Progress report summarizing the reef fish sampling, PCB - Earthjustice
Progress report summarizing the reef fish sampling, PCB - Earthjustice
Progress report summarizing the reef fish sampling, PCB - Earthjustice
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egional recreational offshore <strong>fish</strong>ing destination, a historically significant regional,<br />
national and international diving destination and provide hard bottom <strong>reef</strong><br />
community habitat enhancement in an area off northwest Florida where only about<br />
3% of <strong>the</strong> continental shelf seafloor is well developed natural hard bottom structure<br />
(Thompson et al., 1999). Additionally <strong>the</strong>re were expectations that <strong>the</strong> project would<br />
provide an economic boost to Pensacola and adjacent coastal communities.<br />
The Navy proposed to leave on board <strong>the</strong> ex-Oriskany some regulated solid <strong>PCB</strong><br />
containing material at concentrations ≥ 50 ppm in difficult to access passageways<br />
and compartments on deck levels below <strong>the</strong> carrier’s hanger deck at water depths<br />
from 160-212 feet and deeper where <strong>the</strong> hull was expected to penetrate and settle<br />
below <strong>the</strong> seabed. This triggered a requirement for a risk-based <strong>PCB</strong> bulk product<br />
waste disposal approval from <strong>the</strong> EPA. The EPA/MARAD vessel cleaning BMPs<br />
state, “Where <strong>the</strong>re is reason to suspect manufactured products containing solid<br />
<strong>PCB</strong>s greater than or equal to 50 ppm, remove <strong>the</strong> equipment or component from<br />
<strong>the</strong> vessel or provide proof that <strong>the</strong> equipment or component is free of <strong>PCB</strong>s unless<br />
a bulk product waste disposal approval has been obtained under Title 40 Code of<br />
Federal Regulation (CFR) §761.62(c)” (USEPA and MARAD, 2006). As a result of<br />
this requirement, <strong>the</strong> Navy requested a risk-based <strong>PCB</strong> bulk product disposal<br />
authorization from EPA Region 4 (Atlanta, Georgia).<br />
I(C) (3) Navy Submittal of <strong>PCB</strong> Bulk Product Disposal Application to EPA<br />
On April 28, 2004 <strong>the</strong> U.S. Department of <strong>the</strong> Navy submitted an application to <strong>the</strong><br />
EPA Region 4 Regional Administrator requesting to dispose of <strong>PCB</strong> bulk product<br />
waste remaining on board <strong>the</strong> ex-Oriskany at <strong>the</strong> time of <strong>reef</strong>ing in accordance with<br />
<strong>the</strong> requirements of Title 40 CFR §761.62(c) (Glen Clark, NAVSEA PMS 333,<br />
Oriskany Project Manager, personal communication). The Navy’s application had<br />
to demonstrate that based on technical, environmental, or waste-specific<br />
characteristics or considerations, <strong>the</strong> proposed storage or disposal methods or<br />
locations would not pose an unreasonable risk of injury to health or <strong>the</strong><br />
environment. The EPA subsequently requested o<strong>the</strong>r information that it believed<br />
necessary to evaluate <strong>the</strong> Navy’s application.<br />
I(C) (4) Navy Development of <strong>PCB</strong> Risk Assessment Models and Documents for EPA<br />
Review<br />
The Navy spent several years developing a series of documents justifying <strong>the</strong>ir<br />
request to sink <strong>the</strong> ex-Oriskany with some anticipated <strong>PCB</strong> bulk product left on<br />
board. The document development process with accompanying laboratory and in<br />
situ studies and model development began prior to and continued in tandem with<br />
<strong>the</strong> environmental remediation work on <strong>the</strong> ship. The documents developed for<br />
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