Monday, April 28, 2014

STORIS not the first Queen to be dishonored: CGC ACUSHNET pt. 2


USCGC ACUSHNET and USCGC STORIS, together in a photo for the Historic American Engineering Record.

The USS HOGA (YT-146) assists the burning USS NEVADA (BB-36) out of the main channel during the Japanese attack on Pearl Harbor, Dec. 7, 1941. NEVADA was the only battleship able to sortie during the attack but was badly damaged and in danger of sinking in the channel, obstructing the harbor. HOGA helped beach the NEVADA at Hospital Point, out of the channel. The plucky little tug then helped fight fires and rescue survivors throughout the harbor area.

As outlined earlier, STORIS was identified in the December 2006 Environmental Assessment as being problematic because of PCB contamination, relegating her to special disposition procedures because of the TSCA. STORIS would have had to be transferred to another US federal agency, a foreign government, or a museum nonprofit by conditional donation. However, the removal of 18 linear feet of a black foam insulation in January 2007 miraculously made STORIS free of regulated PCBs. ACUSHNET was declared PCB-free in the EA. The transfer of any property that is contaminated with hazardous materials such as PCBs, asbestos, or lead-based paint through GSA is regulated by 41 CFR 101-42.

PCBs were extensively used in shipbuilding and maintenance applications up until the chemicals were banned in 1979. Since both ships were constructed during World War II and similar coatings, lubricants, wiring and other materials that would have contained PCBs as a matter of the pervasive use of these substances, the likelihood that either ship was truly “PCB-free” is seriously open to debate. Several other cutters that were of World War II vintage that would have used similar materials and their PCB-free status also come into question, particularly the three 180-foot Seagoing Buoy Tenders on the Great Lakes that are used as museum ships, BRAMBLE (WLB-392), SUNDEW (WLB-404) and ACACIA (WLB-406), as well as the heavy icebreaker MACKINAW (WAGB-83). MACKINAW was built in Toledo right after STORIS. Then there is IRONWOOD (WLB-297), which is used as a training ship in Astoria, OR.

While the 180s were updated with new wiring in the 1970s during their MAJREN yard periods, the wiring would still have been manufactured before the 1979 PCB ban. Earlier coats of interior paints that may have contained PCB-based flame retardants would also still be on board beneath subsequent layers of paint from later years. I have been told it would unusual for all interior paint surfaces to be blasted to bare metal as were some of the outer hulls, so it is still quite possible that all these ships contain PCBs to some degree. Two other 180s, PLANETREE (WLB-307) and IRIS (WLB-395) are currently in the Suisun Bay Reserve Fleet mooring where STORIS spent six years. They are currently being offered for scrap through a memorandum of agreement between the U.S. Coast Guard and MARAD as these two ships are considered too contaminated with PCBs and other toxic materials to sell or donate for any other purpose without Congressional approval. It does raise some legitimate questions, particularly with the sparse paper trail leading back to the U.S. Coast Guard related to exactly how all of these ships were remediated of hazardous materials. Even the recently released MARAD paperwork related to STORIS questioned the validity of the CG’s position that the ship was clean.

It’s expensive and comprehensive to test absolutely everything that may contain PCBs on older ships, so it is accepted within the U.S. shipbreaking industry that only way a ship of that vintage can be totally and truly PCB-free would be to dismantle it and properly recycle all the materials to absolutely remove any possible PCB-impregnated materials.

Again, a good read of the pervasive use of PCBs on obsolete vessels is here:

When donating ships for preservation and museum/monument use, the U.S. Navy requires that the museum groups enter into a very detailed, extensive three-way agreement between the EPA, the Navy and recipient of the ship that binds the museum group to recognize the probability of PCB contamination on board the ship they are receiving. The agreements outline the locations where PCBs may be found and the legal obligations for how to handle any work that might disturb the PCB-containing material. Had STORIS Museum and The Last Patrol been successful in taking custody of STORIS from the government, I have been told by two experts in the shipping industry that the museum organizations would have had to sign such an agreement. Yet there is no evidence that any such documentation was required by the U.S. Government agencies involved with the excessing, sale and approval for export of the ship. There also does not seem to be any evidence of similar agreements for the 180s and MACKINAW.

Here are examples of such PCB agreements, these being from the USS HOGA, a 1941-built tugboat that is a National Historic Landmark as the last of the ships that was physically AT Pearl Harbor during the Dec. 7 attack. These agreements serve as a waiver of the TSCA that regulates PCBs. This is one of the federal laws that was likely violated with the excessing/sale of STORIS and export for scrapping in a “lesser-developed” country. (Violation of TSCA probably also includes the sales of ACUSHNET and the other ships as federal law prohibits the “distribution in commerce” of vessels containing PCBs…) HOGA was built in the same time frame as STORIS and would likely have used much of the same construction and maintenance materials over the years. After her Navy years, she was used as a fireboat in Oakland, CA.

The donation agreement for HOGA:

The agreement between the EPA and U.S. Navy:

The binding agreement for the Arkansas Inland Maritime Museum, recipient of HOGA:

While HOGA requires these strict waivers to comply with TSCA, the Coast Guard ships do not have these agreements. Instead, there are simple, one-line designations within their paperwork that identify them as “PCB-free” with no backup documentation to prove HOW they are clean, with no details of remediation or how extensive testing would prove otherwise.

More about HOGA:

The tug is currently in the SF Bay area while the Arkansas museum works to collect donations to fund the tow to her proposed display berth in North Little Rock.

The statements received from members of STORIS’ last crew validated the concerns that STO had undocumented materials on board that would have contained regulated amounts of PCBs. It stands to reason that, if the same lax testing procedures were used to look for PCBs on the other ships by following testing procedures that intentionally avoided sampling locations where PCBs would be found, that the other ships likely contain PCBs on board. MACKINAW’s paperwork shows PCB testing performed in a similar fashion to that which was done on STORIS a few months later. I have had STORIS crew who also briefly sailed on ACUSHNET tell me that she was similarly equipped and configured with equipment that was “old.” I also had a very experienced Coast Guard officer who served on several 180s and MACKINAW tell me about potential locations where old wiring and paint would be found. Yet looking at the Environmental Assessments for STORIS/ACUSHNET and MACKINAW as well as the transfer paperwork for BRAMBLE, serious questions arise as to the true validity of the “PCB-free” designation.

These circumstances, as outlined, seem to demonstrate a serious issue of how the government disposed of these vessels. This includes the sale of STORIS (for foreign scrapping), ACUSHNET (for private use that will likely disturb encapsulated PCBs through fanciful and disrespectful modification) or the other ships used as museums, all without the strict hazardous materials guidelines outlined as in the U.S. Navy agreements.

(Originally posted April 7, 2014)

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