballast and
bilge tanks.  If a viable invasive species is found that may be expected to survive at the artificial
reef site, that species should be removed or eliminated; the vessel should be clean of all such
living organisms.
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  Considerations for Other In-water Uses of Obsolete Vessels
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DIVING OPPORTUNITIES

The narrative goals set out under the section "Guidance for Preparing Vessels to Create Artificial
Reef Habitat" also should be achieved while preparing a vessel for diver opportunities. For
example, if preparation for diver use calls for the removal of wall paneling that will in turn
expose any materials of concern that were identified in the aforementioned section, the
respective narrative goals should be addressed (e.g. if asbestos is exposed once the panel is
removed, the objectives of the asbestos narrative goal should be met).

Additional vessel preparation to support the in-water use of recreational diving may include:

   •   Removal of sharp and protruding objects along the divers' access path which could snag
       on divers' equipment or otherwise pose a danger to the divers.

   •   Removal of doors and access hatches and widening of openings to allow safe access for
       divers.

   •   Widening of corridors by removal of some wall paneling and provision of large openings
       in the exterior of the ship to allow light to penetrate and ensure safe diver access.

   •   Sealing entrances into restrictive compartments such as the boiler rooms and engine
       rooms to ensure diver safety.

When preparing the vessel for diver opportunities, careful consideration also should be given to
vessel stability (for transport and sinking operations) as well as vessel integrity (for the life of the
vessel once placed at the reef site).
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BREAKWATERS/BARRIERS

Although the best management practices (BMPs) presented in this document are intended for use
in preparing ships for artificial reef habitat, they are also applicable to in-water uses of vessels
such as breakwaters or other types of barriers. It is recommended that the BMPs be used for
preparing a vessel to serve as a breakwater; however, additional vessel preparations are most
likely necessary. Placement of a vessel in a high energy environment (e.g., where there is
significant wave, current, or tidal action) would likely result in more rapid degradation of a
vessel structure than if placed at typical reef locations. If ships are to be placed in high
intensity/energy environments, additional vessel preparation measures will be necessary.

Each project should be analyzed to determine what additional preparations are necessary beyond
those recommended for preparing vessels to serve as reef habitat. For example, non-friable
asbestos and intact/undisturbed or sealed friable asbestos deemed acceptable to remain on the
vessel if used as reef habitat may need to be removed to prevent any release of asbestos that may
occur when placed in a persistently high energy environment.  For the same reason, it may also
be necessary to remove negatively buoyant vessel debris as well as some affixed ship
components and fixtures.

Water depth at a breakwater site may critically affect a vessel's stability and long-term structural
integrity. In this case, average wave energy in large, open  bodies of water as a function of water
depth is the major concern. The vessel itself may break apart over time if placed in a high
energy wave environment.

Wave interaction with a vessel serving as a breakwater can be destructive; however, the
magnitude of such destruction to the vessel is difficult to predict.  The wave interaction is
primarily dependent on wave height, wave speed, depth of the breakwater, as well as the
composition and configuration of the "vessel" breakwater itself. Wave energy can resuspend
bottom sediments, causing siltation on the vessel or destabilization of the vessel's structure
which could in turn move short distances or entirely off the original breakwater site. Planning
for worst-case storms may be required at breakwater sites where movement of the vessel would
be detrimental to various ecosystem components.
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                                     Appendix A

                 National Defense Authorization Act for Fiscal Year 2004

The National Defense Authorization Act for Fiscal Year 2004 (PL 108-136) included two
provisions relating to the use of vessels as artificial reefs.  One such provision, § 3516 (PL 108-
136, Div. C, Title XXXV, § 3516, Nov. 24, 2003,117 Stat. 1795), amended the Bob Stump
National Defense Authorization Act for Fiscal Year 2003 (PL 107-314, Div. C, Title XXXV, §
3504(b), Dec. 2,2002,116 Stat. 2754; 16 U.S.C. 1220 note) to read in pertinent part as follows:
        (b) Environmental Best Management Practices for Preparing Vessels for Use
     as Artificial Reefs.—

              (1) Not later than March 31, 2004, the Secretary of Transportation, acting
     through the Maritime Administration, and the Administrator of the Environmental
     Protection Agency shall jointly develop guidance recommending environmental best
     management practices to be used in the preparation of vessels for use as artificial
     reefs.

              (2) The guidance recommending environmental best management practices
     under paragraph (1) shall be developed in consultation with the heads of other Federal
     agencies, and State agencies, having an interest in the use of vessels as artificial reefs.

              (3) The environmental best management practices under paragraph (1)
     shall ~
              (A) include recommended practices for the preparation of vessels for use as
            artificial reefs to ensure that vessels so prepared will be environmentally sound
            in their use as artificial reefs;
              (B) promote consistent use of such practices nationwide;
              (C) provide a basis for estimating the costs associated with the preparation of
            vessels for use as artificial reefs; and
              (D) include mechanisms to enhance the utility of the Artificial Reefing
            Program of the Maritime Administration as an option for the disposal of
            obsolete vessels.

