U.S. Environmental Protection Agency U.S. Maritime Administration 

National Guidance: Best Management Practices for 

Preparing Vessels Intended to Create Artificial Reefs 

May 2006 
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Page Left Intentionally Blank
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ACKNOWLEDGEMENTS 

This document was jointly developed by the U.S. Environmental Protection Agency’s (EPA) 

Oceans and Coastal Protection Division within the Office of Water and the Department of 

Transportation’s Maritime Administration. To assist in early stages of document development, 

an interagency workgroup was established by Laura S. Johnson of EPA. The following agencies 

actively participated on this workgroup: 

• Maritime Administration 

• National Oceanic and Atmospheric Administration 

• United States Army Corps of Engineers 

• United States Fish and Wildlife Service 

• United States Coast Guard 

• United States Department of the Navy 

• United States Environmental Protection Agency 

 

 

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 Photo courtesy of Laura S. Johnson

Maritime Administration’s James River Reserve Fleet, Virginia. 

Cover Photos

Top photo: Ex-USS Spiegel Grove en route to artificial reef sink site. Photo courtesy of Andy Newman, Florida 

Keys News Bureau. 

Middle photo: Ex-USS Spiegel Grove resting at its artificial reef site. Photo courtesy of Florida Fish and Wildlife 

Conservation Commission, Division of Marine Fisheries Management, Artificial Reef Program. 

Bottom photo: The scuttling of Navy Dive Tender YDT-14 on April 1, 2000, approximately 18 miles SE of 

Pensacola Pass, Escambia County, Florida. Photo courtesy of Florida Fish and Wildlife Conservation

Commission, Division of Marine Fisheries Management, Artificial Reef Program. 
4

TABLE OF CONTENTS

Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 

Siting of Artificial Reefs . . . . . . . . . . . . . . . . . . . . . . . . . 17 

Guidance for Preparing Vessels to Create Artificial Reef Habitat 

Oil and Fuel 

 Narrative Clean-up Goal . . . . . . . . . . . . . . . . . . 22 

 What are oil and fuel? . . . . . . . . . . . . . . . . . . 22 

What are the potential environmental impacts 

of oil and fuel? . . . . . . . . . . . . . . . . . . . 22 

 Where are oils and fuels found in a ship? . . . . . . . . . 23 

 How should the vessel be prepared; what are the 

 appropriate BMPs for oil and fuel? . . . . . . . . 24 

Asbestos 

Narrative Clean-up Goal . . . . . . . . . . . . . . . . . . 30 

What is asbestos? . . . . . . . . . . . . . . . . . . . . . . 30 

What are the potential environmental impacts 

of asbestos? . . . . . . . . . . . . . . . . . . . . 31 

 Where is asbestos found on a ship? . . . . . . . . . . . . 31 

 How should the vessel be prepared; what are the 

 appropriate BMPs for asbestos? . . . . . . . . . . 32 

Polychlorinated Biphenyls (PCBs) 

