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U.S. Environmental Protection Agency
U.S. Maritime Administration
National Guidance: Best Management Practices for
Preparing Vessels Intended to Create Artificial Reefs
May 2006
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ACKNOWLEDGEMENTS
This document was jointly developed by the U.S. Environmental Protection Agency's (EPA)
Oceans and Coastal Protection Division within the Office of Water and the Department of
Transportation's Maritime Administration. To assist in early stages of document development,
an interagency workgroup was established by Laura S. Johnson of EPA. The following agencies
actively participated on this workgroup:
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
Photo courtesy of Laura S. Johnson
Maritime Administration's James River Reserve Fleet, Virginia.
Cover Photos
Top photo: Ex-USS Spiegel Grove en route to artificial reef sink site. Photo courtesy of Andy Newman, Florida
Keys News Bureau.
Middle photo: Ex-USS Spiegel Grove resting at its artificial reef site. Photo courtesy of Florida Fish and Wildlife
Conservation Commission, Division of Marine Fisheries Management, Artificial Reef Program.
Bottom photo: The scuttling of Navy Dive Tender YDT-14 on April 1, 2000, approximately 18 miles SE of
Pensacola Pass, Escambia County, Florida. Photo courtesy of Florida Fish and Wildlife Conservation
Commission, Division of Marine Fisheries Management, Artificial Reef Program.
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TABLE OF CONTENTS
Executive Summary 7
Introduction 9
Siting of Artificial Reefs 17
Guidance for Preparing Vessels to Create Artificial Reef Habitat
Oil and Fuel
Narrative Clean-up Goal 22
What are oil and fuel? 22
What are the potential environmental impacts
of oil and fuel? 22
Where are oils and fuels found in a ship? 23
How should the vessel be prepared; what are the
appropriate BMPs for oil and fuel? 24
Asbestos
Narrative Clean-up Goal 30
What is asbestos? 30
What are the potential environmental impacts
of asbestos? 31
Where is asbestos found on a ship? 31
How should the vessel be prepared; what are the
appropriate BMPs for asbestos? 32
Polychlormated Biphenyls (PCBs)
Narrative Clean-up Goal 35
What are PCBs? 35
What are the potential environmental impacts of PCBs? . .35
Where are PCBs found on a ship? 36
How should the vessel be prepared; what are the
appropriate BMPs for PCBs? 37
Paint
Narrative Clean-up Goal 40
What types of paint and anti-fouling systems are used
on ships and where are they found? 40
What are the potential environmental impacts
ofpaint? 41
How should the vessel be prepared; what are the
appropriate BMPs for paint? 41
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Solids/Debris/Floatables
Narrative Clean-up Goal 43
What are solids/debris/floatables? 43
What are the potential environmental impacts
of solids/debris/floatables? 43
Where are solids/debris/floatables found on ships? .... 44
How should the vessel be prepared; what are the
appropriate BMPs for solids/debris/floatables? . . 44
Other Materials of Environmental Concern
Narrative Clean-up Goal 46
What are other materials of environmental concern? . ... 46
What are the potential environmental impacts of
other materials of environmental concern? 46
Where are other materials of environmental concern
found on ships? 46
How should the vessel be prepared; what are the
appropriate BMPs for other materials of
environmental concern? 46
Considerations for Other In-water Uses of Obsolete Vessels
Diving Opportunities 50
Exhibits
Exhibit 1: Summary of Narrative Clean-up Goals for
Materials of Concern
Exhibit 2: Ex-USS Spiegel Grove Total Project Costs 11
Exhibits: Ex-US S Spiegel Grove Vessel Specifications 11
Exhibit 4: Ex-USS Oriskany Total Project Costs 12
Exhibits: Ex-USS Oriskany Vessel Specifications 12
Appendices
Appendix A: Federal Statutes Related to the Transfer of
Obsolete MARAD and Navy Vessels for Use as
Artificial Reefs 51
Appendix B: Federal Environmental Laws Relevant for
Consideration in the Preparation of a Vessel for
Use as an Artificial Reef 57
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Appendix C: Information Related to Materials Found on
Scuttled Vessels that may have Potentially Hazardous
Effects on the Marine Environment ............ 65
Appendix D: Developing Workplans for Vessel Preparation
Prior to Reefing
68
Appendix E: General Principles for a Vessel Clean-up Operation . 70
Appendix F: Recommended Checklist for Documenting
Vessel Clean-up Using this Guidance
71
Appendix G: Suggested Cleaning Methods for Oils, Fuels, and
Semi-solids (Greases) 73
References
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Photo courtesy of Florida Fish and Wildlife Conservation Commission
The scuttling of Adolphus Busch on Dec. 5, 1998, approximately 7 miles S of
Summerland Key, Monroe County, Florida.
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EXECUTIVE SUMMARY
This guidance document was developed to satisfy the mandate of Section 3516 of the National
Defense Authorization Act for Fiscal Year 2004, which requires that the Maritime
Administration (MARAD) and the U.S. Environmental Protection Agency (EPA) jointly develop
guidance recommending environmental best management practices to be used in the preparation
of vessels for use as artificial reefs. It also responds to MARAD's request for the 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.
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 obsolete and
decommissioned military and commercial vessels when employing the vessel management
option of artificial reefing. Artificial reefs should only be developed where such reefs will
enhance native marine resources and benefit the natural marine environment. Strategically sited
artificial reefs not only can 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. It is recommended that these best management practices be implemented for such
in-water uses of vessels, with the caveat that further vessel preparation beyond that employed for
artificial reef habitat may be needed. When preparing a vessel for such 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 narrative 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, polychlorinated 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.
In keeping with Section 3516 of the National Defense Authorization Act for Fiscal Year 2004,
this guidance document addresses only recommended clean-up practices for vessels that are
intended to be placed as artificial reefs. It neither endorses such placement nor does it address
the potential availability or environmental effects associated with alternatives to placement of
vessels as artificial reefs.
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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
Narrative Clean-up Goal
Remove liquid fuels and oils and semi-solids (greases) so that: no visible
sheen is remaining on the tank surfaces (this includes all interior fittings,
piping, structural members); no film or visible accumulation is remaining on
any vessel structure or component (e.g., on machinery or from spills on
decking or carpet). The end result of such clean-up should be that no sheen
be visible upon sinking a vessel.
Remove any loose asbestos and asbestos that may become loose during
vessel sinking; remove or seal accessible friable asbestos.
Remove all manufactured products containing greater than or equal to (>) 50
parts per million (ppm) of solid PCBs; remove all liquid PCBs regardless of
concentration; remove all materials contaminated by PCB spills where the
concentration of the original PCB source is > 50 ppm.
Remove harmful exterior hull anti-fouling systems that are determined to be
active; remove exfoliating (peeling) 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.
The narrative clean-up performance goals for the materials of concern highlighted in this
guidance should be achieved while preparing a vessel intended for artificial reefing. 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. These
include, but are not limited to, issues such as vessel inspections by appropriate authorities and
storage and disposal of waste generated during clean-up/preparation. Further, this document
does not provide information on how to sink a vessel or the required actions or regulatory
procedures/processes associated with the actual act of sinking a vessel.
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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 to satisfy the
mandate of Section 3516 of the National Defense Authorization Act for Fiscal Year 2004, which
requires that the Maritime Administration (MARAD) and the U.S. Environmental Protection
Agency (EPA) jointly develop guidance recommending environmental best management
practices (BMPs) to be used in the preparation of vessels for use as artificial reefs. It also
responds to MARAD's request for the 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.
An interagency workgroup, chaired by EPA, was established to develop the BMPs. The
workgroup included 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. The best management
practices presented in this document should be implemented for all permitted in-water uses of
vessels; further diver safety preparations may be needed based on the intended in-water use, such
as recreational diving.
Objectives of the Guidance Document
The BMPs, jointly developed by EPA and MARAD, are to serve as national guidance for federal
agencies for the preparation of vessels for use as artificial reefs. Section 3516 of the National
Defense Authorization Act for Fiscal Year 2004 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 MARAD's authority to transfer obsolete vessels for artificial reefing.
Below is a description of how this document addresses the four requirements of the statute.
The use of this guidance will help ensure that vessels prepared for use as artificial reefs
"will be environmentally sound in their use as artificial reefs." For each material of
concern identified, this document provides a narrative clean-up performance goal and
information on methods for addressing those goals in preparation of the vessel prior to
sinking. The preparation of vessels in this manner will help 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
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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 narrative clean-up performance goals provided in this document, if
implemented and complemented with strategic site selection (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 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
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 cleaning
and preparing 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." Although the best management
practices were developed independent of costs associated with clean-up, the narrative
clean-up performance goals in this document can be used as a basis for estimating the
cost for appropriate vessel preparation. In order to determine the estimated cost to
prepare a specific vessel for use as an artificial reef, the narrative clean-up performance
goals, along with the vessel preparation BMPs, can be used to scope the volume of work
to be accomplished based on a detailed ship-check and implementation of a
representative PCB sampling protocol. There is wide variability of ships and associated
kinds and amounts of material found on a particular ship, as well as wide variability of
remediation and disposal costs in different geographic locations within the U.S.
