Watch this EPA video on YouTube about PCBs on board obsolete ships:
Ironically, the narrator, Christopher Rollins of EPA Region IX, was directly involved with releasing STORIS for export. Jon Ottman spoke with him in the days prior to STORIS being towed from Suisun Bay and Rollins indicated that he had paperwork that indicated that the ship was free of regulated PCBs. Rollins obviously never inspected the ship himself. That paperwork was later shared with Jon Ottman and shared here in prior posts. These documents are clearly deficient, particularly in light of information that was revealed after the ship arrived in Mexico.
It became known after the export of STORIS to Mexico that there were, indeed, large quantities of undocumented wiring on board the ship, wiring that was not included in any of the US Coast Guard documentation or the GSA literature that was publicly available related to STORIS and her sale through GSA Auction. GSA listed STORIS for sale as a seaworthy vessel in the auction listing, with no indication that she contained hazardous materials or PCBs.
We received two key letters, signed statements from men who served on the ship’s last crew. One was a letter from an electrician’s mate, testifying to the large amount of original and old wiring still on board STORIS. While most of it had been bypassed, a large quantity of wiring was abandoned in place because it was encapsulated in asbestos. To remove the wiring would have disturbed the asbestos, creating two haz-mat situations out of one. This wire could date back as far as 1942 when the ship was built and had a high probability of containing PCBs at levels above regulated limits. The letter also explained that there was an oily substance oozing from the wiring into the junction boxes throughout the ship, particularly in a main junction box in the overhead on the mess deck. This oily substance is consistent with PCB-containing materials.
The other letter was from a senior enlisted deck officer. The letter addressed the PCB report used by GSA, EPA, MARAD and the Coast Guard to approve the export of STORIS to Mexico for scrapping. This gentleman went through and line-by-line, pointed out that the sites chosen were deficient. In his expressed opinion as an experienced deck officer with 30 years of service in the Coast Guard and two tours aboard STORIS, there was a conscious effort to avoid testing areas on STORIS that would have tested positive for PCBs above regulated levels. He explains that most of the chosen test sites were materials added to the ship well after the 1979 PCB manufacturing ban implemented in the U.S. He identifies significant quantities of old wiring on board the ship that would likely contain PCBs as well as quantities of asbestos and lead paint.
Another critical find was a document that was created for the shipyard contractors that would be assuming the layup work for STORIS after she was turned over by Coast Guard personnel for final preparation for her storage in the Suisun Bay National Defense Reserve Fleet, near Benicia, California. This document from May 2007 has standard boilerplate language discussing various hazards on the ship but on page 48, section 3.8, are the instructions for the lamping of the ship during her mothball layup. The specifications read as follows: "the original lighting distribution wirings (sic) is in fair to poor condition, and keeping it energized without a watch presents a risk of electrical fire." This is a direct reference to the original/old wiring referred to in the EM’s statement. This confirms the presence of old wiring in the ship and in a document generated by the U.S. Coast Guard itself. Work to eliminate or remedy this old wiring was not taken. STORIS was put into storage in summer 2007 and sat untouched until the tow to Ensenada October 25 and arrival on 29 October.
The layup document is located here: http://goo.gl/d1DC5U
There is a high likelihood that STORIS was exported with a significant quantity of undocumented wiring and interior paints on board that contain polychlorinated biphenyls (PCBs) above regulated limits of 50 ppm. There are several federal laws – US and Mexican – are likely to have been violated. Those laws and regulations include, but are not limited to, the National Environmental Policy Act, the Bilge and Ballast Water regulations and conforming San Francisco Bay Area Regional Water Quality Control Board policy concerning obsolete vessels held at the Suisun Bay Reserve Fleet (SBRF), the Toxic Substances Control Act of 1976 (TSCA) PCB export regulations and the international Basel Convention, of which Mexico is a signatory. There is also the matter of whether GSA ensured the buyer would comply with international environmental compacts which the U.S. is a party to, such as the Organization of Economic Co-operation and Development (OECD). It is worth noting that Mexican law prohibits the import of PCBs and that country has no facility capable of properly disposing of PCBs.
MEXICO HAS NO FACILITIES AT WHICH PCBS CAN BE DISPOSED OF IN AN ENVIRONMENTALLY SAFE MANNER. This is evidenced by the since-withdrawn EPA waiver to import tons of PCBs from Mexico by Veolia ES Technical Solutions in Texas (http://www.epa.gov/osw/hazard/tsd/pcbs/pubs/veolia.htm).