Narrative Clean-up Goal . . . . . . . . . . . . . . . . . . 35 

What are PCBs? . . . . . . . . . . . . . . . . . . . . . . . 35 

 What are the potential environmental impacts of PCBs? . . 35 

 Where are PCBs found on a ship? . . . . . . . . . . . . . 36 

 How should the vessel be prepared; what are the 

 appropriate BMPs for PCBs? . . . . . . . . . . . . 37 

Paint 

Narrative Clean-up Goal . . . . . . . . . . . . . . . . . . 40 

 What types of paint and anti-fouling systems are used 

on ships and where are they found? . . . . . . . . 40

What are the potential environmental impacts 

 of paint? . . . . . . . . . . . . . . . . . . . . . . 41 

 How should the vessel be prepared; what are the 

 appropriate BMPs for paint? . . . . . . . . . . . . 41 
5

Solids/Debris/Floatables 

Narrative Clean-up Goal . . . . . . . . . . . . . . . . . . 43 

What are solids/debris/floatables? . . . . . . . . . . . . . 43 

What are the potential environmental impacts 

of solids/debris/floatables? . . . . . . . . . . . . . 43 

 Where are solids/debris/floatables found on ships? . . . . 44 

 How should the vessel be prepared; what are the 

 appropriate BMPs for solids/debris/floatables? . . 44 

Other Materials of Environmental Concern 

Narrative Clean-up Goal . . . . . . . . . . . . . . . . . . 46 

What are other materials of environmental concern? . . . . 46 

What are the potential environmental impacts of 

other materials of environmental concern? . . . . . 46 

 Where are other materials of environmental concern 

 found on ships? . . . . . . . . . . . . . . . . . . . 46 

 How should the vessel be prepared; what are the 

 appropriate BMPs for other materials of 

environmental concern? . . . . . . . . . . . . . . 46 

Considerations for Other In-water Uses of Obsolete Vessels 

Diving Opportunities . . . . . . . . . . . . . . . . . . . . . . . . 50

Exhibits 

Exhibit 1: Summary of Narrative Clean-up Goals for 

Materials of Concern . . . . . . . . . . . . . . . . . . . . 8 

Exhibit 2: Ex-USS Spiegel Grove Total Project Costs . . . . . . 11 

Exhibit 3: Ex-USS Spiegel Grove Vessel Specifications . . . . . 11 

Exhibit 4: Ex-USS Oriskany Total Project Costs . . . . . . . . . 12 

Exhibit 5: Ex-USS Oriskany Vessel Specifications . . . . . . . 12 

Appendices 

Appendix A: Federal Statutes Related to the Transfer of 

Obsolete MARAD and Navy Vessels for Use as 

Artificial Reefs . . . . . . . . . . . . . . . . . . . . . . . 51 

Appendix B: Federal Environmental Laws Relevant for 

Consideration in the Preparation of a Vessel for 

Use as an Artificial Reef . . . . . . . . . . . . . . . . . . 57 
6

Appendix C: Information Related to Materials Found on 

Scuttled Vessels that may have Potentially Hazardous 

Effects on the Marine Environment . . . . . . . . . . . . 65 

Appendix D: Developing Workplans for Vessel Preparation 

Prior to Reefing . . . . . . . . . . . . . . . . . . . . . . 68 

Appendix E: General Principles for a Vessel Clean-up Operation . 70 

Appendix F: Recommended Checklist for Documenting 

Vessel Clean-up Using this Guidance . . . . . . . . . . . 71 

Appendix G: Suggested Cleaning Methods for Oils, Fuels, and 

Semi-solids (Greases) . . . . . . . . . . . . . . . . . . . 73 

References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 76

Photo courtesy of Florida Fish and Wildlife Conservation Commission 

The scuttling of Adolphus Busch on Dec. 5, 1998, approximately 7 miles S of 

Summerland Key, Monroe County, Florida. 
7

EXECUTIVE SUMMARY 

This guidance document was developed to satisfy the mandate of Section 3516 of the National 

Defense Authorization Act for Fiscal Year 2004, which requires that the Maritime 

Administration (MARAD) and the U.S. Environmental Protection Agency (EPA) jointly develop 

guidance recommending environmental best management practices to be used in the preparation 

of vessels for use as artificial reefs. It also responds to MARAD’s request for the EPA to 

provide national environmentally-based best management practices for the preparation of vessels 

to be sunk with the intention of creating artificial reefs in permitted artificial reef construction 

areas. 

Options for managing obsolete and decommissioned military and commercial vessels include reuse of the vessel or parts of the vessel, recycling or scrapping, creating artificial reefs, and 

disposal on land or at sea. This document discusses the preparation of obsolete and 

decommissioned military and commercial vessels when employing the vessel management 

option of artificial reefing. Artificial reefs should only be developed where such reefs will 

enhance native marine resources and benefit the natural marine environment. Strategically sited 

artificial reefs not only can enhance aquatic habitat, but also provide an additional option for 

conserving, managing, and/or developing fishery resources. 

Although the best management practices presented in this document are intended for use when 

preparing vessels to serve as artificial reef habitat, the best management practices may have 

applicability to other in-water uses of vessels, such as the creation of recreational diving 

opportunities. It is recommended that these best management practices be implemented for such 

in-water uses of vessels, with the caveat that further vessel preparation beyond that employed for 

artificial reef habitat may be needed. When preparing a vessel for such in-water uses, 

consideration should be given to vessel stability and integrity prior to and after final placement. 

This guidance identifies materials or categories of materials of concern that may be found aboard 

vessels and specifically identifies where they may be found. For each material or category of 

material, this document provides a narrative clean-up performance goal and information on 

methods for achieving those goals in preparation of the vessel prior to sinking. Materials of 

concern include, but are not limited to: oil and fuel, asbestos, polychlorinated biphenyls (PCBs), 

paint, solids/debris/floatables, and other materials of environmental concern. Exhibit 1 provides 

a summary of the narrative clean-up goals for materials of concern. 

In keeping with Section 3516 of the National Defense Authorization Act for Fiscal Year 2004, 

this guidance document addresses only recommended clean-up practices for vessels that are 

intended to be placed as artificial reefs. It neither endorses such placement nor does it address 

the potential availability or environmental effects associated with alternatives to placement of 

vessels as artificial reefs. 
8

Exhibit 1. Summary of Narrative Clean-up Goals for Materials of Concern 

Material of Concern Narrative Clean-up Goal

Oil And Fuel 

Remove liquid fuels and oils and semi-solids (greases) so that: no visible 

sheen is remaining on the tank surfaces (this includes all interior fittings, 

piping, structural members); no film or visible accumulation is remaining on 

any vessel structure or component (e.g., on machinery or from spills on 

decking or carpet). The end result of such clean-up should be that no sheen 

be visible upon sinking a vessel. 

Asbestos 

Remove any loose asbestos and asbestos that may become loose during 

vessel sinking; remove or seal accessible friable asbestos.

Polychlorinated 

Biphenyls (PCBs) 

Remove all manufactured products containing greater than or equal to (≥) 50 

parts per million (ppm) of solid PCBs; remove all liquid PCBs regardless of 

concentration; remove all materials contaminated by PCB spills where the 

concentration of the original PCB source is ≥ 50 ppm. 

Paint

Remove harmful exterior hull anti-fouling systems that are determined to be 

active; remove exfoliating (peeling) and exfoliated paint. 

Solids/Debris/ 

Floatables 

Remove loose debris, including materials or equipment that are not 

permanently attached to the vessel that could be transported into the water 

column during a sinking event. 

Other Materials of 

Environmental Concern 

Remove other materials that may negatively impact the biological, physical, 

or chemical characteristics of the marine environment. 