              (4) The environmental best management practices developed under
     paragraph (1) shall serve as national guidance for Federal agencies for the preparation
     of vessels for use as artificial reefs.
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              (5) Not later than March 31, 2004, the Secretary of Transportation, acting
     through the Maritime Administration, and the Administrator of the Environmental
     Protection Agency shall jointly establish an application process for governments of
     States, commonwealths, and United States territories and possessions, and foreign
     governments, for the preparation of vessels for use as artificial reefs, including
     documentation and certification requirements for that application process.

              (6) The Secretary of Transportation shall submit to Congress a report on the
     environmental best management practices developed under paragraph (1) through the
     existing ship disposal reporting requirements in section 3502 of Floyd D. Spence
     National Defense Authorization Act for Fiscal Year 2001 (as enacted into law by
     Public Law 106-398;  1654A-492) [Pub.L. 106-398, Div. C, Title XXXV, § 3502, Oct.
     30, 2000,114 Stat. 1654A-492,  which is not classified to the Code].  The report shall
     describe such practices, and may include such other matters as ths Secretary considers
     appropriate.
The second such provision, § 1013 (PL 108-136, Div. A, Title X, § 1013, Nov. 24, 2003,117
Stat. 1590), amended Title 10 of the United States Code by adding section § 7306b. New §
7306b (a) authorizes the Secretary of the Navy to transfer vessels stricken from the Naval Vessel
Register for use as an artificial reef. New § 7306b (c) requires the Secretary of the Navy to
ensure that the preparation of a vessel transferred pursuant to 10 U.S.C. § 7306b (a) for use as an
artificial reef is conducted in accordance with the environmental best management practices
developed pursuant to 16 U.S.C. § 1220 note and applicable environmental laws. The complete
text of Section 1013 of the National Defense Authorization Act for Fiscal Year 2004 is as
follows:
     (a) AUTHORITY TO MAKE TRANSFER- Chapter 633 of title 10, United States
     Code, is amended by inserting after section 7306a the following new section:
     'Sec. 7306b. Vessels stricken from Naval Vessel Register: transfer by gift or
     otherwise for use as artificial reefs
        '(a) AUTHORITY TO MAKE TRANSFER- The Secretary of the Navy may
        transfer, by gift or otherwise, any vessel stricken from the Naval Vessel Register
        to any State, Commonwealth, or possession of the United Slates, or any municipal
        corporation or political subdivision thereof, for use as provided in subsection (b).
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        '(b) VESSEL TO BE USED AS ARTIFICIAL REEF- An agreement for the
        transfer of a vessel under subsection (a) shall require that—
               '(1) the recipient use, site, construct, monitor, and manage the vessel only
               as an artificial reef in accordance with the requirements of the National
               Fishing Enhancement Act of 1984 (33 U.S.C. 2101 et seq.), except that the
               recipient may use the artificial reef to enhance diving opportunities if that
               use does not have an adverse effect on fishery resources (as that term is
               defined in section 2(14) of the Magnuson-Stevens Fishery Conservation
               and Management Act (16 U.S.C. 1802(14)); and
               '(2) the recipient obtain, and bear all responsibility for complying with,
               applicable Federal, State, interstate, and local permits for using, siting,
               constructing, monitoring, and managing the vessel as an artificial reef

        '(c) PREPARATION OF VESSEL  FOR USE AS ARTIFICIAL REEF- The
        Secretary shall ensure that the preparation of a vessel transferred under subsection
        (a) for use as an artificial reef is conducted in accordance with--
               '(1) the environmental best management practices developed pursuant to
               section 3504(b) of the Bob Stump National Defense Authorization Act for
               Fiscal Year 2003 (Public Law 107-314; 16 U.S.C. 1220 note); and
               '(2) any applicable environmental laws.

        ' (d) COST SHARING- The Secretary may share with the recipient of a vessel
        transferred under subsection (a) any costs associated with transferring the vessel
        under that subsection, including costs of the preparation of the vessel under
        subsection (c).

        ' (e) NO LIMITATION ON NUMBER OF VESSELS TRANSFERABLE TO
        PARTICULAR RECIPIENT- A State, Commonwealth, or possession of the
        United States, or any municipal corporation or political subdivision thereof, may
        be the recipient of more than one vessel transferred under subsection (a).

        '(f) ADDITIONAL TERMS AND CONDITIONS- The Secretary may require
        such additional terms and conditions in connection with a transfer authorized by
        subsection (a) as the Secretary considers appropriate.

        ' (g) CONSTRUCTION- Nothing in this section shall be construed to establish a
        preference for the use as artificial reefs of vessels stricken from the Naval Vessel
        Register  in lieu of other authorized  uses of such vessels, including the domestic
        scrapping of such vessels, or other disposals of such vessels, under this chapter or
        other applicable authority.1.

     (b) CLERICAL AMENDMENT- The table of sections at the beginning of such
     chapter is amended by inserting after the item relating to section 7306athe following
     new item:
         '7306b. Vessels stricken from Naval Vessel Register: transfer by gift or
          otherwise for use as artificial reefs.'.
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                                      Appendix B

             Some Legal Authorities that may Apply to Vessel-to-Reef Projects

This appendix identifies certain statutes, regulations, and executive orders that may apply to
artificial reef projects. It is not an exhaustive list.