Therefore, it is not possible to provide in this document representative cost estimates
associated with the preparation of a ship for reefing. A reasoned estimate of the actual
cost of preparation will require a ship-by-ship analysis.
In order to provide some insight into the costs that have been incurred for vessel-to-reef
projects, some pertinent vessel-specific information is provided here. Two recent
examples of vessels that have been prepared with the intent of serving as artificial reefs
are the ex-USS Spiegel Grove and the ex-USS Oriskany. The total cost of reefing the ex-
USS Spiegel Grove, which was a MARAD vessel, was $1.3 million.1 This total cost
includes costs for both vessel clean-up/preparation, as well as costs other than vessel
clean-up/preparation. Details of the project cost estimates are presented in Exhibit 2.
Vessel specifications for the ex-USS Spiegel Grove are presented in Exhibit 3. The ex-
USS Spiegel Grove was cleaned/prepared prior to the availability of the BMPs presented
in this document. Further information regarding the ex-USS Spiegel Grove can be found
1 Communication between Captain Spencer Slate, ex-USS Spiegel Grove vessel-to-reef project co-manager, and
Laura S. Johnson, EPA.
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at http://www.fla-keys.com/spiegelgrove/.
Exhibit 2. Ex-USS Spiegel Grove Total Project Costs
PCB sampling protocol and removal
Reorienting the vessel
Towing and berthing
Other clean-up and scuttling preparation
and execution
Ship clean-up time
Project duration
$75,000
$550,000
$125,000
$550,000
7 months
8 years
Exhibit 3. Ex-USS Spiegel Grove Vessel Specifications
Type of vessel
Overall length
Extreme beam
Keel date
Launch date
Decommission date
Location of reefed vessel
Landing Ship Dock (LSD)
5 10 feet
84 feet
Sept. 7, 1954
Nov. 10, 1955
Oct. 2, 1989
6 miles off the Florida Keys in
the Florida Keys National
Marine Sanctuary
Photo courtesy of Andy Newman
Ex-USS Spiegel Grove, once a MARAD vessel, under way to
Florida Keys for final sinking preparations.
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The total cost of reefing the ex-USS Oriskany, which is a Navy vessel, was $15.63
million. This total cost includes costs for both vessel clean-up/preparation, as well as
costs other than vessel clean-up/preparation. Details of the project cost estimates are
presented in Exhibit 4. As noted later in this document, the Navy is required to
clean/prepare vessels intended for use as artificial reefs in accordance with this BMP
guidance. The Draft BMP guidance was available for the ex-USS Oriskany vessel clean-
up/preparation. Vessel specifications for the ex-USS Oriskany are presented in Exhibit 5.
Further information regarding the ex-USS Oriskany can be found at
http://peos.crane.navv.mil/reefing/oriskany.htm.
Exhibit 4. Ex-USS Oriskany Total Project Costs
Ship remediation (BMP-related)
Flight deck remediation (BMP -related)
PCB model and risk assessment
development (BMP-related)
Towing and berthing
Scuttling preparation and execution
Ship clean-up time
Project duration
$8.28M
$3.61M
$3.74M
$3.07M
$4.90M
12 months
3 years (FY03
through FY06)
Exhibit 5. Ex-USS Oriskany Vessel Specifications
Type of vessel
Overall length
Extreme beam
Keel date
Launch date
Decommission date
Location designated for reefing this
vessel
Essex Class aircraft
carrier (CV-34)
911 ft
107ft
May 1, 1944
Oct. 13, 1945
Sept. 30, 1976
23 miles south off
Pensacola, Florida
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Photo courtesy of U.S. Navy
Ex-US S Oriskany arriving at NAS Pensacola, Florida. March 23, 2006.
If the narrative clean-up goals provided in this document cannot be economically
achieved, for example because of very significant amounts of materials of concern on the
vessel, then the vessel would not be a good candidate for reefing. 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 where clean-up could pose potential worker
safety risks or could incur high costs may not be good candidate vessels for reefing.2
Some portions of a candidate vessel may be economically salvageable. Any such salvage
operations should occur 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 some 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 vessel-
to-reef project.
2 The BMP guidance does not address worker safety issues. Readers with an interest in such safety issues
and concerns should consult other relevant documents, such as those prepared by OSHA, State or local
safety agencies, and other relevant EPA documents. For example, EPA's^ Guide for Ship Scrappers -
Tips for Regulatory Compliance presents important information related to environmental and worker safety
and health issues for ship scrapping/ship breaking operations when handling specific hazardous materials.
This document can be accessed via the World Wide Web at
http://www.epa.gov/oecaerth/resources/publications/civil/federal/shipscrapguide.pdf.
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Photo courtesy of U.S. Navy
Metal recovery and salvage operations onboard the ex-USS Oriskany while being cleaned.
In the process of preparing a vessel for reefing, there are requirements and regulations, including
permit processes, appropriate disposal of waste generated during vessel clean-up/preparation,
and vessel inspections by appropriate authorities to consider that are not discussed in great detail
in this document, with the exception of TSCA requirements applicable to PCBs. Appendix B
does provide, however, an overview of principal federal environmental statutes potentially
affecting preparation or placement of a vessel for use as an artificial reef. Further, other than
siting considerations that would affect how a vessel is prepared for use as an artificial reef, this
document does not detail the legal requirements applicable to transfer, siting, or sinking of
vessels as artificial reefs in vessel-to-reef projects, except for the overview offered in Appendix
B. The information in Appendix B is intended only for the convenience of the reader in order to
provide a useful starting point for identifying the principal environmental statutes of interest. On
a case-by-case basis, additional federal statutes also may apply, though the federal statutes
identified in Appendix B would be most relevant for the preparation of a vessel for use as an
artificial reef. The final preparation plan for any particular artificial reef project will necessarily
be vessel-specific, and will depend on the characteristics of the vessel and final permitted
artificial reef construction site, as well as regulatory considerations. In addition, State and local
laws also may apply to vessel preparation, but the document does not attempt to identify such
laws 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
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exception of materials containing PCBs, this document does not comprehensively discuss
applicable legal requirements, 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.
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.
When preparing a vessel that is intended to serve as an artificial reef, documenting the clean-up
procedures used and the contaminants that will remain onboard the vessel is a key element of the
BMPs. More specifically, a description of how the BMP narrative clean-up performance goals
were achieved, and a visual inspection, are needed to determine whether and how the vessel has
been cleaned to the level recommended in this guidance document so the vessel can be managed
appropriately. A recommended checklist for documenting vessel clean-up using this guidance
can be found in Appendix F. A vessel inspection by qualified personnel should be conducted to
confirm satisfactory clean-up/preparation. It also should be noted that applicable regulatory
regimes may require such an inspection.
Achieving and verifying satisfaction of the BMP clean-up goals could help support permit
applications under the Clean Water Act Section 404 (33 U.S.C. 1344) or Rivers and Harbors Act
Section 10 (33 U.S.C. 403), if a permit application is submitted to the U.S. Army Corps of
Engineers. Further, robust BMP documentation might prove useful for demonstrating
consistency with Coastal Zone Management Act programs (16 U.S.C. 1452, et seq.), as well as
for any other State or local certifications necessary to carry out a vessel-to-reef project. Also,
EPA officials may find BMP documentation useful as part of their review under EPA
certification authority pursuant to the Liberty Ship Act. (Note: this Act only applies to
DOT/MARAD-owned obsolete vessels intended for use as an artificial reef for the conservation
of marine life.)
This guidance does not substitute for any statute or regulation, nor is it a regulation itself. The
document recommends environmental best management practices for use in the preparation of
vessels for use as artificial reefs. Associated with the recommended environmental best
management practices are narrative environmental clean-up performance goals, as well as
recommendations and suggestions in furtherance of those goals. By its terms, the guidance itself
does not impose binding requirements on any federal agency, States, other regulatory or resource
management authorities, or any other entity. Among other things, the document includes
mechanisms to enhance the utility of the Artificial Reefing Program of the Maritime
Administration as an option for the disposal of obsolete vessels. It should be noted that under 10
U.S.C. 7306b(c), the Secretary of the Navy must ensure that the preparation of a vessel (that is
stricken from the Naval Vessel Register) for use as an artificial reef is conducted in accordance
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with the environmental best management practices in this guidance. This latter statutory
requirement, not today's guidance document itself, governs the Navy's application and use of
this document.
Organization of this Guidance Document
This document describes guidelines for the preparation of vessels in a manner that will help
ensure that the marine environment will benefit from their use as artificial reefs. Strategic siting
is an essential component of a successful artificial reef project. Before the discussion of vessel
preparation is presented, a cursory description of reef site selection recommendations is
provided.
For each material or category of material of concern identified, this document provides a
narrative clean-up 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.
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 such as recreational
diving. This potential obsolete vessel management option is 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 help 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.
Because 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, 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 targeted fishery resources to the maximum extent practicable;
minimize conflicts among competing uses of water and water resources;
minimize the potential for environmental risks related to site location;
be consistent with international law and national fishing law and not create an obstruction
to navigation;
be based on scientific information; and
conform to any federal, State, or local requirements or policies for artificial reefs.