The narrative clean-up performance goals for the materials of concern highlighted in this 

guidance should be achieved while preparing a vessel intended for artificial reefing. There are 

statutory requirements and associated regulations, as well as permit processes applicable to the 

process of preparing a vessel for reefing that are not highlighted in this document. These 

include, but are not limited to, issues such as vessel inspections by appropriate authorities and 

storage and disposal of waste generated during clean-up/preparation. Further, this document 

does not provide information on how to sink a vessel or the required actions or regulatory 

procedures/processes associated with the actual act of sinking a vessel. 
9

INTRODUCTION 

Several options exist for managing obsolete and decommissioned military and commercial 

vessels. These options include re-use of the vessel or parts of the vessel, recycling or scrapping, 

creating artificial reefs, and disposal on land or at sea. This document discusses the vessel 

management option of artificial reefing. This guidance document was developed to satisfy the 

mandate of Section 3516 of the National Defense Authorization Act for Fiscal Year 2004, which 

requires that the Maritime Administration (MARAD) and the U.S. Environmental Protection 

Agency (EPA) jointly develop guidance recommending environmental best management 

practices (BMPs) to be used in the preparation of vessels for use as artificial reefs. It also 

responds to MARAD’s request for the EPA to provide national environmentally-based best 

management practices for the preparation of vessels to be sunk with the intention of creating 

artificial reefs in permitted artificial reef construction areas. 

An interagency workgroup, chaired by EPA, was established to develop the BMPs. The 

workgroup included representatives from the EPA, U.S. Coast Guard, U.S. Navy, MARAD, U.S. 

Army Corps of Engineers, National Oceanic and Atmospheric Administration, and the U.S. Fish 

and Wildlife Service. 

Although these best management practices are intended for use when preparing vessels to serve 

as artificial reef habitat, such best management practices may have applicability to other in-water 

uses of vessels, such as the creation of recreational diving opportunities. The best management 

practices presented in this document should be implemented for all permitted in-water uses of 

vessels; further diver safety preparations may be needed based on the intended in-water use, such 

as recreational diving.

Objectives of the Guidance Document

The BMPs, jointly developed by EPA and MARAD, are to serve as national guidance for federal 

agencies for the preparation of vessels for use as artificial reefs. Section 3516 of the National 

Defense Authorization Act for Fiscal Year 2004 provides that the BMPs are to (1) ensure that 

vessels prepared for use as artificial reefs “will be environmentally sound in their use as artificial 

reefs”; (2) “promote consistent use of such practices nationwide”; (3) “provide a basis for 

estimating the costs associated with the preparation of vessels for use as artificial reefs”; and (4) 

include measures that will “enhance the utility of the Artificial Reefing Program of the Maritime 

Administration as an option for the disposal of obsolete vessels.” Appendix A provides further 

detail on Section 3516 and MARAD’s authority to transfer obsolete vessels for artificial reefing. 

Below is a description of how this document addresses the four requirements of the statute. 

• The use of this guidance will help ensure that vessels prepared for use as artificial reefs 

“will be environmentally sound in their use as artificial reefs.” For each material of 

concern identified, this document provides a narrative clean-up performance goal and 

information on methods for addressing those goals in preparation of the vessel prior to 

sinking. The preparation of vessels in this manner will help ensure that their use as 

artificial reefs is environmentally sound. The purpose of creating an artificial reef is to 

benefit the environment by enhancing aquatic habitat and marine resources, as well as 
10

 

providing an additional option for conserving, managing, and/or developing fisheries 

resources. This document describes appropriate vessel preparation that could achieve 

such benefits as an artificial reef and avoid negatively impacting the environment with 

pollutants. The narrative clean-up performance goals provided in this document, if 

implemented and complemented with strategic site selection (siting), will maximize the 

opportunity for these vessels to benefit the environment as artificial reefs. 

• The use of this guidance document will “promote consistent use of such practices 

nationwide” and in turn will also provide measures that will “enhance the utility of the 

Artificial Reefing Program of the Maritime Administration as an option for the disposal 

of obsolete vessels.” The best management practices described in this document serve as 

national guidance for the preparation of vessels for use as artificial reefs. As the use of 

vessels as artificial reefs is becoming a more common management option for obsolete 

vessels, the development of this guidance document is timely. Currently, no guidance of 

this kind is available. The use of this guidance document can enhance the utility of 

MARAD’s Artificial Reefing Program, by establishing a national approach to cleaning 

and preparing candidate obsolete vessels, while also promoting consistent use of such 

practices for vessel-to-reef projects. 

• The use of this document will “provide a basis for estimating the costs associated with 

the preparation of vessels for use as artificial reefs.” Although the best management 

practices were developed independent of costs associated with clean-up, the narrative 

clean-up performance goals in this document can be used as a basis for estimating the 

cost for appropriate vessel preparation. In order to determine the estimated cost to 

prepare a specific vessel for use as an artificial reef, the narrative clean-up performance 

goals, along with the vessel preparation BMPs, can be used to scope the volume of work 

to be accomplished based on a detailed ship-check and implementation of a 

representative PCB sampling protocol. There is wide variability of ships and associated 

kinds and amounts of material found on a particular ship, as well as wide variability of 

remediation and disposal costs in different geographic locations within the U.S. 

Therefore, it is not possible to provide in this document representative cost estimates 

associated with the preparation of a ship for reefing. A reasoned estimate of the actual 

cost of preparation will require a ship-by-ship analysis. 

In order to provide some insight into the costs that have been incurred for vessel-to-reef 

projects, some pertinent vessel-specific information is provided here. Two recent 

examples of vessels that have been prepared with the intent of serving as artificial reefs 

are the ex-USS Spiegel Grove and the ex-USS Oriskany. The total cost of reefing the exUSS Spiegel Grove, which was a MARAD vessel, was $1.3 million.1

 This total cost 

includes costs for both vessel clean-up/preparation, as well as costs other than vessel 

clean-up/preparation. Details of the project cost estimates are presented in Exhibit 2. 

Vessel specifications for the ex-USS Spiegel Grove are presented in Exhibit 3. The exUSS Spiegel Grove was cleaned/prepared prior to the availability of the BMPs presented 

in this document. Further information regarding the ex-USS Spiegel Grove can be found 

1

 Communication between Captain Spencer Slate, ex-USS Spiegel Grove vessel-to-reef project co-manager, and 

Laura S. Johnson, EPA. 
11

at http://www.fla-keys.com/spiegelgrove/. 