Clean Water Act § 404 (33 U.S.C. 1344)
Placement of fill material (including structures such as those used to create artificial reefs) in
inland waters and the territorial sea require a Clean Water Act Section 404 permit from the U.S.
Army Corps of Engineers (Corps). In issuing these permits, the Corps must determine that the
permit would not cause or contribute to violations of applicable water quality standards or cause
or contribute to significant degradation of waters of the United States. EPA may prohibit,
withdraw, or restrict the use of a site if EPA determines that the placement of the artificial reef
will have an unacceptable adverse effect on municipal water supplies, shellfish beds and fishery
areas, wildlife, or recreational areas.

Clean Water Act § 401 (33 U.S.C. 1341)
Under Section 401 of the Clean Water Act,  Section 404 permits for proposed discharges of
dredged or fill material are subject to State certification as to compliance with applicable State
water quality standards. No such permit may be issued unless State certification is obtained or is
waived under Section 401.

Rivers and Harbors Act of 1866 § 10 (33 U.S.C. 403)
Section 10 of the Rivers and Harbors Act (RHA) requires a permit from the U.S. Army Corps of
Engineers for the construction of any structure (including artificial reefs) in or over any
"navigable water of the United States" (see  33 CFR Part 329), the excavation from or deposition
of material in such waters, or any obstruction or alteration in a navigable waters of the United
States.  Structures or work outside the limits of navigable waters of the United States also require
a Section 10 permit if the structure or work  affects the course, location, or condition of the
waterbody in such a manner as to impact on its navigable capacity.  Under the Outer Continental
Shelf Lands Act (43 U.S.C. 1333(e))5 Section 10 permit requirements also apply to the creation
of structures on the Outer Continental Shelf of the United States, including artificial reefs.  33
C.F.R. 322.(3)(b).

Liberty Ship Act (16 U.S.C. §§ 1220, et seq.)
This Act allows States to apply to the Secretary of the Department of Transportation (DOT) for
the use of DOT owned obsolete vessels as an artificial reef for the conservation of marine life.
This Act requires that the State application to DOT include a certification from EPA that the
proposed use of the vessel will be compatible with "applicable water quality standards and other
appropriate environmental protection requirements" (16 U.S.C. §§ 1220 (b)).

National Fishing Enhancement Act of 1984 (33 U.S.C. §§ 2101, et seq.)
This Act applies to artificial reefs in waters  of the United States or on the Outer Continental
Shelf for the purpose of enhancing fishery resources. The Act obligates NOAA to issue a
national artificial reef plan that addresses issues such as siting and design criteria. This Act also
amends the Liberty Ship Act by moving responsibility for Liberty Ships from the Department of

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Commerce to the Department of Transportation, as well as moving responsibility of all obsolete
vessels owned by the Department of Transportation to States that apply for and acquire them. In
addition, this Act establishes further requirements to be applied by the Corps in the exercise of
its permitting authority over artificial reefs,

Coastal Zone Management Act of 1972 (16 U.S.C. §§ 1452, et seq.)
The Coastal  Zone Management Act establishes a Federal/State partnership to provide for the
comprehensive management of coastal resources.  States develop management programs based
on enforceable policies and mechanisms to balance resources protection and coastal development
needs.  The Federal consistency provisions require that all Federal activities (including direct
Federal actions and Federal financial assistance to state and local governments) be consistent to
the maximum extent practicable with the enforceable policies of a state's Federally-approved
coastal management program.  Any applicant for a Federal license or permit must be consistent
with the enforceable policies of a State's coastal management program.

Toxic Substance Control Act (15 U.S.C. §§ 2601, et seq.)
The Toxic Substance Control Act bans the manufacture., processing, use, and distribution in
commerce of PCBs and directs the EPA to set regulations for the disposal of PCBs. The PCB
program has historically used a limit of k50 ppm for the disposal of PCBs.  PCBs ^50 ppm are
regulated for disposal at 40 CFR 761. The sinking of ships containing PCBs at regulated levels
(^50 ppm) is considered PCB disposal and requires approval under §761,62(c) from the U.S.
EPA. PCBs may be found in a variety of shipboard materials but the location and concentration
may vary from item to item and within classes of items. There are two ways to determine
regulatory status of items suspected to contain PCBs: 1) assume "worst case" (&50 ppm) and
remove the suspect item(s), or 2) sample and analyze the items for PCB concentration.

Federal Insecticide, Fungicide, and Rodenticide Act Amendments of 1988 (7 U.S.C. 136-
1367)
EPA has used its authority under FIFRA to regulate antifoulant paints, including those
containing organotins, copper, and other compounds. Such paints which make antifoulant claims
are pesticides under FIFRA. As part of the partial conclusion of the TBT Special Review, EPA
used its FIFRA authority to impose requirements, such as certification and training for
applications  and other label requirements dealing with TBT applications and disposal.