Additional considerations that may be relevant to the placement of a vessel for the creation of an
artificial reef include:
facilitating access and use by recreational and/or commercial fishermen; and
facilitating access and use by recreational divers.
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
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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
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. Oftentimes, 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;
existing live bottom (i.e., marine areas supporting growth of sponges, sea fans, corals,
and other sessile invertebrates generally associated with rock outcrops); or
habitats of Endangered Species Act listed species and species of State and local concern.
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;
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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.
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.
Project planners should evaluate vessel-to-reef projects and potential sites with regard to
chemical and biological conditions as well as long-term durability and stability, as these will
affect future habitat value.
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 principal 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 to avoid creating a
hazard to navigation - minimum clearance above the reef should accommodate the draft of the
largest vessels expected to operate in the vicinity with an adequate safety margin. Water depth at
the site may critically affect artificial reef material stability and long-term structural integrity. In
large, open bodies of water, average wave energy as a function of water depth is the major
concern.
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Guidance for Preparing Vessels to Create Artificial Reef Habitat
Photo courtesy of Laura S. Johnson
Worker sweeping debris during flight deck removal onboard the ex-USS Oriskany.
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OIL AND FUEL
Narrative Clean-up Goal: Remove liquid fuels and oils and semi-solids (greases) so
that: no visible sheen is remaining on the tank surfaces (this includes all interior fittings,
piping, structural members); no film or visible accumulation is remaining on any vessel
structure or component (e.g., on machinery or from spills on decking or carpet). The end
result of such clean-up should be that no sheen be visible upon sinking a vessel.
What are oil and fuel?
For purposes of this guidance, the term oil includes crude oil; petroleum and petroleum-refined
products (e.g., diesel fuel, gasoline, kerosene, and bunkers); and non-petroleum oils such as
synthetic oils (e.g., silicone fluids), wood-derivative oils (e.g., resin/rosin oils), animal fats and
oil, and edible and inedible seed oils from plants, which might be more relevant for cargo
vessels.
Some common refined petroleum products and their characteristics 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. 5 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.
What are the potential environmental impacts of oil and fuel?
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
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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, they both have limited solubility in water, they both create slicks on the water surface,
and they both form emulsions and sludge. However, 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
effects).
Where are oils and fuels found in a ship?
Diesel fuel and fuel oil may be contained in various tanks throughout a 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 systems and components also
contain oils.
The vessel's piping and tank arrangements generally will contain some 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. Other types of fuels and oils may be
contained in cargo tanks.
"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.
Spills of fuels and oils may be found near cargo holds, ship store rooms, engineering spaces, and
any other equipment that may house fuel and oil.
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Photo courtesy of Laura S. Johnson
Flushed hydraulic system onboard the ex-USS Oriskany.
How should the vessel be prepared; what are the appropriate BMPsfor oil and fuel?
The aim of clean-up is to remove liquid fuels, oils, and grease. Although it is impossible to
remove all fuels, oils, and grease, a very thorough clean-up is achievable. In general, all liquid
fuels and oils and semi-solids (greases) should be drained, flushed, and 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. The opening
and cleaning of pipes varies according to the type of product that was in the lines. No visual
evidence of weeping (oozing or releasing drops of liquid) should exist at openings. An
alternative and very effective option for hydrocarbon clean-up is removal of the equipment and
piping. Suggested cleaning methods for liquid fuels and oils, and semi-solids are found in
Appendix G.
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 (e.g., oil for generators). Such used oil and grease should be removed from the vessel
before sinking. While the goal is to remove all oil and grease, 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
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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 fuel or oil 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 G. Regardless of the selected tank
cleaning method, the effluent and water must be collected, treated, and disposed of in
compliance with applicable regulations. Large volumes will require the services of a pumper
truck or barge, while smaller quantities should be collected and stored in 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 fuel or oil until proven
otherwise. Structural tanks include, but are not limited to: fuel storage/settling/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. At a minimum, liquid fuels and oils in
such tanks should be removed.
Tank interiors including deckheads should be cleaned of all fuel and oil. No visible fuel and oil
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
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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. A temperature gauge that
does 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 Seals
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.
Stern tubes and seals, if of the oil bath type, should be drained of oil. Note that draining the stern
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 unconventional propulsion systems
will be addressed on a case-by-case basis. The objective is that no oil or fuel remains 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 as described in the previous
subsection ("Non-combustion Engines, Shafting, Gearing, and Stern Seals").
Auxiliary Machinery
Auxiliary machinery that has oil 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.
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Many pieces of auxiliary machinery have a lubricating oil system or are in direct contact with
oil.
All lubricating oil system components should be stripped from auxiliary machinery, drained and
cleaned. Lubricating oil sumps should be drained and cleaned.
Hydraulics
All hydraulic systems should be assumed to have employed a petroleum- or synthetic-based fluid
that needs to be cleaned. 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 remains. 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.
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
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 cargo holds or storerooms, and interior surfaces which may have been
subject to 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. All debris
should be removed, particularly any debris contaminated with fuel, oil, or grease. 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.
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Photo courtesy of Laura S. Johnson
Oil absorbent pad in engine room bilge of the ex-USS Oriskany.
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 systems containing fuels, oils, or grease will continue to
drip for some time after initial draining. Over a short period of time, these drips can
necessitate 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 wastewater.
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 decks and floor coverings should be cleaned. Floor coverings include
ceramic tile, linoleum and linoleum tile, carpet, and any other floor coverings. In compartments
subject to fuel and oil 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 fuels, oils, or grease
should be removed from the vessel.
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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.
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
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.
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What are the potential environmental impacts of asbestos?
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)
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/fireproofmg
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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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.
Asbestos pipe wrapping on the ex-USS Oriskany.
Photo courtesy of Laura Casey
How should the vessel be prepared; what are the appropriate BMPsfor asbestos?
Asbestos can be found throughout ships, from the top of the bridge to the bilge. Identifying the
locations and types of asbestos onboard early in the clean-up process is essential for vessel
preparation and may involve qualified asbestos inspectors. 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, the encapsulation should be strong enough that its integrity will not be
impacted by the preparation for sinking as well as the sinking itself.
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The primary source of friable asbestos is 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. If such
friable asbestos is not covered with canvas and/or paint, the friable asbestos should be sealed or
encapsulated with an epoxy or other non-water soluble and non-toxic sealer.
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 lose
their integrity and can break up and raft.
Where possible, these sheets should be
removed. Note that asbestos 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
marine 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.
Photo courtesy of Laura S. Johnson
Patched asbestos pipe wrapping on the ex-USS Oriskany.
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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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POLYCHLORINATED BIPHENYLS (PCBs)
Narrative Clean-up Goal: Remove all manufactured products containing greater than or
equal to (>) 50 parts per million (ppm) of solid PCBs; remove all liquid PCBs regardless
of concentration; remove all materials contaminated by PCB spills where the
concentration of the original PCB source is > 50 ppm.
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 of 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.
What are the potential environmental impacts of PCBs?
PCBs have been demonstrated to cause a variety of adverse health effects. PCBs have been
shown to cause cancer in animals and have also been shown to cause a number of serious non-
cancer health effects in animals, including effects on the immune system, reproductive system,
nervous system, endocrine system, and other health effects. Studies in humans provide
supportive evidence for potential carcinogenic and non-carcinogenic effects of PCBs. The
different health effects of PCBs may be interrelated, as alterations in one system may have
significant implications for the other systems of the body. EPA's peer reviewed cancer
reassessment concluded that PCBs are probable human carcinogens. In addition, PCBs are
persistent and bioaccumulative. PCBs bioaccumulate in fatty or lipid-rich tissues. PCBs have a
limited solubility in aqueous solutions and 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 and
bioaccumulated in the fish they are ingesting.
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 and sediments, or ingestion of contaminated fish, shellfish, or
crustaceans. (See Appendix C)
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Where are PCBs found on a ship?
Although no longer commercially produced in the United States, PCBs are most likely to be
present in vessels deployed before the 1979 PCB ban. For such vessels, PCBs may be found in
both the solid (waxy) and liquid (oily) forms in equipment and materials onboard ships. The
equipment that may contain PCBs in concentrations of > 50 ppm and the manufactured products
containing > 50 ppm of solid PCBs, include:
Materials and items that could contain solid PCBs
Cable insulation
Rubber and felt gaskets
Thermal insulation material including fiberglass, felt, foam, and cork
Voltage regulators, switches, reclosers, bushings, and electromagnets
Electronic equipment, switchboards, and consoles
Adhesives and tapes
Oil-based paint
Caulking
Rubber isolation mounts
Foundation mounts
Pipe hangers
Plastics
Materials and items that could contain liquid PCBs
Oil used in electrical equipment and motors, anchor windlasses, hydraulic systems, and
leaks and spills from such items
Materials and items that could contain either liquid or solid PCBs
Transformers, capacitors, and electronic equipment with capacitors and transformers
inside
Fluorescent light ballasts
Surface contamination of machinery and other solid surfaces
Items containing PCBs may be found throughout a ship and are not always easily identifiable or
readily accessible. PCBs may be found in a variety of shipboard materials, but the location and
concentration can vary from item to item and within classes of items. PCB-containing materials
also are likely to vary from ship to ship, and even ships in the same class can contain differing
types and 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, weapons storage areas, or areas with hydraulic equipment. Be
aware that these pieces of equipment or systems are vulnerable to leaks and spills, which could
leave spill residues behind and contaminate porous materials (e.g., carpet, wood, rubber/plastic
mats, paint).
