remedial efforts will likely be required when
science determines actual environment and human health.
It is very important to note that vessels have short underwater life spans as artificial reefs, estimated at 60 years.125 The limited 60 year lifespan of a vessel as an artificial reef means that liabilities from contamination that can be remediated will remain an economic consideration of the initial dumping. These costs far outstrip any perceived benefits to fisheries. As Jack Sobel, said, "There's little evidence that artificial reefs have a net benefit." 126
Turning back to the Ex-ORISKANY, it is important to note that despite the clean-up
costs, the clean-up wa
remediation left intact an estimated 700 pounds of solid PCBs found in approximately 362,200 pounds of electric cable insulation, 31,700 pounds of fiberglass bulkhead insulation and 284,000 pounds of contaminated paint all left onboard for sinking.127 Some material, such as
Two U.S Coast Guard HU-25 Falcon jets were sunk off the coast of North Carolina as artificial reefs. Image Source: Flickr user Tidewater Muse under Creative Commons agreement. Photo by: Lance Cpl. Randall A. Clinton Photo ID: 2006614155548
125 126 127
Lukens, R.R. and Selberg, 2004. http://www.reuters.com/article/idUSN2943349920070709
http://www.sdafs.org/flafs/PDF/October%202008%20issue.pdf BASEL ACTION NETWORK
the electric cable insulation, sampled as high as 19,000 ppm with an average of 1,500 ppm.128 Legal PCB levels under the Toxic Substances Control Act (TSCA) are equal to or less than 50 ppm.
The Navy claimed that the estimated 680,000 pounds of PCB contaminated material, existing in hundreds of compartments at various levels below the main deck, was not accessible unless the vessel was fully dismantled. Rather than dismantling and recycling the vessel at an approved domestic facility, the Navy identified remediation of these PCBs as cost-prohibitive and sought an exception to TSCA via a risk- based disposal permit from the EPA. The Navy developed the Prospective Risk Assessment Model (PRAM) and conducted a study at a cost of $3.74 million to illustrate a limited risk to human health and the environment from the ocean disposal of PCBs during the sinking of this vessel.
The EPA and its Science Advisory Board accepted the Navy’s conclusions that the risks associated with sinking the vessel were negligible and that the sinking would result in a material value to sports fisheries. On this basis, the EPA issued the risk-based disposal permit for the sinking of the PCB contaminated vessel. However, the environmental implications of such a decision are still yet to be fully realized, but future remediation costs are probable.