Progress report summarizing the reef fish sampling, PCB - Earthjustice

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for expressing their views on the draft PCB disposal approval and the Oriskany Reef project. The meeting was attended by approximately 150 local residents. Several participants made statements in support of the proposal to reef the ex- Oriskany. Two individuals posed questions to the EPA panel members that were pertinent to the proposed action. During the 30 day public comment period which ended January 19, 2006, EPA received written comments from 143 individuals or organizations. Most of the written comments were short statements in support of the proposed action. Two comments, submitted by Pensacola area residents expressed opposition to the proposed action. EPA also received lengthy comments from the Basel Action Network (BAN), an environmental group, opposing the proposed reefing action and expressing concerns about possible conflict with international laws and treaties if regulated PCBs were left on board the ex- Oriskany when it was reefed. One concern raised was project costs. The approximately $20 million project cost to which Escambia County contributed $950,000 and Okaloosa County $50,000 was not a factor for EPA’s risk based analysis. Based on scrap values at the time and other long range planning considerations, the Navy determined the project was cheaper than subsidized scrapping. Additionally 960 tons of metals were recycled from the ex-Oriskany (Elizabeth Freeze, NAVSEA PMS 33 communication with EPA). There was a local concern about potential diver dermal exposure to PCBs in the water column. EPA considered this dermal exposure minimal when weighed against evaluation of chronic PCB exposure risk from long term fish consumption. There was a question about whether the PCB risk-based PCB bulk waste disposal approval also applied to future vessels. EPA emphasized the approval was only applicable to ex-Oriskany. EPA summarized and formally responded in writing to nine comments that also included the principal concerns of BAN (USEPA, 2006a). On February 15, 2006, in a document issued to the U.S. Navy and the FWC, the EPA, Region 4 (Atlanta, Georgia) approved the risk-based disposal of polychlorinated biphenyl (PCB) bulk product waste associated with the reefing of the decommissioned former Navy aircraft carrier ex Oriskany (CVA-34) (USEPA 2006b). The EPA approval to dispose of PCB bulk product associated with the proposed sinking of the ex-Oriskany for use as an artificial reef was issued pursuant to Section 6(e) of the Toxic Substances Control Act (TSCA), 15 USC § 2605(e), and the federal PCB regulations at 40 CFR § 761.62(c). The approval for risk-based disposal of PCB bulk product waste was revised (Revision #1) by EPA on July 16, 2007 to include Escambia County along with FWC and the U.S. Department of the Navy Inactive Ships Program Office as a responsible party. 18 | P age
I(C)(6) PCB Containing Materials On Board ex-Oriskany Before and After Environmental Remediation PCB source term estimates for the ex-Oriskany were described by Pape (2004). Pape estimated the total weights of the various PCB containing ship board materials identified by NAVSEA PMS 333, the estimated weights of solid PCBs in each material based upon results of the Navy’s routine sampling protocol and results for vessels during the inactivation process. Where direct material weight measurements were unavailable for materials aboard the Oriskany, such quantities were estimated using data from surrogate vessels (e.g. other ships in the Essex/Ticonderoga carrier class). Some materials containing PCBs above regulated levels (at or above concentrations of 50 ppm) were targeted for partial removal. All PCB containing liquids and all lubricants, the latter estimated at 208,140 lbs, were removed (Pape, 2006). The solid phase PCBs were distributed on the ex- Oriskany primarily in wire cable insulation, fiberglass bulkhead insulation, paints, rubber products and vent gasket material left in place, following environmental remediation. The materials were in more difficult to access locations in the ship’s interior, primarily on decks below the hanger bay deck (beneath the flight deck) in compartments, passageways, and other spaces. There was no significant removal of rubber products (estimated at 11,898 lbs) or ventilation gaskets (2,680 lbs) due to unregulated average PCB concentrations in these products (37.3 ppm and 20.3 ppm respectively; 50.9 ppm and 33.5 ppm at the 95% Upper Confidence Limit, respectively). About 5% or 44,000 lbs of the 298,999 lbs of paint coatings on board were removed in the form of loose, flaking paint. The average PCB concentration in the paints was reported at 11.6 ppm (19.7 ppm at the 95% Upper Confidence Limit). Approximately 72.6% (83,995 lbs) of the estimated 115,695 lbs of bulkhead insulation were removed. Next to cable insulation which originally contained about 95% of the PCBs prior to partial removal, the bulkhead insulation, prior to partial removal had the next highest total quantity of PCBs (3% or 24.9 lbs; 68.0 lbs at the 95% Upper Confidence Limit). The average PCB concentration in bulkhead material was 215 ppm (587.7 ppm Upper Confidence Limit). Pape (ibid.) estimated 403,600 lbs of electrical cable insulation was originally on board the ex-Oriskany. This figure excluded the weight of the wiring housed by the insulation and any paint coating the insulation. Average cable insulation PCB concentrations were 1493 ppm (2766.0 ppm, 95% Upper Confidence Limit). Approximately 10% of the insulation was estimated to have been removed during environmental remediation with the accompanying nonferrous metal wiring salvaged and recycled. Electrical cable removal occurred primarily in the ship’s island (superstructure) and hanger bay below the flight deck. PCBs in the 90% of the remaining electrical cable 19 | P age
Page 1 and 2: Progress report summarizing the ree
Page 3 and 4: EXECUTIVE SUMMARY In compliance wit
Page 5 and 6: LIST OF FIGURES Figure Page No. 1.