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Photo courtesy of Laura S. Johnson
Ex-USS Oriskany electronic equipment stripped of capacitors and transformers.
How should the vessel be prepared; what are the appropriate BMPsfor PCBs?
PCBs are regulated for disposal under 40 CFR Part 761, and will be discussed in this context.
The PCB regulations require manufactured products containing > 50 ppm of solid PCBs (PCB
bulk product waste) and materials contaminated by spills of liquids containing PCBs (PCB
remediation waste) to be properly disposed. Although the ship itself is being "reused" or
"recycled" as an artificial reef, the PCBs must be properly disposed. Disposal requirements for
each type of PCB waste are referenced below (also see Appendix B).
Where there is reason to suspect that equipment or manufactured products containing solid PCBs
may contain PCBs > 50 ppm, either remove the equipment or component from the vessel, or
provide proof that the equipment or component is free of PCBs, unless a PCB bulk product waste
disposal approval has been obtained under 40 CFR 761.62(c) (see below).
Under TSCA regulations, a spill of liquids containing PCBs > 50 ppm is considered an illegal
disposal of PCBs. Material(s) contaminated by such a spill must be cleaned or removed and
disposed of, unless a risk-based disposal approval has been obtained under 40 CFR 761.61(c).
Spill residues and materials contaminated by these spills are regulated differently than bulk
product waste (see below).
The design and implementation of a representative sampling and analytical plan can help
determine the presence or absence of PCBs in materials containing solid PCBs at > 50 ppm or
materials containing PCBs as the result of spills. If the data from the sampling and analytical
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plan indicates the absence of PCBs, the ship and its components are not subject to the PCB
provisions of TSCA.
Liquid Materials Manufactured with PCBs
Remove all liquid-filled electrical equipment suspected of containing PCBs or PCB-
contaminated dielectric fluid, regardless of PCB concentration. Materials such as lubricating oils
and greases used for winches and cargo-handling machinery, hydraulic fluids, heat transfer
fluids, and waste oils should be removed from the vessel in accordance with the guidance in the
"Oil and Fuel" section of this document.
Engine room electrical cabling on the ex-USS Oriskany.
Photo courtesy of Laura Casey
Manufactured Products Containing Solid PCBs
Remove all manufactured products containing > 50 ppm of solid PCBs, 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.
Thermally removing PCB-containing materials is generally not authorized without prior written
approval. Because PCB sampling and analytical procedures can be expensive and time
consuming, there may be situations when the cost of sampling and analysis far exceeds the cost
for removal and disposal. In some cases, vessel-to-reef projects have shown that removal of all
electrical cables and wires suspected of containing PCBs was the most economical course of
action.
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While the complete removal of all manufactured products containing > 50 ppm of solid PCBs is
recommended, EPA recognizes that in some vessels it may not be feasible to identify and remove
every such item. If such materials cannot be feasibly identified and/or removed, an application
to EPA for a risk-based approval to dispose of the PCB bulk product waste in a marine
environment for purposes of creating an artificial reef is required pursuant to 40 CFR 761.62(c).
(EPA's decision includes consideration of a risk assessment submitted by the applicant, and a
public participation process. Please consult the responsible EPA office for more information.)3
Materials Containing PCBs as a Result of Spills
Remove all materials containing > 50 ppm of PCBs due to PCB spills. In addition, depending on
the concentration of the spilled PCBs and the date when the spill occurred, it may be necessary to
remove materials currently containing less than 50 ppm of PCBs due to spills.4 If it is not known
when a spill occurred, you should generally assume that it occurred after July 1, 1979.
During vessel clean-up/preparation, attention should be directed to locations on the ship that are
known to house equipment and systems that typically contain PCB liquids. Because such
equipment or systems are vulnerable to leaks and spills during the lifetime of the vessel, the
areas surrounding the equipment or systems are likely contaminated by liquids containing PCBs.
If there is no information regarding whether a spill occurred and/or the PCB concentration of any
spilled liquid, design and implement a representative sampling plan to verify that there are no
PCBs present in the areas surrounding the liquid-filled equipment or systems. If the sampling
results indicate presence of PCBs as a result of a spill of liquids containing PCBs, remove the
spill residue and the materials contaminated by the spill (e.g., remove paint from a contaminated
surface such as a metal deck, strip the contaminated area down to bare metal in accordance with
40 CFR 761.79(b)(i)(B)). If spill residues or materials contaminated by PCB spills cannot be
feasibly removed, an application to EPA for a risk-based approval to dispose of the PCBs in a
marine environment for purposes of creating an artificial reef is required pursuant to 40 CFR
761.61(c). (EPA's decision includes consideration of a risk assessment submitted by the
applicant, and a public participation process. Please consult the responsible EPA office for more
information (see footnote # 3).)
Any vessel owner and/or sponsor should carefully consider the amount of time, resources and financial
commitments necessary to address the identification, removal, and disposal of non-liquid PCB-containing materials
and materials contaminated by spills of liquids containing PCBs before finally deciding if a vessel is suitable for
reefing, and well in advance of commencing clean-up. EPA strongly recommends vessel owners and/or sponsors to
begin discussions as soon as possible with the PCB coordinator for the EPA Region in which the vessel is proposed
to be sunk. A list of EPA's current PCB coordinators may be found at www.epa.gov/pcb/coordin.html.
For PCB spills that occurred between April 18, 1978, and July 1, 1979, and where the original source was > 500
ppm PCBs, remove all materials containing any concentration of PCBs. For PCB spills that occurred after July 1,
1979, and where the original source was > 50 ppm PCBs, remove all materials containing any concentration of
PCBs. Remove all materials currently containing > 50 ppm PCBs as a result of spills (of any concentration) that
occurred prior to April 18, 1978. Consult the PCB regulations at 40 CFR 761.3, 761.50(b)(3) and 761.61.
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PAINT
Narrative Clean-up Goal: Remove harmful exterior hull anti-fouling systems that are
determined to be active; remove exfoliating (peeling) and exfoliated paint.
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^ 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 hulls 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 added
biocides.
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.
Photo courtesy of Laura S. Johnson
Exfoliating ceiling paint on the ex-USS Oriskany before being cleaned.
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What are the potential environmental impacts of paints?
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)
How should the vessel be prepared; what are the appropriate BMPs for paints?
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
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, 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 of such supporting information
include, but are not limited to, any documentation related to the following: the type and age of
the existing AFS, the most recent repainting or dry-dock cycle, and the most recent underwater
hull cleaning. When necessary, such information may be supplemented by 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 and essentially all the
underwater hull area is covered with marine growth, the AF coatings can be left in place without
further evaluation, as they are no longer likely to be 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 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 guidance presented under the "PCB" and
"Solids/Debris/Floatables" sections when appropriate. If paint is found to contain PCBs, then
the protocols found in the "PCB" section of this document should be followed.
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Removal of intact paints generally is not necessary. Topside paint may contain other
constituents, such as trace metals or biocides. Unlike underwater hull paint containing high
concentrations of biocides designed to leach rapidly, topside paints are designed for long life.
They also may contain significantly lower levels of these substances than hull coatings.
However, 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.
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. These materials
can consist of vessel 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.
What are the potential
environmental impacts
of solids, debris, and
floatables?
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 does
not biodegrade readily. The longer that introduced materials remain in the marine environment,
the greater the threat they pose to the environment.
Photo courtesy of Laura S. Johnson
Solids, debris, floatables, and exfoliating paint on a vessel of
the MARAD James River Reserve Fleet.
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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. 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;
Alteration of the ecosystem and its processes may occur throughout the water column as
a result of debris introduced into the marine environment. Debris settling on the bottom
may change benthic floral and faunal 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 for coastal communities impacted by the debris which could be
costly; and
Increasing the risk of spills and other environmental impacts resulting from potential
danger to navigation (e.g., hull damage, damage to propellers, and damage to cooling and
propulsion systems).
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.
How should the vessel be prepared; what are the appropriate BMPsfor
solids/debris/floatables ?
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 (including netting material).
Deck drains should be proven clear of debris. Consideration should also be given to the removal
of items that could become a floatable over time (e.g., floatable fiberglass insulation, floatable
foam).
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
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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
cleaned as understood 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 should not be placed on the vessel solely for disposal. However, material
needed for the reefing operation (e.g., clean concrete or rock for ballast) or of a commemorative
nature (e.g., plaques and markers) is not considered debris for the purposes this document.
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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.
What are other materials of environmental concern?
Refer to the list provided below.
What are the potential environmental impacts of other materials of environmental
concern?
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."
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.
How should the vessel be prepared; what are the appropriate BMPsfor other materials
of environmental concern?
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, contaminated
rain water, 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.