Exhibit 2. Ex-USS Spiegel Grove Total Project Costs 

PCB sampling protocol and removal $75,000

Reorienting the vessel $550,000

Towing and berthing $125,000 

Other clean-up and scuttling preparation 

and execution $550,000 

Ship clean-up time 7 months 

Project duration 8 years 

Exhibit 3. Ex-USS Spiegel Grove Vessel Specifications 

Type of vessel Landing Ship Dock (LSD) 

Overall length 510 feet 

Extreme beam 84 feet 

Keel date Sept. 7, 1954 

Launch date Nov. 10, 1955 

Decommission date Oct. 2, 1989 

Location of reefed vessel 6 miles off the Florida Keys in 

the Florida Keys National 

Marine Sanctuary 

Photo courtesy of Andy Newman

Ex-USS Spiegel Grove, once a MARAD vessel, under way to 

Florida Keys for final sinking preparations. 
12

The total cost of reefing the ex-USS Oriskany, which is a Navy vessel, was $15.63 

million. This total cost includes costs for both vessel clean-up/preparation, as well as

costs other than vessel clean-up/preparation. Details of the project cost estimates are 

presented in Exhibit 4. As noted later in this document, the Navy is required to 

clean/prepare vessels intended for use as artificial reefs in accordance with this BMP 

guidance. The Draft BMP guidance was available for the ex-USS Oriskany vessel cleanup/preparation. Vessel specifications for the ex-USS Oriskany are presented in Exhibit 5. 

Further information regarding the ex-USS Oriskany can be found at 

http://peos.crane.navy.mil/reefing/oriskany.htm. 

Exhibit 4. Ex-USS Oriskany Total Project Costs 

Ship remediation (BMP-related) $8.28M 

Flight deck remediation (BMP-related) $3.61M 

PCB model and risk assessment 

development (BMP-related) 

$3.74M 

Towing and berthing $3.07M 

Scuttling preparation and execution $4.90M 

Ship clean-up time 12 months 

Project duration 3 years (FY03 

through FY06) 

Exhibit 5. Ex-USS Oriskany Vessel Specifications 

 

 

Type of vessel Essex Class aircraft 

carrier (CV-34) 

Overall length 911 ft 

Extreme beam 107 ft 

Keel date May 1, 1944 

Launch date Oct. 13, 1945 

Decommission date Sept. 30, 1976 

Location designated for reefing this 

vessel 

23 miles south off 

Pensacola, Florida 
13

 

Photo courtesy of U.S. Navy

Ex-USS Oriskany arriving at NAS Pensacola, Florida. March 23, 2006. 

If the narrative clean-up goals provided in this document cannot be economically 

achieved, for example because of very significant amounts of materials of concern on the 

vessel, then the vessel would not be a good candidate for reefing. The methods, 

approach, and level of effort for clean-up, as well as worker safety concerns, are directly 

dependent on the vessel’s condition and the amount of materials of environmental 

concern that are found aboard. Vessels where clean-up could pose potential worker 

safety risks or could incur high costs may not be good candidate vessels for reefing. 2

Some portions of a candidate vessel may be economically salvageable. Any such salvage 

operations should occur in a manner that will minimize debris and contamination with 

oils or other products that have to be cleaned up at a later date. This activity should allow 

for improved access for subsequent clean-up efforts, and the salvage proceeds may help 

offset some costs for vessel preparation. 

Operations associated with salvage, clean-up, and diver access have the potential to adversely 

impact vessel stability. Failure to consider the impact of these activities on vessel stability 

before and during scuttling operations could result in premature and uncontrolled capsizing 

and/or sinking of the vessel. Therefore, vessel stability considerations should be an integral part

of the salvage, clean-up, modification (for diver access), transport, and sinking plans of a vesselto-reef project. 

2

 The BMP guidance does not address worker safety issues. Readers with an interest in such safety issues 

and concerns should consult other relevant documents, such as those prepared by OSHA, State or local

safety agencies, and other relevant EPA documents. For example, EPA’s A Guide for Ship Scrappers –

Tips for Regulatory Compliance presents important information related to environmental and worker safety 

and health issues for ship scrapping/ship breaking operations when handling specific hazardous materials. 

This document can be accessed via the World Wide Web at

http://www.epa.gov/oecaerth/resources/publications/civil/federal/shipscrapguide.pdf. 
14

Photo courtesy of U.S. Navy

Metal recovery and salvage operations onboard the ex-USS Oriskany while being cleaned. 

 

In the process of preparing a vessel for reefing, there are requirements and regulations, including 

permit processes, appropriate disposal of waste generated during vessel clean-up/preparation, 

and vessel inspections by appropriate authorities to consider that are not discussed in great detail 

in this document, with the exception of TSCA requirements applicable to PCBs. Appendix B 

does provide, however, an overview of principal federal environmental statutes potentially 

affecting preparation or placement of a vessel for use as an artificial reef. Further, other than 

siting considerations that would affect how a vessel is prepared for use as an artificial reef, this 

document does not detail the legal requirements applicable to transfer, siting, or sinking of 

vessels as artificial reefs in vessel-to-reef projects, except for the overview offered in Appendix 

B. The information in Appendix B is intended only for the convenience of the reader in order to 

provide a useful starting point for identifying the principal environmental statutes of interest. On 

a case-by-case basis, additional federal statutes also may apply, though the federal statutes 

identified in Appendix B would be most relevant for the preparation of a vessel for use as an 

artificial reef. The final preparation plan for any particular artificial reef project will necessarily 

be vessel-specific, and will depend on the characteristics of the vessel and final permitted 

artificial reef construction site, as well as regulatory considerations. In addition, State and local 

laws also may apply to vessel preparation, but the document does not attempt to identify such 

laws in Appendix B. 