Organotin Antifouling Paint Control Act of 1988 (33 U.S.C. 2401-2410)
Organotin-based antifoulant systems are also regulated pursuant to OAPCA, which presently
prohibits use of organotin-antifouling paints on vessels under 25 meters in length (excluding
aluminum hulls, outboard motors, and external drive units), and restricts the leaching rate of
organotin antifoulant paints used on larger vessels.


           Additional Legal Authorities that may Apply to teasel-to-Reef Projects
    •   Endangered Species Act (16 U.S.C,           •  Magnuson-Stevens Fishery
       1531)                                         Conservation and Management Act
                                                     (16 U.S.C. 1801, et seq.)
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      Fish and Wildlife Conservation Act           •   Fish and Wildlife Coordination Act
      of 1980(16U.S.C. 2901-2912, et                (16U.S.C. 661-666c)
      seq.)
                                               •   National Environmental Policy Act
      Marine Mammal Protection Act of               of 1969 (42 U.S.C. 4321,4331-4335,
      1972 (16 U.S.C. 1361,1371-1384                4341-4347)
      note, 1386-1389,  1401-1407,1411-
      1418,1421-1421H)                         •   National Marine Sanctuary Program
                                                   Regulations (15 C.F.R. Part 922)
      Migratory Bird Conservation Act (16
      U.S.C. 715-715r)

      National Marine Sanctuaries Act (16
      U.S.C. 1431,etseq.)
            Some Executive Orders that may Apply to Vessel-to-Reef Projects

   *  Executive Order Number 12962 (60          •   Executive Order Number 11990 (42
      FR 30769) - Recreational Fisheries               FR 26961) - Protection of Wetlands
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                                      Appendix C

Information related to materials found on scuttled vessels that may have potentially hazardous
                           effects on the marine environment*

"The text provided in this appendix is an excerpt from the 2003 "Draft Policy Statement of the National Marine
Sanctuary Program: Artificial Reef Permitting Guidelines."

Scuttled Vessels
The scuttling of vessels requires particular attention in this policy because of their size and
potential lexicological effects on the environment. As discussed above, sunken ships potentially
attract divers away from natural reefs and thus may be beneficial to natural reefs in NMSs.
However, there is a wide array of concerns that must be addressed before intentionally sinking a
ship.

The removal of petroleum products, hazardous materials, paint cans, batteries, plastics, oil, and
fuel is specified on the U.S. Coast Guard's Ocean Disposal/Artificial Reef Inspection form.
Additionally, under the Toxic Substances Control Act (TSCA), the EPA has the authority to
gather information on and regulate chemical substances and mixtures imminently hazardous or
presenting unreasonable risk of injury to public health  or the environment. Despite these
controls, some materials of concern may still remain on items used as artificial reef material.
Such materials include: asbestos, polychlorinated biphenols  (PCBs), iron, lead paint, and
antifouling paint. The NMSP should consider the risks associated with materials remaining on
vessels to be used as artificial reefs.

Asbestos is the name given to six naturally occurring minerals that are used as insulators and fire
retardants. Several studies have investigated the effects of asbestos on fish (Batterman and Cook
1981, Belanger et al. 1990, Belanger et al 1986, Woodhead  et al 1983). The findings indicate
that asbestos concentrations on the order of lOeto lOsfibers/L 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. Undisturbed, non-friable (not
easily crumbled) asbestos has been found to be relatively harmless (Garcia and Salzwedel 1995,
Montoyae/o/1985),

PCBs may still exist in water-tight gaskets, cable insulation, paint, transformers, capacitors, and
other components of decommissioned Navy vessels (Matore et al, 1996, Eisler and Belisle 1996).
These chemicals have been implicated in: reduced primary productivity in phytoplankton;
reduced hatchability of contaminated fish and bird eggs; reproductive failure in seals; altered
steroid levels and subsequent reproductive impairment in fish and sea stars; reduced fertilization
efficiency in sea urchins; and reduced plasma retinal and thyroid hormone levels potentially
leading to increased susceptibility to microbial infections, reproductive disorders and other
pathological alternation in seals and other marine mammals  (Adams and Slaughter-Williams
1988, Brouwer et al. 1989, Clark 1992, den Besten et al. 1991).