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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
transit. Any lines that have been charged with any fire-fighting product other than untreated
seawater or fresh water should be treated in the same manner as fuel lines 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 extant mercury or items containing
mercury should be removed from the vessel. Even minute quantities of mercury may be of
concern and should be removed. Note that there is a health hazard associated with airborne
mercury.
Photo courtesy of Laura Casey
Mercury removed from smoke detector onboard the ex-USS Oriskany.
Lead
Lead ballast bars, shielding and fittings should be removed from the vessel if the reef site is
located in fresh or brackish water.
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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 (except where it
may safely be left on the ship in accordance with the references below). The Navy is more
familiar with addressing this material generally 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 N13.12-1999, "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
Photo courtesy of Florida Fish and Wildlife Conservation Commission
Diver exploring the ex-USS Spiegel Grove artificial reef.
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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 help ensure safe diver access.
Sealing entrances into restrictive compartments such as the boiler rooms and engine
rooms to help ensure diver safely.
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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Appendix A
Federal Statutes Related to the Transfer of Obsolete MARAD and Navy
Vessels for Use as Artificial Reefs
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:
Title XXXVMaritime Administration
Subtitle A - Maritime Administration Reauthorization
Section 3516. AUTHORITY TO CONVEY OBSOLETE VESSELS
TO UNITED STATES, TERRITORIES, AND FOREIGN
COUNTRIES FOR REEFING
(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 the 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 § 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:
Title X- General Provisions
Subtitle B - Naval Vessels and Shipyards
Section 1013. TRANSFER OF VESELS STRICKEN FROM THE
NAVAL VESSEL REGISTER FOR USE AS ARTIFICIAL REEFS.
(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
Xa) 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 States, or any municipal
corporation or political subdivision thereof, for use as provided in subsection (b).
Xb) 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
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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.
Xc) 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.
Xd) 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).
Xe) 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).
Xf) 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.
Xg) 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.'.
(b) CLERICAL AMENDMENT- The table of sections at the beginning of such
chapter is amended by inserting after the item relating to section 7306a the following
new item:
"7306b. Vessels stricken from Naval Vessel Register: transfer by gift or
otherwise for use as artificial reefs.'.
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Transfer of Obsolete Vessels by the Department of Transportation
Public Law 92-402 (16 U.S.C. 1220, et. seq.) authorizes the U.S. Maritime Administration
(MARAD), under the Department of Transportation, to transfer obsolete ships to any state for
use as an artificial reef. In addition, MARAD's authority was amended by Public Law 107-314
section 3504, as amended by Public Law 108-136, to allow MARAD to provide financial
assistance to states for environmental preparation, towing, and/or sinking and also allows
MARAD to transfer obsolete vessels to U.S. territories and foreign countries for use as artificial
reefs.
Title XXVI Conservation
Chapter 2 SB - Reefs for Marine Life Conservation
§ 1220. State applications for obsolete ships for use as offshore reefs
(a) Conservation of marine life
Any State may apply to the Secretary of Transportation (hereafter referred to in this
chapter as the "Secretary") for obsolete ships which, but for the operation of this
chapter, would be designated by the Secretary for scrapping if the State intends to sink
such ships for use as an offshore artificial reef for the conservation of marine life.
(b) Manner and form of applications; minimum requirements
A State shall apply for obsolete ships under this chapter in such manner and form as
the Secretary shall prescribe, but such application shall include at least (1) the location
at which the State proposes to sink the ships, (2) a certificate from the Administrator,
Environmental Protection Agency, that the proposed use of the particular vessel or
vessels requested by the State will be compatible with water quality standards and
other appropriate environmental protection requirements, and (3) statements and
estimates with respect to the conservation goals which are sought to be achieved by
use of the ships.
(c) Copies to federal officers for official comments and views
Before taking any action with respect to an application submitted under this chapter,
the Secretary shall provide copies of the application to the Secretary of the Interior,
the Secretary of Defense, and any other appropriate federal officer, and shall consider
comments and views of such officers with respect to the application.
§ 1220a. Transfer of title; terms and conditions
If, after consideration of such comments and views as are received pursuant to section
1220(c) of this title, the Secretary finds that the use of obsolete ships proposed by a
State will not violate any federal law, contribute to degradation of the marine
environment, create undue interference with commercial fishing or navigation, and is
not frivolous, he may transfer without consideration to the State all right, title, and
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interest of the United States in and to any obsolete ships which are available for
transfer under this chapter if
(1) the State gives to the Secretary such assurances as he deems necessary that such
ships will be utilized and maintained only for the purposes stated in the application
and, when sunk, will be charted and marked as a hazard to navigation;
(2) the State agrees to secure any licenses or permits which may be required under the
provisions of any other applicable federal law;
(3) the State agrees to such other terms and conditions as the Secretary shall require in
order to protect the marine environment and other interests of the United States; and
(4) the transfer would be at no cost to the Government (except for any financial
assistance provided under section 1220(c)(l) of this title) with the State taking
delivery of such obsolete ships and titles in an "as-is where-is" condition at such
place and time designated as may be determined by the Secretary of Transportation.
§ 1220b. Obsolete ships available; number; equitable administration
A State may apply for more than one obsolete ship under this chapter. The Secretary
shall, however, taking into account the number of obsolete ships which may be or
become available for transfer under this chapter, administer this chapter in an
equitable manner with respect to the various States.
§ 1220c. Denial of applications; finality of decision
A decision by the Secretary denying any application for a obsolete ship under this
chapter is final.
§ 1220c-l. Financial assistance to State to prepare transferred ship
(a) Assistance authorized
The Secretary, subject to the availability of appropriations, may provide, to any State
to which an obsolete ship is transferred under this chapter, financial assistance to
prepare the ship for use as an artificial reef, including for
(1) environmental remediation;
(2) towing; and
(3) sinking.
(b) Amount of assistance
The Secretary shall determine the amount of assistance under this section with respect
to an obsolete ship based on
(1) the total amount available for providing assistance under this section;
(2) the benefit achieved by providing assistance for that ship; and
(3) the cost effectiveness of disposing of the ship by transfer under this chapter and
provision of assistance under this section, compared to other disposal options for that
ship.
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(c) Terms and conditions
The Secretary
(1) shall require a State seeking assistance under this section to provide cost data and
other information determined by the Secretary to be necessary to justify and document
the assistance; and
(2) may require a State receiving such assistance to comply with terms and conditions
necessary to protect the environment and the interests of the United States.
§ 1220d. "Obsolete ship" defined
For purposes of sections 1220, 1220a, 1220b, and 1220c of this title, the term
"obsolete ship" means any vessel owned by the Department of Transportation that has
been determined to be of insufficient value for commercial or national defense
purposes to warrant its maintenance and preservation in the national defense reserve
fleet and has been designated as an artificial reef candidate.
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Appendix B
Federal Environmental Laws Relevant for Consideration in the Preparation
of a Vessel for Use as an Artificial Reef
This Appendix identifies selected federal statutes relevant for consideration in preparation of a
vessel for use as an artificial reef. For these statutes, the Appendix explains their potential
relevance and briefly summarizes the relevant provisions. The first set of statutes briefly
summarized are environmental laws administered by EPA which may be relevant to the removal
of material from vessels or the disposal of such removed material. In addition, although this
document focuses on environmental best management practices for vessel preparation, for the
reader's convenience the Appendix also briefly summarizes federal statutes establishing permit
requirements for the actual placement of the vessel as an artificial reef. Finally, the Appendix
briefly describes a number of other significant federal environmental statutes that may affect
issuance of such permits or the actual conduct of placement activities.
The information in this Appendix is intended only for the convenience of the reader in order to
provide a useful starting point for identifying the principal environmental statutes of interest.
The Appendix is not intended to be an exhaustive list of every conceivably relevant statute, nor
do the brief summaries in this list alter or replace any requirements, regulations, or applicable
guidance under those statutes that are summarized. Readers also should be aware that in 2000,
EPA published tips for regulatory compliance for ship scrapping, and that document contains
additional guidance that may be useful in preparation of a vessel for use as an artificial reef. See
www.epa.gov/oecaerth/resources/publications/civil/federal/shipscrapguide.pdf
State and local laws also may apply to vessel preparation or placement for use as an artificial
reef, and interested readers should consult with appropriate State and local authorities to identify
such further requirements.
EPA-Administered Federal Environmental Laws Relevant to Vessel Preparation
The Clean Air Act (CAA), 42 U.S.C. §§ 7401, et seq., generally addresses the emission
of air pollutants. Among other things, it directs EPA to establish minimum national
standards for air quality, and assigns primary responsibility to the states to assure
compliance with the standards through State Implementation Plans (SIPs). State-specific
SIPs may impose requirements that are more prescriptive, more stringent, or more
specific than the minimum national standards. Among national standards relevant for
vessel preparation, EPA has established a National Emissions Standards for Hazardous
Air Pollutants (NESHAP) for asbestos at 40 CFR Part 61 Subpart M. The asbestos
NESHAP is intended to minimize the release of asbestos fibers during demolition and
renovation activities, which would include asbestos removal when preparing a vessel for
use as an artificial reef. EPA has delegated authority to inspect and enforce the asbestos
NESHAP to most states, which, as noted, may have requirements that are more stringent
than federal requirements. Other NESHAPs also may be relevant to removal of other
materials on vessels, and may be found at 40 CFR Parts 61 and 63. In addition, Title VI
of the Act directs EPA to establish requirements for the control of substances that
contribute to stratospheric ozone depletion, which include substances such as halons used
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in fire suppression systems and certain refrigerants, that the best management practices in
this guidance recommend be removed from a vessel in preparation for its use as an
artificial reef. The recovered ozone-depleting refrigerants and halons should be delivered
to an EPA-approved refrigerant and/or halon reclaimer for proper handling. Regulations
addressing recycling and reuse of such removed refrigerants and halons, including
chlorofluorocarbons and hydrofluorocarbons (sometimes referred to under the trade name
Freon), appear at 40 CFR Part 82.