This guidance identifies materials or categories of materials of concern that may be present 

aboard vessels, indicates where these materials may be found, and describes their potential 

adverse impacts if released into the marine environment (Appendix C provides related 

information). The materials of concern include, but are not limited to: fuels and oil, asbestos, 

polychlorinated biphenyls (PCBs), paints, debris (e.g., vessel debris, floatables, introduced 

material), and other materials of environmental concern (e.g., mercury, refrigerants). With the 
15

exception of materials containing PCBs, this document does not comprehensively discuss 

applicable legal requirements, although those requirements that are directly applicable to vessel 

preparation must also be met prior to vessel sinking and placement. Because the best 

management practices described in this document are directed at the environmental concerns 

associated with using vessels as artificial reefs, other sources of information should also be used 

with regard to preparation of the vessel from a diver safety perspective or for any other potential 

in-water uses. 

A detailed description and characterization of the potential sources of contamination from a 

vessel intended for use as an artificial reef should be conducted and a plan developed. The 

purpose of this plan is to assure that materials potentially contributing to pollution of the marine 

environment are addressed. Appendix D of this document presents information regarding the 

development of workplans; Appendix E provides information regarding general principles for 

clean-up operations. 

When preparing a vessel that is intended to serve as an artificial reef, documenting the clean-up 

procedures used and the contaminants that will remain onboard the vessel is a key element of the 

BMPs. More specifically, a description of how the BMP narrative clean-up performance goals 

were achieved, and a visual inspection, are needed to determine whether and how the vessel has 

been cleaned to the level recommended in this guidance document so the vessel can be managed 

appropriately. A recommended checklist for documenting vessel clean-up using this guidance 

can be found in Appendix F. A vessel inspection by qualified personnel should be conducted to 

confirm satisfactory clean-up/preparation. It also should be noted that applicable regulatory 

regimes may require such an inspection. 

Achieving and verifying satisfaction of the BMP clean-up goals could help support permit 

applications under the Clean Water Act Section 404 (33 U.S.C. 1344) or Rivers and Harbors Act 

Section 10 (33 U.S.C. 403), if a permit application is submitted to the U.S. Army Corps of 

Engineers. Further, robust BMP documentation might prove useful for demonstrating 

consistency with Coastal Zone Management Act programs (16 U.S.C. 1452, et seq.), as well as 

for any other State or local certifications necessary to carry out a vessel-to-reef project. Also, 

EPA officials may find BMP documentation useful as part of their review under EPA 

certification authority pursuant to the Liberty Ship Act. (Note: this Act only applies to 

DOT/MARAD-owned obsolete vessels intended for use as an artificial reef for the conservation 

of marine life.) 

This guidance does not substitute for any statute or regulation, nor is it a regulation itself. The 

document recommends environmental best management practices for use in the preparation of 

vessels for use as artificial reefs. Associated with the recommended environmental best 

management practices are narrative environmental clean-up performance goals, as well as 

recommendations and suggestions in furtherance of those goals. By its terms, the guidance itself 

does not impose binding requirements on any federal agency, States, other regulatory or resource 

management authorities, or any other entity. Among other things, the document includes 

mechanisms to enhance the utility of the Artificial Reefing Program of the Maritime 

Administration as an option for the disposal of obsolete vessels. It should be noted that under 10 

U.S.C. 7306b(c), the Secretary of the Navy must ensure that the preparation of a vessel (that is 

stricken from the Naval Vessel Register) for use as an artificial reef is conducted in accordance 
16

with the environmental best management practices in this guidance. This latter statutory 

requirement, not today’s guidance document itself, governs the Navy’s application and use of 

this document. 

Organization of this Guidance Document

This document describes guidelines for the preparation of vessels in a manner that will help 

ensure that the marine environment will benefit from their use as artificial reefs. Strategic siting 

is an essential component of a successful artificial reef project. Before the discussion of vessel 

preparation is presented, a cursory description of reef site selection recommendations is 

provided. 

For each material or category of material of concern identified, this document provides a 

narrative clean-up performance goal and information on methods for addressing those goals in 

preparation of the vessel prior to sinking. Additional information for each material includes a 

description of its shipboard use and where it may be found on a vessel, as well as its expected 

impacts if released into the marine environment. 

Although the best management practices presented in this document are intended for use when 

preparing a vessel to serve as artificial reef habitat, it is recommended that these best 

management practices be implemented for other in-water uses of vessels such as recreational 

diving. This potential obsolete vessel management option is briefly described in this document. 
17

SITING OF ARTIFICIAL REEFS 

Artificial reefs can enhance marine resources and in turn benefit the marine environment; 

however, creating a successful reef entails more than randomly placing miscellaneous materials 

in ocean, estuarine, or other aquatic environments. Planning (including siting), long-term 

monitoring, and evaluation are necessary components of each project to help ensure that the 

anticipated benefits of artificial reefs are attained. Improperly planned, constructed, or managed 

reefs may be ineffective, may cause conflict among competing user groups of the reef site, may 

increase the potential to over harvest targeted species, or may damage natural habitats. In such 

cases, the anticipated benefits of an artificial reef project may be negated. 

Because the purpose of creating an artificial reef is to benefit the environment by enhancing 

aquatic habitat and marine resources, as well as providing an additional option for conserving, 

managing, and/or developing fisheries resources, artificial reefs should not cause harm to 

existing living marine resources and habitats. Properly prepared and strategically sited artificial 

reefs can enhance fish habitat, provide more access to quality fishing grounds, and provide 

managers with another option for conserving, managing and/or developing fishery resources. 