Page 7 and 8: I (A) (1) EPA Oriskany Reef PCB Tie
Page 9 and 10: validate the Navy developed PCB fat
Page 11 and 12: that “the numbering standard for
Page 13 and 14: ship material leachate experiments
Page 15 and 16: solid PCB containing materials woul
Page 17: EPA review included: 1) a human hea
Page 21 and 22: I(C) (8) Oriskany Reef Created In a
Page 23 and 24: fishes for the Monitoring Work Plan
Page 25 and 26: I (D) (2) Fishing Vessel Sampling P
Page 27 and 28: long from the top to the mouth of t
Page 29 and 30: During sample round #2 all four che
Page 31 and 32: The rod and reel manpower sampling
Page 33 and 34: was intentionally scheduled after t
Page 35 and 36: weren’t running after each fish w
Page 37 and 38: actually shipped to GERG on Februar
Page 39 and 40: samples during Sampling Rounds 1-8
Page 41 and 42: harvesting at least 15 legal size r
Page 43 and 44: attraction as expressed by an incre
Page 45 and 46: Of these 10 reef assessment dives,
Page 47 and 48: assessments which were limited to t
Page 49 and 50: not considered target species for a
Page 51 and 52: have had any PAH levels approaching
Page 53 and 54: Oriskany, and one recapture at a
Page 55 and 56: ed snapper season commencement. The
Page 57 and 58: Table 8a. List of reef fish species
Page 59 and 60: Oriskany Reef during Sampling Round
Page 61 and 62: Species Composition of Oriskany Sam
Page 63 and 64: The GERG lab reported their receipt
Page 65 and 66: pectoral fins of the blackfin snapp
Page 67 and 68: Trophic level or position Trophic p
Page 69 and 70:
that means after five years only 3%
Page 71 and 72:
II (D) (1) (c) Red Snapper Discussi
Page 73 and 74:
1,000,000 ΣPCB (pg/g) a. Sample Da
Page 75 and 76:
The PCB levels measured from red sn
Page 77 and 78:
fins relatively short, not reaching
Page 79 and 80:
Results of PCB analysis by sample d
Page 81 and 82:
ody, these spots giving a yellow-st
Page 83 and 84:
II (D) (3) (c) Red Porgy Discussion
Page 85 and 86:
cheeks that are speckled with brigh
Page 87 and 88:
II (D) (4) (c) Whitebone Porgy Disc
Page 89 and 90:
(common) name. The first spine is l
Page 91 and 92:
II (D) (5) (c) Gray Triggerfish Dis
Page 93 and 94:
The Scamp inhabits continental shel
Page 95 and 96:
Results of PCB analysis by sample d
Page 97 and 98:
species was not among the first 30
Page 99 and 100:
elieved to be unlikely since most o
Page 101 and 102:
trip less than 15% of the time due
Page 103 and 104:
II F (6) (b) Current Florida Marine
Page 105 and 106:
assessment, technological feasibili
Page 107 and 108:
III Oriskany Reef Monitoring Projec
Page 109 and 110:
Fishbase.org (Internet site). 2011.
Page 111 and 112:
Ingram, G.W., Jr. and W.F. Patterso
Page 113 and 114:
Patterson, W. F., J. H. Cowan Jr, e
Page 115 and 116:
Thompson, M.J., W.W. Schroeder, and
Page 117 and 118:
Table 2. FWC Fish Census data taken
Page 119 and 120:
Table 4. Fish census data taken by
Page 121 and 122:
frogfish Antennarius sp.
Page 123 and 124:
eef butterflyfish Chaetodon sedenta
Page 125 and 126:
Vermilion snapper Rhomboplites auro
Page 127 and 128:
OR-RS-042 Red Snapper 4/12/2007 HnL
Page 129 and 130:
OR-RS-155 Red Snapper 11/18/2009 Hn
Page 131 and 132:
Table 14. Tissue sample characteris
Page 133 and 134:
Table 15. Percent composition of to
Page 135 and 136:
Table 16b. Percent composition of t
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Progress report summarizing the reef fish sampling, PCB - Earthjustice

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