The Clean Water Act (CWA), 33 U.S.C. §§ 1251, et seq., generally regulates the addition
of pollutants from a point source to waters of the United States. The definition of point
source includes a "vessel or other floating craft." CWA requirements are implemented,
among other things, through permits under either section 402 (the National Pollutant
Discharge Elimination System (NPDES) permitting program) or section 404 (the
permitting program for dredged and fill material). Pollutants generated in the preparation
of a vessel for use as an artificial reef that are discharged to waters of the U.S., including
via contaminated storm water, require NPDES permit authorization. The NPDES
permitting program is primarily administered by states, with EPA oversight. In addition
to the CWA's NPDES permitting program, section 311 establishes a program for the
prevention and abatement of, and remedial response to, oil and hazardous substance
spills. See 40 CFR Parts 110, 112, 116, and 117. Section 311 imposes requirements for
reporting the release of oil and hazardous substances, which might be relevant to the
preparation of a vessel for use as an artificial reef should preparation result in such a
release. Section 311 is jointly administered by EPA and the U.S. Coast Guard, depending
on the location of the source. (For discussion of CWA section 404 permitting and the
placement of vessels as artificial reefs, refer to the section of this Appendix describing
federal laws that establish permitting requirements for placement of artificial reefs).
The Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA), 42 U.S.C. §§ 9601, et seq., better known as the "Superfund Act," addresses
cleanup of hazardous substances. CERCLA and its implementation documents empower
EPA and other agencies to identify and prioritize sites for cleanup, and to order or carry
out environmental remediation. Subject to limited defenses, CERCLA imposes strict
liability for environmental cleanup on persons connected to facilities from which there
are releases into the environment. CERCLA also mandates reporting to the National
Response Center of hazardous substance releases. In conjunction with CWA section 311,
CERCLA provides for federal preparation of the National Contingency Plan for
responding to a hazardous substances release. As noted regarding CWA section 311,
CERCLA is relevant to the preparation of a vessel for use as an artificial reef in its
release reporting requirements, particularly for oil and hazardous substances. CERCLA
is administered by federal agencies, not states.
The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), 7 U.S.C. §§ 136, et
seq., generally regulates the registration, labeling, distribution, sale, and use of pesticides.
EPA regulates anti-foulant paints, including those containing organotins, copper, and
other pesticidal compounds under FIFRA. EPA has relied on FIFRA and the Organotin
Anti-fouling Paint Control Act of 1988 (33 U.S.C. §§ 2401, et seq.) for authority to
impose requirements, such as certification and training for applicators and label
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requirements dealing with tributyl tin (TBT) application and disposal. TBT anti-fouling
paint label requirements include provisions directing that all paint chips, spent abrasives,
and any other waste products from paint removal be disposed of in a sanitary landfill. 53
Fed. Reg. 39022, 39038, col. 3 (October 4, 1988). In addition, use of any pesticide in the
preparation of a vessel for use as an artificial reef must comply with label requirements.
For the most part, FIFRA is administered by EPA, though some states have primary
enforcement responsibility for FIFRA use violations.
The Marine Protection, Research and Sanctuaries Act (MPRSA), 33 U.S.C. §§ 1401, et
seq., prohibits, unless authorized by an MPRSA permit, (1) transportation of material
from the United States for the purpose of ocean dumping; (2) transportation of material
from anywhere for the purpose of ocean dumping by federal agencies or U.S. flagged
vessels; and (3) dumping of material transported from outside the United States into the
territorial sea of the United States. If any materials removed from vessels being prepared
for use as an artificial reef were subsequently proposed for ocean dumping, a permit
under the MPRSA would be necessary. Denial of such a permit request, however, would
be highly likely because land-based alternatives (the consideration of which are required
for MPRSA permit issuance) typically would be available. In addition, it would seem
improbable that such a proposal could satisfy the other applicable environmental criteria
of the MPRSA and implementing regulations. The MPRSA is administered by EPA and
the U.S. Army Corps of Engineers, not states.5
The Resource Conservation and Recovery Act (RCRA), 42 U.S.C. §§ 6901, controls the
management of hazardous wastes "from cradle to grave." If, in the preparation of a
vessel for use as an artificial reef, a waste is generated that is specifically listed as
hazardous or exhibits any hazardous characteristics, e.g. toxicity, and the waste is not
excluded or exempt from the RCRA Subtitle C regulations, then this waste would be
considered hazardous waste and subject to all applicable RCRA regulations. See 40 CFR
Parts 260 and 261. Depending upon the volume of hazardous wastes that are generated
and the length of time the hazardous wastes are accumulated, RCRA regulations provide
conditional exemptions from some of the regulatory requirements. In most states, EPA
has authorized the State to administer some or all of RCRA requirements under state law
in lieu of federal law and, depending on the state, state law may include requirements that
are more stringent or prescriptive than federal law. Hazardous waste and used oil must
be managed according to RCRA regulations.
The Toxic Substance Control Act (TSCA), 15 U.S.C. §§ 2601, et seq., bans the
manufacture, processing, use, and distribution in commerce of poly chlorinated biphenyls
(PCBs) and directs EPA to set regulations for the disposal of PCBs. TSCA requirements
generally determine the degree of necessary PCB removal from vessels being prepared
for use as an artificial reef. Although TSCA imposes requirements for toxic substances
other than PCBs, TSCA's PCB requirements are uniquely relevant to preparation of a
The MPRSA definition of "dumping" excludes the construction of fixed structures or artificial islands, as well as
deposits of materials for the purpose of developing or maintaining fisheries resources, when otherwise regulated by
federal or state law (or occurring pursuant to authorized federal or state programs). Because the placement of a
vessel to create an artificial reef in waters subject to jurisdiction of the United States is regulated under other federal
laws, the actual placement of vessels for use as an artificial reef is not subject to regulation under the MPRSA.
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vessel for use as an artificial reef because of the likely presence of PCBs on many
obsolete vessels. More specific guidance on the applicability of TSCA's PCB
requirements to vessels being prepared for use as an artificial reef is provided in the
section of the environmental best management practices addressing PCBs, and readers
should refer to that section for further information.
Federal Environmental Laws Establishing Permit Requirements for Placement of Vessels as
Artificial Reefs
Section 404 of the CWA, 33 U.S.C. § 1344, establishes a permitting program for the
discharge of dredged or fill material to waters of the Unites States. Placement of a vessel
in waters of the United States as an artificial reef would constitute a discharge of fill
material, and therefore would require a CWA section 404 permit. 33 CFR 323.2(e) & (f).
For CWA purposes, "waters of the United States" include most inland waters as well as
the waters of the territorial sea, which, under the CWA, is measured from the baseline
(i.e., the line of ordinary low water along that portion of the coast which is in direct
contact with the open sea and the line marking the seaward limit of inland waters) in a
seaward direction a distance of three miles. Section 404 permitting is primarily
administered by the U.S. Army Corps of Engineers (Corps), using environmental
guidelines set out in EPA regulations appearing at 40 CFR Part 230. Among other
things, except as provided by 40 CFR 230.5(b) and 230.7(b)(l) (relating to activities
covered by an applicable general permit), these guidelines require consideration of
practicable alternatives to the proposed discharge, and in the case of proposed discharges
to special aquatic sites, presume that all practicable alternatives not involving a discharge
into a special aquatic site have less adverse impact on the aquatic ecosystem, unless
clearly demonstrated otherwise. 40 CFR230.5(c); 230.10(a). Special aquatic sites are
identified at 40 CFR Part 230 Subpart E and include, among other things, marine
sanctuaries and coral reefs. In addition to evaluation for compliance with these
guidelines, section 404 permits are also subject to the Corps' public interest review under
33 CFR 320.4. Corps regulations relevant to the CWA section 404 permitting program
appear at 33 CFR Parts 320, 323, 325, 328, and 331. Though EPA has authorized two
States to administer the section 404 permitting program for certain waters in those States,
these State programs probably would not to be relevant to the placement of a vessel for
use as an artificial reef because states may not assume section 404 permitting authority
for discharges of fill material to waters supporting commercial navigation, waters subject
to the ebb and flow of the tide, or waters of the territorial seas, where a former
vessel/artificial reef would likely be sited.