Antifouling  paints typically containing tributyltin (TBT) and copper (Cu) are often used to paint
vessel hulls  to inhibit the growth of organisms below the water line. An IMO convention to
control the use of harmful anti-fouling systems on ships was adopted on October 5,2001. The
convention will prohibit the use of harmful organotins, including TBT, in anti-fouling paints
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used on ships and establish a mechanism to prevent the potential future use of other harmful
substances in anti-fouling systems. TBT has been found to be toxic to non-target, non-fouling
organisms at low levels (approximately 7.5-10.5 ng TBT/L).  One of its most marked effects has
been the induction of shell thickening and growth anomalies  in oysters and imposexzin the
dogwhelk Nucella lapillus potentially leading to sterility (Gibbs et al. 1998). The discovery of
the highly toxic nature of TBT-based paints has led many countries to ban the use of these paints
for non-aluminum hulled vessels less than 25 meters in length. Copper, though an effective
antifoulant, has not been shown to cause extensive effects on non-target organisms at relatively
low levels. When present in high concentrations, however, copper can be toxic to aquatic life
(Sorrenson 1991). In a study conducted when a cargo ship collided with part of the Great Barrier
Reef and remained grounded for 12 days, sediment containing 8.0 mg kg supenM) TBT, 72 mg
kg super(-l) Cu and 92 mg kg super(-l) Zn was found to significantly inhibit larval settlement
and metamorphosis (Negri et al. 2002). At this level of contamination, larvae survived but
contracted to a spherical shape and swimming and searching behavior ceased. At higher
contamination levels, 100% mortality was recorded. These results indicate that the contamination
of sediment by anti-fouling paint has the potential to significantly reduce coral recruitment in the
immediate vicinity of the site and that this contamination may threaten the recovery of the
resident coral community unless the paint is removed.

Iron, an essential element like copper, can be contributed to the environment from steel hulls of
sunken vessels. As an essential element, iron levels will tend to be closely regulated by
organisms, and thus, it is unlikely that any pollution-derived  effects will be observed except in
severe and localized cases (Thompson 1990). Corals living in seawater with high iron
concentrations have been shown to incorporate the iron into their skeletons (Brown et al. 1991).
Studies on phytoplankton and macroalgae indicate that in areas where plant nutrients such as
nitrate and phosphate are abundant the availability of iron is actually a limiting factor in growth
and biornass (Coale et al. 1996, Frost 1996, Matsunaga et al. 1994, Takeda 1998, Wells et al
1995). Hence the concern of unnatural iron inputs from artificial reefs seerns to center not on the
occurrence of adverse toxicological effects in marine organisms, but rather on the alteration of
the composition of natural assemblages of algae and species which compete with algae.

Lead paint has been used on the interiors of some vessels. Lead has no biological function and,
therefore, exhibits accumulation trends  in organisms (Thompson  1990). Corals have been shown
to incorporate lead into their skeletons (Dodge and Gilbert 1984). Unicellular algae and sea
urchins appear to be the most sensitive marine organisms (Berhard 1980). Growth inhibition has
been observed in the algae species Thalassiosira pseudonana and Porphyridium marinwn
exposed to lead as well as in sea urchins.

Despite the potential toxicological effects of the chemicals discussed above, adverse effects will
not occur unless the chemicals are present at or above their effective concentrations. The South
Carolina Department of Natural Resources completed an assessment in the mid-1990s on the
levels of PCB and heavy metals in biota found on ex-military ships used as artificial reefs. Over
100 samples were collected from locations along the South Carolina coast. Of the 80 tissue
samples analyzed for PCBs, only  19 were found to contain concentrations above the 100 ppb
weight wet limit of quantitation and all  were well below the U.S.  Food and Drug
Administration's alert action level of 2000 ppb weight wet. (Note that being below safe levels for
human consumption does not necessarily mean there are no adverse effects on the marine

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organism itself.) No significant differences were detected in the tissues of organisms collected
from vessels know to contain PCB-laden materials, vessels suspected to have PCB-laden
materials, and natural hard bottom control sites. Although some of the collected samples were
moderately high in a particular heavy metal, no clear correlation was found between high metal
levels and a particular type of sample site. Gastropods, however, did contain  much higher levels
of lead, possibly attributed to the fact that they would graze directly on the painted surfaces.
South Carolina concluded that the PCB and metal levels detected in the study did not indicate
increased hazards around military ships used as artificial reefs.