 

Placement of a vessel to create an artificial reef should: 

• enhance and conserve targeted fishery resources to the maximum extent practicable; 

• minimize conflicts among competing uses of water and water resources; 

• minimize the potential for environmental risks related to site location; 

• be consistent with international law and national fishing law and not create an obstruction 

to navigation; 

• be based on scientific information; and 

• conform to any federal, State, or local requirements or policies for artificial reefs. 

Additional considerations that may be relevant to the placement of a vessel for the creation of an 

artificial reef include: 

• facilitating access and use by recreational and/or commercial fishermen; and 

• facilitating access and use by recreational divers. 

Artificial reef project planners should identify the habitat type and/or species targeted for 

enhancement and determine which biological, physical, and chemical site conditions will be 

most conducive to meeting the reef objectives. Once these siting conditions, including 

community settlement and recruitment dynamics, are determined, they should be used in 

identifying potential construction sites. Existing communities (e.g., infaunal, epifaunal, benthic, 

demersal, mid-water, surface-oriented) in the area where the artificial reef is to be placed should 
18

be considered prior to placement -- this should include monitoring to establish baselines for the 

fishing resources. 

Caution should be exercised when developing artificial reefs in nearshore areas due to the 

increased potential for resource competition as well as competition for niche space. Improperly 

sited reefs might enhance a recreational fish resource at the expense of other species or habitat; it 

may also alter the ecological balance of the area. For example, sandy estuarine habitat often 

provides critical nursery grounds for the juveniles of many species of bottom fish. During this 

life stage, the primary predator protection for these juvenile fish is the absence of large fish -- 

which are favored by recreational anglers. Oftentimes, sandy estuarine locations tend to be 

popular choices for siting artificial reefs to attract large fish for recreational fishing, thereby 

altering existing predatory/prey interactions and creating resource competition. Strategic project 

planning can minimize these conflicts. 

Artificial reefs should not be constructed such that they are placed on or threaten the integrity of 

natural habitats such as: 

• existing coral reefs; 

• significant beds of aquatic grasses or macroalgae; 

• oyster reefs; 

• scallop, mussel, or clam beds; 

• existing live bottom (i.e., marine areas supporting growth of sponges, sea fans, corals, 

and other sessile invertebrates generally associated with rock outcrops); or 

• habitats of Endangered Species Act listed species and species of State and local concern. 

The goals and priorities of an artificial reef project should direct overall site selection. Within 

the identified target area, existing natural and artificial reefs and known bottom obstructions 

should be identified. Exclusion areas for potential artificial reef projects should include, but are 

not limited to: 

• shipping lanes; 

• restricted military areas; 

• areas of poor water quality (e.g., low dissolved oxygen, dredged material disposal sites); 

• traditional trawling grounds; 

• unstable bottoms; 

• areas with extreme currents, or high wave energy; 
19

• existing right-of-ways (e.g., oil and gas pipelines and telecommunication cables); 

• sites for purposes that are incompatible with artificial reef development; and 

• areas designated as habitat areas of particular concern or special aquatic sites. 

 

The bottom composition and configuration at an artificial reef site affects reef stability and 

longevity and should be carefully evaluated in the site selection process. In most cases, soft 

sediments such as clays, silts, and loosely packed sands should be avoided. Over time, artificial 

reef materials may sink into these sediments or become partially covered. 

Project planners should evaluate vessel-to-reef projects and potential sites with regard to 

chemical and biological conditions as well as long-term durability and stability, as these will 

affect future habitat value. 

Coastal physical processes can greatly influence a potential artificial reef site. Artificial reef 

planners should be aware that bottom sediments shift and may change significantly during 

storms, hurricanes, and geologic events. Materials that present large amounts of surface area 

may scour deeply into almost any bottom type, depending upon storm events, currents, or wave 

action. 

The principal hydrographic factors to be considered in selecting sites for artificial reef placement 

include water depth, potential wave height, currents, and tides. Water depth is a significant 

siting criterion. Artificial reefs should be placed in water at sufficient depths to avoid creating a 

hazard to navigation – minimum clearance above the reef should accommodate the draft of the 

largest vessels expected to operate in the vicinity with an adequate safety margin. Water depth at 

the site may critically affect artificial reef material stability and long-term structural integrity. In 

large, open bodies of water, average wave energy as a function of water depth is the major 

concern. 
20

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21

Guidance for Preparing Vessels to Create Artificial Reef Habitat 

Photo courtesy of Laura S. Johnson

Worker sweeping debris during flight deck removal onboard the ex-USS Oriskany.
22

OIL AND FUEL 

Narrative Clean-up Goal: Remove liquid fuels and oils and semi-solids (greases) so 

that: no visible sheen is remaining on the tank surfaces (this includes all interior fittings, 

piping, structural members); no film or visible accumulation is remaining on any vessel 

structure or component (e.g., on machinery or from spills on decking or carpet). The end 

result of such clean-up should be that no sheen be visible upon sinking a vessel. 

 What are oil and fuel? 

For purposes of this guidance, the term oil includes crude oil; petroleum and petroleum-refined 

products (e.g., diesel fuel, gasoline, kerosene, and bunkers); and non-petroleum oils such as 

synthetic oils (e.g., silicone fluids), wood-derivative oils (e.g., resin/rosin oils), animal fats and 

oil, and edible and inedible seed oils from plants, which might be more relevant for cargo 

vessels. 