Section 10 of the Rivers and Harbors Act of 1899 (RHA), 33 U.S.C. §§ 403, requires a
permit from the Corps for, among other things, the construction of any structure
(including artificial reefs) in or over any "navigable water of the United States" as that
term is defined at 33 CFR Part 329.6 Structures or work outside the limits of "navigable
waters of the United States" also require a section 10 permit if the structure or work
6 In cases where the waters in which the vessel is being placed for use as an artificial reef are subject to both RHA
section 10 and CWA section 404 permitting (e.g., the 3 mile territorial sea), Corps practice is to issue a single
consolidated permit satisfying the requirements of both these statutes.
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affects the course, location, or condition of the waterbody in such a manner as to impact
on navigational capacity. Under section 4(e) of the Outer Continental Shelf Lands Act,
43 U.S.C. § 1333(e), RHA section 10 permit requirements also apply to the creation of
structures on the Outer Continental Shelf of the United States, including artificial reefs.
33 CFR 322.3(b). Issuance of permits under RHA section 10 involves a public interest
review by the Corps in accordance with 33 CFR 320.4. To help safeguard navigational
and other marine uses, Corps permits for artificial reefs have required that permittees
notify the National Oceanic & Atmospheric Administration (NOAA) prior to, and upon
completion of, the reefing activity, including a drawing certifying the location and
configuration of the completed activity. 33 CFR Part 325, Appendix A, special condition
B.5. Corps regulations relevant to the RHA section 10 permitting program appear at 33
CFR Parts 320, 322, 325, 329, and 331.
Other Significant Federal Environmental Statutes That May Affect Issuance of Permits or
Licenses for Artificial Reefs or the Conduct of Placement Activities.
The Liberty Ship Act, 16 U.S.C. §§ 1220, et seq., authorizes states to apply to the
Secretary of the Department of Transportation (DOT) for the use of DOT-owned obsolete
vessels, including obsolete vessels of the Maritime Administration, as an artificial reef for
the conservation of marine life. The Liberty Ship 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). The ability to meet such standards and
requirements will be affected by what materials are onboard the vessel.
The National Fishing Enhancement Act of 1984 (NFEA), 33 U.S.C. §§ 2101, et seq.,
applies to all artificial reefs in waters of the United States or on the Outer Continental
Shelf for the purpose of enhancing fishery resources. Section 204 of NFEA obligates
NOAA to issue a national artificial reef plan that addresses issues such as siting and
design criteria. Additionally, NFEA section 205 establishes further requirements to be
applied by the Corps in the exercise of its previously described permitting authority for
placement of artificial reefs under RHA section 10 or CWA section 404. Such
requirements are reflected in the previously identified Corps permitting regulations for
artificial reefs (e.g., 33 CFR 320.3(o), 322.5(b), and 325.1(d)(8)).
The Coastal Zone Management Act (CZMA), 16 U.S.C. 1451, et seq., establishes a
federal/state partnership to provide for the comprehensive management of coastal
resources. Under CZMA section 307(c)(3), applicants for a required federal license or
permit to conduct an activity affecting the coastal zone of a state with an approved
coastal management program need to provide the federal permitting agency and the
relevant state with a certification that the proposed activity complies with the enforceable
policies of the state's approved program and will be conducted in a manner that is
consistent with the program. Under CZMA section 307(c)(l), a federal agency activity
that affects the coastal zone must be carried out in a manner which is consistent to the
maximum extent practicable with the enforceable policies of an approved coastal
management program. Relevant implementing regulations established by NOAA (which
is responsible for federal administration of the CZMA) appear at 15 CFR Part 930,
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Subpart C (consistency for federal agency activities) and Subpart D (consistency for
activities requiring a federal license or permit). NOAA's CZMA regulations were
recently amended. 71 Fed. Reg. 788 (Jan. 5, 2006). The regulations provide that in the
case of federal agency applications for federal licenses or permits, as well certain general
permits proposed by a federal agency, review will be conducted under the Subpart C
regulations. See 15 CFR 930.31(d) & 930.52. Corps regulations implementing the
CZMA for its RHA section 10 and CWA section 404 permit programs appear at 33 CFR
320.3(b), 320.4(h), and 325.2(b)(2).
The National Environmental Policy Act of 1969 (NEPA), 42 U.S.C. §§ 4321, et seq.,
requires that federal agencies include in their decision-making processes appropriate and
careful consideration of the environmental effects of, and alternatives to, their actions.
NEPA section 102(2)(C) includes a requirement for preparation of an environmental
impact statements (EIS) for "major federal actions significantly affecting the quality of
the human environment." For proposed federal actions where the environmental effects
are unclear, the agency often prepares an environmental assessment, which is a brief and
concise document containing sufficient evidence and analysis for the agency to determine
whether to prepare an EIS or to issue a finding of no significant impact. 40 CFR
1501.4(b), 1508.9(a)(l), 1508.13. Council on Environmental Quality regulations
implementing NEPA appear at 40 CFR Parts 1500 - 1518. Corps regulations
implementing NEPA for its RHA section 10 and CWA section 404 permit programs
appear at 33 CFR 320.3(d) and Part 325, Appendix B.
Under Clean Air Act section 309, 42 U.S.C. § 7609, EPA reviews and comments on the
environmental impacts of several types of actions of other federal agencies, including all
actions subject to the requirement under the National Environmental Policy Act to
prepare an Environmental Impact Statement. EPA comments in writing and make those
comments available to the public. If EPA determines that the action is unsatisfactory
from the standpoint of public health or welfare or environmental quality, EPA refers the
matter to the Council on Environmental Quality.
The Endangered Species Act (ESA), 16 U.S.C. §§ 1531, et seq., addresses the
conservation of federally-listed threatened and endangered species and the ecosystems on
which those species depend. ESA section 7 requires that federal agencies, in consultation
with the National Marine Fisheries Service and/or the U.S. Fish and Wildlife Service7,
ensure that any action authorized, funded, or carried out by the agency (including
issuance of federal permits) is not likely to jeopardize the continued existence of listed
species or result in the adverse modification of their designated critical habitat.
Whenever such an agency action may affect a listed species or critical habitat, the
interagency consultation requirement is triggered, and the ESA section 7 procedural
requirements at 50 CFR Part 402 apply. In addition, ESA section 9 generally prohibits
anyone from taking listed animal species without authorization. "Take" is defined in
ESA section 3(19) to include harming and killing. Authorization to take is generally
granted through the section 7 consultation process, in exchange for measures to minimize
7 The National Marine Fisheries Service is now referred to as NOAA Fisheries, and is generally responsible for
marine species under the ESA. The U.S. Fish and Wildlife Service is generally responsible for terrestrial and
freshwater species.
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the take. Detailed information regarding ESA compliance can be found online at
http://www.nmfs.noaa.gov/pr/species/esa.htm and
http://www.fws.gov/endangered/wildlife.html. EPA's CWA section 404(b)(l) guidelines
also address ESA issues in the context of CWA section 404 permitting and appear at 40
CFR 230.30. Corps regulations implementing the ESA for its RHA section 10 and CWA
section 404 permit programs appear at 33 CFR 320.3(1) and 325.2(b)(5).
The Fish and Wildlife Coordination Act, 16 U.S.C. §§ 661, et seq., provides that
whenever the waters or channel of a waterbody are proposed or authorized to be modified
by a public or private agency under federal permit or license, the agency first shall
consult with the USFWS and the head of the state agency responsible for wildlife
resources. The purpose of this consultation is to promote conservation of wildlife
resources by preventing loss of and damage to such resources and to provide for the
development and improvement of wildlife resources in connection with the agency
action. Although the recommendations of the Secretary of the Interior and state officials
are not binding, the federal agency must give them full consideration. In addition, EPA's
CWA section 404(b)(l) guidelines address wildlife issues in the context of section 404
permitting and appear at 40 CFR Part 230, Subpart D. Corps regulations implementing
the Fish and Wildlife Coordination Act for its RHA section 10 and CWA section 404
permit programs appear at 33 CFR 320.3(e) and 320.4(c).
Title III of the National Marine Sanctuaries Act (NMSA), 16 U.S.C. §§ 1431, et seq.,
authorizes the Secretary of Commerce to designate and manage national marine
sanctuaries. Under NMSA section 304(d), federal agency actions (including private
activities authorized by federal permits) that are likely to destroy, cause the loss of, or
injure sanctuary resources are subject to consultation with the Secretary of Commerce. If
the Secretary finds that a federal action is likely to have this effect, the Secretary must
recommend feasible alternatives to protect resources, and if the agency does not follow
those alternatives it must provide a written statement explaining why. The marine
sanctuary program is administered by NOAA, which has promulgated implementing
regulations at 15 CFR Part 922. Part 922 specifically identifies all designated marine
sanctuaries and their boundaries, as well as applicable regulations and restrictions
governing their use. EPA's CWA section 404(b)(l) guidelines also address marine
sanctuaries in the context of section 404 permitting and appear at 40 CFR 230.40. Corps
regulations implementing these NMSA provisions for its RHA section 10 and CWA
section 404 permit programs appear at 33 CFR 320.3(c) and 320.4(1).