References
Adams, J.A. and S. Slaughter-Williams. 1988. The effects of PCBs on fertilization and
       morphology mArbaciapunctulata. Water Air Soil Pullot. 38: 299-310.
Batterman, A.L. and P.M. Cook. 1981. Determination of mineral fiber concentrations in fish
       tissues. Can. J. Fish. Aquat. Sci. 38: 952-959.
Belanger, S.E., K. Schurr, D.A. Allen, and A.F. Gohara. 1986. Effects of chrysotile asbestos on
       coho salmon and green sunfish: evidence of pathological stress. Environ. Res. 39: 74-85.
Belanger, S.E., D.S. Cherry, and J. Cairns, Jr. 1990. Functional and pathological impairment of
       Japanese Medaka (Oryzias latipes) by long-term asbestos exposure. Aquat. Toxicol. 17:
       133-154.
Brouwer, A., P.J.H. Reijnders, and J.H. Koeman.  1989. Poly chlorinated biphenol (PCB)-
       contaminated fish induces vitamin A and thyroid hormone deficiency in the common
       seal. Aquatic Toxicology. 15: 99-106.
Brown, B.E., A.W. Tudhope, M.D.A. Le Tissier, and T.P. Scoffin. 1991.  A novel mechanism for
       iron incorporation into coral skeletons. Coral Reefs 10: 211-215.
Clark, R.B. 1992. Marine  Pollution. Clarendon Press, Oxford, 172.
Coale, K.H., S.E. Fitzwater, R.M. Gordon, K.S. Johnson, and R.T. Barber. 1996. Control of
       community growth and export production by upwelled iron in the equatorial Pacific
       Oceaa Lett. Nature 379:  621-624.
den Beston, P.J., J.M.L. Elenbaas, J.R. Maas, S.J. Dieleman, H.J. Herwig, and P.A. Voogt. 1991.
       Effects of cadmium and potychlorinated biphenols on steroid metabolism and
       cytochrome P-450 monooxygenase system in the sea star Aster ias rubens L.
       AquaticToxicology. 20: 95-100.
Frost, B.W. 1996. Phytoplankton bloom on iron rations. Nature 383: 475-476.
Garcia, C.B. and H. Salzwedel. 1995. Successional patterns on fouling plates in the Bay of Santa
       Marta, Colombian Caribbean. An. Inst. Invest. Mar. Puntade Betin. 24: 95-121.
Gibbs, P.E., P.L. Pascoe, and G.R. Burt. 1988. Sex change in the female dog-whelck, Nucella
       lapillus, induced by tributyltin from antifouling paints. J. Mar. Biol. Ass. U.K. 68:715-
       731.
Matore, R.M., T.D. Mathews, and M. Bell. 1998. Levels of PCBs and heavy  metals in biota
       found on ex-military ships used as artificial reefs. South Carolina Department of Natural
       Resources, Charleston, South Carolina.
Matsunaga, K.., Y. Suzuki, K. Kuma, and I. Kudo. 1994. Diffusion of Fe(II) from an iron
       propagation cage and  its effect on tissue iron and pigments of macroalgae on the cage. J.
       Appl. Phycol. 6: 397-403.
Montoya, A.J., Q.R. Quesada, Z.E. Madriz, M.E. Castro, and P.O. Urpi. 1985. Comparative
       analysis of substrates for collection of mangrove oyster spat in Viscaya estuary, Limon,
       Costa Rica. Rev. Biol. Trop. 33: 1-6.

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Negri, A.P., L.D. Smith, N.S. Webster, A.J. Hey ward. 2002. Understanding ship-grounding
       impacts on a coral reef: potential effects of anti-foulant paint contamination on coral
       recruitment. Mar. Pollut. Bull. Vol. 44:111-117.
Sorrenson, E.M. 1991. Metal poisoning in fish. CRC Press, Inc., Boca Raton, 374 pp.
Takeda, S. 1998. Influence of iron availability on nutrient consumption ratio of diatoms in
       oceanic waters. Nature 393: 774-777.
Thompson, D.R. 1990. Metal levels in marine vertebrates. In R.W. Furriess and P.S. Rainbow
       (eds.), Heavy Metals in the Marine Environment.  CRC Press, Inc., Boca Raton, pp 143-
       183.
Wells. M.L. N.M. Price, and K.W. Bruland. 1995. Iron chemistry in seawater and its relationship
       to phytoplankton: a workshop report. Mar. Chem. 48: 157-182.
Woodhead, A.D., R.B. Setlow, and V. Pond. 1983. The effects of chronic exposure to asbestos
       Fibers in the Amazon molly, Poecelia Formosa. Environ. International. 9:173-176.
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                                      Appendix D

              Developing Workplansfor Vessel Preparation Prior to Reefing

Determining the type and location of the potential sources of contamination from a vessel
intended for use as an artificial reef should be conducted as part of a workplan for vessel clean
up and preparation. The purpose of such a workplan is to assure that materials of concern
potentially contributing to pollution of the marine environment are addressed prior to reefing.
The development of a workplan also can allow for more effective clean-up efforts during vessel
preparation by guiding activities such as salvage operations and possibly diver safety
preparations in a manner that minimizes debris and contamination that must be cleaned up or
properly disposed.

Information which may be useful in the preparation of a workplan could include:
       •  Asbestos documentation for the vessel;
       •  PCB documentation for the vessel;
       *  Documentation that naval vessels  have been previously demilitarized and certified to
          be radiologically decontaminated;
       •  Documentation that refrigerants and halons have been removed from shipboard
          systems;
       •  Information on hazardous materials onboard the vessel;
       •  Information on exterior hull paint which could include paint type and date of last
          application;
       •  General drawings of machinery, compartments, and tank layouts;
       •  Description of vessel dimensions including size, weight, and superstructure materials;
       •  Tank soundings describing the volume and contents of fuel oil tanks  prior to
          preparation for reefing;
       •  List of items with beneficial reuse potential to be salvaged prior to sinking;
       •  Assessment of applicable laws and regulations, including permit requirements; and
       •  Reef site surveys and proposed site preparation.
An assessment of the above mentioned information could then direct the preparation actions
needed for the reef project workplan. Some general workplan actions include:

       •  Assess vessel drawings and dimensions;
       •  Identify which items will remain on the vessel;
       •  Identify items to be salvaged prior to sinking;
       •  Estimate economic viability of the reef project (including permit costs and
          timeframes);
       •  Determine if the vessel is a good candidate (i.e., does the workplan fall within
          reasonable time and financial commitments);
       •  Coordinate with all regulatory agencies, local, regional, State and Federal, as well as
          stakeholders,  during all project phases;
       •  Apply for and receive the appropriate permits for the project;
       •  Remove hazardous materials and clean vessel;
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       •  Inspect vessel to clear all findings (that the workplan for removal of materials as well
          as the vessel clean-up is met);
       •  Conduct vessel stability analysis;
       •  Develop strategy for vessel sinking;
       •  Notify NOAA to update nautical charts once the ship has settled on the ocean floor;
          and
       •  Deploy relevant aids to navigation and mooring/marker buoys at the site.
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                                      Appendix E

                    General Principles for a Vessel Clean-up Operation

In order to prepare a vessel intended to create an artificial reef, a workplan should be developed
to direct cleaning operations - as described in Appendix D. Salvage operations should take place
first, being careful to minimize debris and contamination with oils or other products that will
need cleaning sometime during the vessel preparation.  Other vessel clean-up preparations to be
considered include:

       *  Re-use/recycle/dispose of all or some vessel components - besides ferrous scrap
          materials, there may be high value components onboard the vessel, such as non-
          ferrous metals (e.g., copper, aluminum, nickel), and re-useable equipment such as
          generators, machines, pumps, and cranes;
       •  Generally, clean-up operations should begin at the highest part of the compartment or
          tank and proceed downwards to the bilge;
       •  Deal with the large concentrations of oil and hazardous products early in the
          operation;
       •  Keep compartments clean and make concerted efforts to avoid spillage during salvage
          and clean-up operations; and
       •  Consider removing, instead of cleaning, heavily contaminated machinery and piping.
          Removal may be quicker and less expensive. Removal may also allow for less
          overall effort in clean-up as access to the contaminated machinery and piping is
          improved and ongoing contamination from drips and seepage is minimized.
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                                      Appendix F

             Suggested Cleaning Methods for Liquid Hydrocarbons (fuels, oils)
                                and Semi-solids (greases)

Tanks
Methods for cleaning tanks include but are not limited to:

   •   Mechanical Cleaning: Mechanical cleaning involves mechanical removal of sludge and
       remaining fluids and wiping down all surfaces with oil absorbent material. Although
       manpower intensive, this cleaning method limits the spread of contamination and does
       not require large volumes of fluids that are expensive to dispose.

   •   Steam or Hot Water Cleaning: This method is quite effective, although it requires special
       equipment and generates large volumes of oily water. If this method is considered, a plan
       should be developed so that oily water generated during this cleaning method is dealt
       with in accordance with all applicable regulations.  Surfactants or soaps are not
       recommended, as they tend to emulsify any oil present and make the oily water
       exceptionally difficult to treat. This would likely create higher disposal costs.  In tanks
       where deckheads and sides are reasonably free of contamination, pressure washing can
       cause significant contamination of these otherwise clean surfaces through splashing,
       misting, and carry-over.

   •   Solvent Washing: Solvent washing may be an option where there are especially difficult
       residuals or deposits that need removal.  Note that the use of solvents will require special
       handling and disposal of all liquid product generated as wastes.

In rare cases, especially where low-grade fuels have been stored, it may be necessary to resort to
advanced tank cleaning methods such as ultrasonic or special solvents. It may also be
advantageous to use a combination of several different methods, depending on the nature and
location of the contamination.  In general, mechanical cleaning would be the first method to try,
followed by steam/hot water washing, then solvent washing in extremely difficult situations.
Whatever method is selected, the effluent and water should be collected and treated. Large
volumes will require the services of a pumper truck or barge, while smaller quantities should be
collected and stored in drums and removed from the vessel. Caution should be used during all
transfer operations to avoid spills. If transferring large quantities of oil or oil contaminated
liquid, a boom around the vessel should be used to minimize the extent or spreading of a release.

Fuel and Oil Pipe Fittings, Piping with Manifolds, and Filling Points

       Filling points:  All filling stations or deck fittings that were used for receiving fuels, oils
       or other hydrocarbons should be opened and cleaned. Access to the filling stations and
       deck fittings is necessary to ensure that they are completely drained and free of
       hydrocarbons.  This will typically require access from the bottom and the top.

       Fuel and Oil Piping Including Manifolds:  Fuel and oil piping (including non-segregated
       ballast systems) should be drained of all product. The cleaning and opening of pipes

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       varies according to the type of product that was contained in the lines.  In general, the
       more viscous the product, the more opening of pipes and cleaning activity will be
       required. For very viscous products (e.g., No. 6 fuel oil or Bunker C fuel as described in
       the "Oil and Fuel" section of this document), all piping and fittings should be fully
       opened for visual inspection.

       Vertical piping runs should have all valves completely opened and any blanking flanges
       or spectacle plates removed for cleaning.  Horizontal piping runs should be opened at low
       spots. Once draining of piping systems is completed, no visual evidence of hydrocarbon
       weeping should exist at openings.