Some common refined petroleum products and their characteristics are as follows: 

• No. 2 Fuel Oil is a lightweight substance that flows easily, spreads rapidly, and 

disperses readily. It is neither volatile nor likely to form emulsions. 

• No. 4 Fuel Oil is a medium weight substance that flows easily and is readily 

dispersed if treated promptly. It has a low volatility and moderate flash point. 

• No. 5 Fuel Oil (Bunker B) is a medium to heavyweight substance with a low 

volatility and moderate flash point. Dispersion is very difficult and potentially 

impossible. 

• No. 6 Fuel Oil (Bunker C) is a thick substance that is difficult to pump and 

requires preheating for use. No. 6 fuel oil may be heavier than water. It is not 

likely to dissolve, and is likely to form tar balls, lumps, or emulsions. No. 6 fuel 

oil is very difficult or impossible to disperse. It has a low volatility and moderate 

flash point and is especially persistent in the environment. 

 What are the potential environmental impacts of oil and fuel? 

The impacts of fuel and/or oil introduced into the marine environment are influenced by a variety 

of factors, including the physical properties of the oil, whether the oil is petroleum-based or nonpetroleum-based, and the hydrodynamic properties of the receiving waters. Each type of oil has 

distinct physical properties that affect the way it disperses and breaks down, the hazard it may 

pose to ecosystems, and the likelihood that it will pose a threat to manmade resources. For 

example, the rate at which surface dispersion occurs will help to determine the effect of an oil 

spill on the environment. Most oils spread horizontally into a smooth and continuous layer, 

called a “slick,” on the water surface. 

Petroleum-based and non-petroleum-based oils can have both immediate and long-term adverse 
23

effects on the environment. These oils can be dangerous, or even deadly to wildlife. Light 

refined petroleum products, such as gasoline and kerosene, spread on water surfaces. The risk of 

fire and toxic exposure is high, but the products evaporate quickly and leave little residue. 

Alternatively, heavier petroleum-based refined oil products may pose lesser fire and toxic 

hazards and do not spread on water as readily. However, heavier oils are more persistent in the 

environment, and may present a greater clean-up challenge. 

Many non-petroleum oils have physical properties similar to those of petroleum-based oils. For 

example, they both have limited solubility in water, they both create slicks on the water surface, 

and they both form emulsions and sludge. However, non-petroleum oils tend to be persistent, 

remaining in the environment for long periods of time. 

Oil spills can harm the environment in several ways, including the physical damage that directly 

impacts wildlife and their habitats and the toxicity of the oil and its constituents, which can 

poison exposed organisms. Spilled oil in the environment immediately begins to disperse and 

degrade, with concomitant changes in physical and chemical properties. As these processes 

occur, the oil threatens natural resources, including birds and mammals as well as a wide range 

of marine organisms linked in a complex food web. Some organisms can be seriously injured 

(non-lethal effects) or killed (lethal effects) very soon after contact with the oil in a spill (acute 

effects); however, non-lethal toxic effects are often more subtle and often longer lasting (chronic 

effects). 

 

 Where are oils and fuels found in a ship? 

Diesel fuel and fuel oil may be contained in various tanks throughout a ship. For example, 

lubricating oil is found in engine sumps, drums of unused lubricating oil in ship storerooms or 

engineering spaces, and sludge in fuel and cargo tanks. Hydraulic systems and components also 

contain oils. 

The vessel’s piping and tank arrangements generally will contain some oil, fuel, sludge, and 

associated residues. Fuel oil may be found in both integrated and freestanding tanks throughout 

the ship. Lubricating oils may be found in a variety of tanks depending on their individual use. 

System oils are generally located in engine room sump tanks, while cylinder oils and lubrication 

oils will be stored in tanks dedicated for a specific purpose. Other types of fuels and oils may be 

contained in cargo tanks. 

“Used oil” -- any oil that has been refined from crude oil or any synthetic oil that has been used 

and, as a result of such use, is contaminated by physical or chemical impurities -- also may be 

found on ships. Used oil includes spent lubricating fluids that have been removed from engine 

crankcases, transmissions, and gearboxes; industrial oils such as compressor, turbine, and 

bearing oil; metal working oil; and refrigeration oil. 

Spills of fuels and oils may be found near cargo holds, ship store rooms, engineering spaces, and 

any other equipment that may house fuel and oil. 
24

 

 Photo courtesy of Laura S. Johnson

Flushed hydraulic system onboard the ex-USS Oriskany. 

How should the vessel be prepared; what are the appropriate BMPs for oil and fuel? 

The aim of clean-up is to remove liquid fuels, oils, and grease. Although it is impossible to 

remove all fuels, oils, and grease, a very thorough clean-up is achievable. In general, all liquid 

fuels and oils and semi-solids (greases) should be drained, flushed, and cleaned from fuel/lube 

and fluid system equipment (including piping, interior fittings, and structural members) so that 

no visible sheen remains on the tanks or other associated fluid system structures. The opening 

and cleaning of pipes varies according to the type of product that was in the lines. No visual 

evidence of weeping (oozing or releasing drops of liquid) should exist at openings. An 

alternative and very effective option for hydrocarbon clean-up is removal of the equipment and 

piping. Suggested cleaning methods for liquid fuels and oils, and semi-solids are found in 

Appendix G.

During vessel preparation, an economical way of managing used oil is recycling. It should be 

noted that additional used oil might be generated during the final preparation of the vessel prior 

to sinking (e.g., oil for generators). Such used oil and grease should be removed from the vessel 

before sinking. While the goal is to remove all oil and grease, it may be acceptable to leave old 

oil and grease in place if it is determined visually to be dried/solidified and therefore is not likely 

to cause a sheen. 