The Magnuson-Stevens Fishery Conservation and Management Act (Magnuson-Stevens
Act), 16 U.S.C. §§ 1801, et seq., is the principal federal law addressing the conservation
and management of fisheries resources. Among other things, Magnuson-Stevens Act
section 305(b)(l) provides that fisheries management plans developed under the
Magnuson-Stevens Act must identify essential fish habitat (EFH). Magnuson-Stevens
Act section 3(10) defines EFH as "...those waters and substrate necessary to fish for
spawning, breeding, feeding, or growth to maturity." Under section 305(b)(2), federal
agencies are directed to consult with the Secretary of Commerce with respect to any
action to be authorized, funded, or undertaken that may adversely affect any identified
EFH. If the Secretary determines the action would adversely affect such EFH, the
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Secretary is to recommend measures that could be taken by the agency to conserve the
EFH. The agency must respond to such recommendations in writing, including a
description of measures proposed by the agency for avoiding, mitigating, or offsetting the
impact of the activity on the EFH. Under Magnuson-Stevens Act section 305(b)(4), if the
agency's response is inconsistent with the Secretary's recommendations, the agency must
explain why. The locations of EFH identified under the Act can be found online at
http://www.nmfs.noaa.gov/habitat/habitatprotection/efh/fish_manage_c.htm. NOAA
regulations implementing the EFH provisions of the Act appear at 50 CFR Part 600,
Subparts J and K.
The Marine Mammal Protection Act of 1972 (MMPA), 16U.S.C. §§ 1361,1362, 1371-
1384 note, 1386-1389, 1401-1407, 1411-1417, 1421-142Ih, is the principal federal
legislation addressing marine mammal species protection and conservation. MMPA
section 102 prohibits, with certain exceptions, the take of marine mammals in United
States waters and by U.S. citizens on the high seas, and the importation of marine
mammals and marine mammal products into the United States. Marine mammals subject
to the MMPA are defined in MMPA section 3(6) to include both species that are
morphologically adapted to the marine environment (e.g., sea otters, manatees, seals,
walruses, dolphins, whales) or which primarily inhabit the marine environment (e.g.,
polar bears). MMPA section 3(13) provides that "take" means to harass, hunt, capture, or
kill, or to attempt to do so. Depending on the species of marine mammal involved,
MMPA section 3(12) divides MMPA implementation responsibility between the
Department of the Interior (USFWS) and the Department of Commerce (NOAA). Under
this division of responsibility NOAA manages the majority of marine mammals,
including whales, dolphins, porpoises, seals, and sea lions, while the USFWS manages
five species: polar bears, walrus, sea otters, manatees, and dugongs. Relevant
implementing regulations appear at 50 C.F.R Part 216 (NOAA) and 50 CFR Part 18
(USFWS). Corps regulations implementing the MMPA for its RHA section 10 and CWA
section 404 permit programs appear at 33 CFR 320.3(k).
Section 401 of the Clean Water Act (33 U.S.C. 1341) requires that any applicant for a
federal license or permit (e.g., an EPA-issued NPDES permits or a Corps-issued section
404 permit) to conduct an activity that may result in a discharge into waters of the United
States shall provide the permitting agency a certification from the state in which the
discharge originates certifying that the license or permit complies with CWA
requirements, including applicable state water quality standards. No federal license or
permit subject to CWA section 401 may be issued unless the state either grants or waives
certification. As a result, CWA section 401 provides states with the ability to preclude
the issuance of federal permits or licenses subject to section 401 by denying certification,
as well as the ability to indirectly impose conditions upon such federal permits or licenses
by placing limitations or conditions on its section 401 certification. EPA regulations
implementing CWA section 401 appear at 40 CFR Part 121. Corps regulations
implementing the CWA section 401 its RHA section 10 and CWA section 404 permit
programs appear at 33 CFR 320.3(a), 320.4(d), and 325.2(b)(l).
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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 2005 "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 toxicological 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 National
Marine Sanctuaries. 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 National Marine Sanctuaries Program (NMSP) should consider the risks
associated with materials remaining on vessels to be used as artificial reefs. The NMSP will
consult with appropriate agencies (i.e., U.S. EPA, MARAD) to determine the best management
practices to use in evaluating materials for pollution potential).
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 106to 108fibers/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,
Montoya et al 1985).
PCBs may still exist in water-tight gaskets, cable insulation, paint, transformers, capacitors, and
other components of decommissioned Navy vessels (Martore 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 etal. 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
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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
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 imposex in the
dogwhelk Nucella lapillus potentially leading to sterility (Gibbs etal. 1998).8 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 super(-l) 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 biomass (Coale etal. 1996, Frost 1996, Matsunaga etal. 1994, Takeda 1998, Wells etal.
1995). Hence the concern of unnatural iron inputs from artificial reefs seems 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 Thalassiosirapseudonana and Porphyridium marinum
exposed to lead as well as in sea urchins.
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.
1 Imposex is defined as the development of specific male sexual organs in females.
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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. Polychlorinated 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. Scoffm. 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
Ocean. 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 polychlorinated biphenols on steroid metabolism and
cytochrome P-450 monooxygenase system in the sea star Asterias 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. Punta de 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.
Martore, 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.
Negri, A.P., L.D. Smith, N.S. Webster, A.J. Heyward. 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. Furness 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, PoeceliaFormosa. 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 considering activities such as recycling and reuse operations and possibly diver
safely preparations. Any such salvage operations should occur 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 may allow for improved access for subsequent clean-up efforts.
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 actions needed for
preparation of the reef project workplan. Some general workplan preparation 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;
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Remove hazardous materials and clean vessel;
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
Recommended Checklist for Documenting Vessel Clean-up Using this Guidance9 10
I. Specify particular material of concern
II. Describe narrative clean-up goal for that material of concern
III. Conduct surveys and assessments to determine current conditions/amounts of material of
concern and document and describe:
-S Survey design and assessment methodologies
S Who conducted survey/assessment
-S When survey/assessment was conducted
S Results of survey/assessment
IV. Discuss how the narrative clean-up goal for the given material of concern was achieved
(vessel preparation/clean-up initiated specifically for vessel-to-reef project)
S Who carried out the work?
-S When was the work completed?
S What cleaning method was used? What preparation was done to address this
material of concern? How was the narrative clean-up goal achieved?
S For some materials, the narrative clean-up goal is the removal of all of that given
material (e.g., oil and fuel, solids/debris/floatables, antifreeze and coolants, fire
extinguishing systems, batteries, refrigerants and halons, mercury, black and gray
water, invasive species). For these materials of concern, has the removal of all
the specified material been verified? How much of the material was removed and
what was done with it after removal?
S For some materials of concern, the narrative goal allows for some materials to
remain on the vessel if prepared properly (e.g., asbestos, paint, lead ballast bars,
radioactive materials, negatively buoyant vessel debris). For these materials of
9
This template would be used for each material of concern as presented in the BMPs (e.g., oil and fuel; asbestos;
PCBs; paint; solids/debris/floatables; and batteries, antifreeze, coolants, mercury, radioactive materials and other
materials of environmental concern).
10 This checklist is not a regulatory requirement, nor is it a requirement to submit this information to any particular
governmental or quasi-governmental agency, State or Federal. However, this checklist outlines the type of
information that might be useful to show that the goals in this guidance document have been met.
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concern, how much of the specified material was removed and how much remains
on the vessel (e.g., approximately how many lead ballast bars, approximately how
much surface area is still covered with paint, how many rooms/compartments still
contain friable or nonfriable asbestos-containing material)?
-Was the material prepared with the intention of leaving it on board?
-Is the material encapsulated (friable asbestos) or covered with growth
(active anti-fouling paint)? Enclosed in a room (negatively buoyant vessel
debris)?
S How has the completed work been verified?
V. Identify who prepared this document
S Name(s) and title(s)
S Contact information
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Appendix G
Suggested Cleaning Methods for Oils, Fuels
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 or
oils 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 such fuels or oils. This
will typically require access from the bottom and the top.
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Fuel and Oil Piping Including Manifolds: Fuel and oil piping (including non-segregated
ballast systems) should be drained of all fuel and oil. The cleaning and opening of pipes
varies according to the type of fuel or oil that was contained in the lines. In general, the
more viscous the fuel or oil, 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 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 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 fuel or oil. Fittings should be cleaned, or removed
from the vessel.
Bilge Compartments and Piping
All piping that runs through the bilge areas of machinery spaces should be assumed to be
contaminated by fuel, oil, or greases 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,
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Lubricating
Oil System:
Other Systems:
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.
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
fuels, oils, or greases (e.g., superchargers, turbochargers, air filters)
should be examined visually and cleaned if they 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.artificialreef.be. ca/ARresources/cleanup_guidelines. html]
Environment Canada. 1998. Cleanup Standards for Ocean Disposal of Vessels. Artificial
Reef Society of British Columbia website.
[http://www.artificialreef.be.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_1997.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.pdf]
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.
Telephone conversation with Captain Spencer Slate, ex-USS Spiegel Grove vessel-to-reef
project co-manager. April 17, 2006.
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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U.S. Environmental Protection Agency
U.S. Maritime Administration
EPA842-B-06-002
May 2006
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