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40

2011

DISHONORABLE DISPOSAL

effects…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 carcinogenic effects of PCBs.” 117

and

non-

c. Iron

Iron can leach into the environment from steel hulls of sunken vessels. 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. 118

d. Lead Paint

The EPA notes that lead paint has been used on the interiors of some vessels; however the BMP does not require intact lead paint to be removed.119 Lead from paint exhibits accumulation trends in organisms. Corals have

been shown to incorporate lead skeletons and growth inhibition

into

their

has

been

observed in algae exposed to lead.120

species

and

sea

urchins

e. Antifouling Paint Antifouling paints containing tributyltin (TBT) were used to paint vessel hulls to inhibit the growth of organisms below the water line. In 2001, an International Maritime Organization

Convention antifouling states in

was adopted to prohibit paints containing TBT.

the

BMP

document,

the use of The EPA “Scientific

investigations

by

governments

and

international organizations have shown that certain anti-fouling systems used on vessels pose a substantial risk of both acute and chronic toxicity and other adverse impacts to

National Guidance: Best Management Practices for Preparing Vessels Intended to Create Artificial Reefs, May 2006, Pg. 35. 117

Coale et al. 1996; Frost 1996; Matsunaga et al. 1994; Takeda 1998; Wells et al. 1995. 118

National Guidance: Best Management Practices for Preparing Vessels Intended to Create Artificial Reefs, May 2006, Pg. 42 119

120

Thompson, 1990.

BASEL ACTION NETWORK

ecologically and economically important non- target marine organisms. Because this document [BMP] 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.” 121

Antifouling paints containing TBT are present on vessels sunk as artificial reefs. The above EPA statements are merely cautionary as the BMP does not recommend removal of all TBT paints.

f. Polybrominated Diphenyl Esters Polybrominated diphenyl esters (PBDEs) are flame retardants and are found in plastics and upholstery foam (National Marine Fisheries Service 2006). PDBEs likely occur in materials on ships, but their presence and concentration levels have not yet been identified. PBDEs are not mentioned in EPA’s BMP, nor any other guidance or regulation concerning sinking of vessels. PBDEs have been linked to health problems, and like PCBs they bio-accumulate (National Marine Fisheries Service 2006).122

The Needs Assessment and Scoping Study for Sinking Ships as Diving Sites in Puget Sound identifies PBDEs as a contaminant of concern, but the EPA has not yet addressed remediation

of

PBDEs

for

ship

sinking

preparation.

National Guidance: Best Management Practices for Preparing Vessels Intended to Create Artificial Reefs, May 2006, Pg. 41 121

122

http://pubs.usgs.gov/of/2008/1020/pdf/ofr20081020.pdf

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