       Fuel and Oil Piping Fittings: Fittings consist of valves, site glasses, coolers, siphon
       breakers, and filters.  A visual examination of internals, or a cut through the lowest point
       of the fitting may be useful. Where fittings are of complex construction or have more
       than one oil-tight compartment (as in coolers), then access to all sub-compartments or
       components may be necessary. No visual evidence of hydrocarbon weeping should exist
       at openings.

       Unless the piping  is clearly identified as being part of a non-hydrocarbon system or there
       is clear evidence to indicate that the system was not part of a hydrocarbon containing
       system (e.g., seawater piping to coolers, fresh water piping to domestic spaces), it should
       be assumed that the piping contained hydrocarbons.  Fittings should be cleaned, or
       removed from the vessel.

Bilge Compartments and Piping
All piping mat runs through the bilge areas of machinery spaces should be assumed to be
contaminated by hydrocarbons until proven otherwise. Piping in bilge spaces should follow  the
clean-up suggestions as presented in the subsection above entitled "Fuel  and Oil Piping
Including Manifolds."

Combustion Engines
           Structure:        Remove access panels, explosion doors, handhold doors,
                           maintenance panels, gear covers, bearing covers/retaining plates,
                           as necessary to remove oil. Visible oil should be removed from all
                           internal components.  The surrounding and support structure
                           should be made accessible for inspection, especially the area under
                           the engine. At least one main bearing should be opened to
                           determine if the design allows oil to be trapped, thereby indicating
                           whether all bearings should be opened and cleaned.

           Fuel System:     All fuel system components should be cleaned or removed from
                           the engine. These include injectors, carburetors, supply,
                           distribution and return lines, filters, pumps, relief valves, pressure
                           regulating mechanisms, governors, and heat exchangers.  Removal
                           of these items will prevent fuel seepage from their connections. If
                           these items are to be sunk with the vessel, they should be opened,
                           cleaned, and prepared for inspection.

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           Lubricating
           Oil System:
           Other Systems:
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       Lubricating oil sumps should be drained and opened for
       cleaning and visual inspection.  This may require that additional
       access openings be made. All lubricating oil piping, both internal
       and external to the engine, should either be removed or drained.
       Lubricating oil system components should either be cleaned or
       removed from the vessel.  Internal oil gallery plugs should be
       removed. Pedestal and thrust bearings should be drained. Engine
       driven oil pumps should be pulled or cleaned.  Engine oil filling
       and dirty oil drainage arrangements should be removed or cleaned.

       Other components and systems  susceptible to contamination with
       hydrocarbons (e.g., superchargers, turbochargers, air filters) should
       be examined visually and cleaned if hydrocarbons are present.
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                                 REFERENCES

Delaware Department of Natural Resources and Environmental Control's (DNREC)
          Program Summary and Endorsement of NYC Transit's Plan to Use Subway Cars as
          Artificial Reef Material. 2001.

Environment Canada. 1998. Cleanup Guidelines for Ocean Disposal of Ocean Vessels. Artificial
          Reef Society of British Columbia website.
          [http://www.arti ficialreef.bc.ca/ARresources/cleanup^ui delines.html]

Environment Canada. 1998. Cleanup Standards for Ocean Disposal of Vessels. Artificial
          Reef Society of British Columbia website.
          [http://www.arti ficialreef.bc.ca/ARresources/cleanup_standards.html]

Lukens, Ronald R. 1997. Guidelines for Marine Artificial Reef Materials. Final report of the
      Artificial Reef Subcommittee of the Technical coordinating committee Gulf States
      Marine Fisheries Commission.
      [http://www. gsmfc .org/pubs/SFRP/Guidelines_for_Marine_Artificial_Reef_Materials_January_l 997.pdf)

London Convention. Revised 2003. Waste-Specific Guidelines for Vessels Proposed for
          Disposal at Sea (Waste Assessment Guidelines for Vessels).
          [http://www.londonconvention.org/documents/guidelines/4%20-%20Vessels.pdfJ

OSPAR Commission. 1999. OSPAR Guidelines on Artificial Reefs in relation to Living Marine
          Resources.  OSPAR Convention for the Protection of the Marine Environment of the
          North-East Atlantic. (Reference Number: 1999 -13). ANNEX 6 (Ref. Section 3.24).

San Diego Oceans Foundation, Marine Technology Society, and the Artificial Reef Society of
          British Columbia. 2000. Proceedings from Artificial Reef Conference: Converting
          Unused Ships and Structures to Enhance Ocean Environments. San Diego,
          California.

U.S. Department of Commerce. 1985. National Artificial Reef Plan. NOAA Technical
          Memorandum NMFS OF-6. National Marine Fisheries Service. Washington, D.C.

U.S. Department of Commerce. 2002. Draft National Artificial Reef Plan (February 2002).
          NOAA, National Marine Fisheries Service. Silver Spring, Maryland.

U.S. EPA. 2000. A Guide for Ship  Scrappers: Tips for Regulatory Compliance.
          EPA/315-B-00-001.  Environmental Protection Agency. Washington, D.C.

U.S. Navy. Material Management for Radioactive Items in the DoD. DLAINST 4145.8
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