Fuel and Oil Tanks 

All fuels and lubricants should be drained from the tanks and the tanks flushed. Merely sealing 

tanks, whether as the sole means of fuel and oil tank preparation or in combination with partial 
25

tank draining, is insufficient. Over time, the integrity of the sealed tanks will eventually be 

compromised as marine growth density increases and the ship’s underlying structural 

components decay. The placement of the Liberty ship, Joseph L. Meek, sunk off Escambia 

County, Florida, in 1976, demonstrated that corrosion of the ship’s metal will eventually release 

residual fuel sealed in tanks into the environment. Although sealing the tanks without removing 

the contents is not sufficient for managing fuel and oil on a vessel intended to serve as an 

artificial reef, fuel/lube and fluid system equipment and piping intended to stay on the vessel 

should be sealed as necessary for the purpose of towing stability once the fuel/oil has been 

removed. Because these systems need to be opened during vessel preparation for draining and 

flushing the systems clean, sealing these systems may be necessary to help maintain vessel 

stability during transit to the designated artificial reef site. 

There are several accepted and widely used methods to clean fuel and oil tanks. The appropriate 

method will be determined by the type of fuel or oil in the tank, the amount of residue in the 

tank, and the extent of any hard or persistent deposits or residues. In general, lower quality fuels 

and heavy oils will require more cleaning effort. Similarly, tanks for dirty or water-contaminated 

oils will require more cleaning effort. 

 

When cleaning tanks, the following factors should be considered: worker access and safety 

issues, machinery and resources available, and the methods or facilities available to deal with the 

cleaning residues. It may be necessary to experiment with several cleaning methods to see which 

best suits the particular circumstance. 

Some methods for cleaning tanks are detailed in Appendix G. Regardless of the selected tank 

cleaning method, the effluent and water must be collected, treated, and disposed of in 

compliance with applicable regulations. Large volumes will require the services of a pumper 

truck or barge, while smaller quantities should be collected and stored in drums. Caution should 

be used during all transfer operations to avoid spills. If transferring large quantities of oil or oil 

contaminated liquid, a containment boom around the vessel should be used to minimize the 

extent or spreading of an accidental release.

Structural and Non-structural Tanks 

All structural and non-structural tanks are assumed to be contaminated by fuel or oil until proven 

otherwise. Structural tanks include, but are not limited to: fuel storage/settling/service/day 

tanks, cargo tanks, oil tanks, structural hydraulic tanks, fresh water tanks, ballast tanks, stabilizer 

tanks, black and gray water tanks, voids, and cofferdams. At a minimum, liquid fuels and oils in 

such tanks should be removed. 

Tank interiors including deckheads should be cleaned of all fuel and oil. No visible fuel and oil 

should remain on the tank surfaces (this includes all interior fittings, piping, structural members), 

or on the water surface when flooded after sinking. No emulsified oil, as determined by visual 

inspection, should remain. Oil absorbent pads and excess loose oil absorbent material should be 

removed before sinking. 

Gauges and Gauge Lines

Pressure gauges and gauge lines are assumed contaminated with the product that they were 

intended to measure. Fluid filled gauges should be removed. Pressure gauges and gauge lines 
26

should also be removed to prevent oil seepage from these lines. Lines that remain in place 

should be flushed, and the lines cleaned.

Special care should be exercised with mercury thermometers and pressure (typically vacuum) 

measuring devices. These should be removed intact from the vessel. A temperature gauge that 

does not contain any hazardous material can remain in its position. Other measuring instruments 

should be removed from the vessel or opened for cleaning, examination, and possible removal. 

Combustion Engines 

Combustion engines include any reciprocating engine in which fuel is consumed (diesel, 

gasoline, gases), stirling cycle engines, and gas turbines. The entire fuel/oil system should be 

drained and flushed. Any items (e.g., oil filters and strainer elements) that can not be flushed 

should be removed. 

Combustion engines and associated manifolds should be thoroughly drained, flushed, and 

cleaned. Machinery need not be removed if it is completely drained and the sumps flushed and 

cleaned. Sometimes, engines are removed for reuse or to assure that all oil is removed before 

reefing. In some cases, it might be less expensive to remove and dispose of the engines than to 

clean the oil from them. Some methods for cleaning combustion engines are detailed in 

Appendix E. 

Non-combustion Engines, Shafting, Gearing and Stern Seals 

Main gear boxes and associated clutches should be drained of all lubricating oils. Internal gear 

sprayers, lubricating lines, and other components should be removed, or drained. External 

pedestal and thrust bearings should be drained. 

Stern tubes and seals, if of the oil bath type, should be drained of oil. Note that draining the stern 

tubes and seals may require extraordinary measures to preserve the watertight integrity of the 

vessel during the clean-up and salvage operation. 

Vessels that are equipped with thrusters, Z-drives, or other unconventional propulsion systems 

will be addressed on a case-by-case basis. The objective is that no oil or fuel remains in the 

propulsion system. 

Steering Gear 

Hydraulic pumps and associated piping and fittings should either be removed or drained and 

flushed clean. Hydraulic telemotor systems should be treated similarly. Grease lines and 

reservoirs for rudder heads should be removed from the ship, or opened and cleaned. Vessels 

with combined propulsion and steering systems should be addressed as described in the previous 

subsection (“Non-combustion Engines, Shafting, Gearing, and Stern Seals”). 

Auxiliary Machinery 

Auxiliary machinery that has oil as its working fluid should be completely drained and flushed 

clean. Auxiliary machinery refers to machinery and components that are not an integral part of 

the main propulsion system of the vessel. The term can include but is not limited to: pumps, 

motors, compressors, galley equipment, capstans, elevators, and cargo handling machinery. 
27

Many pieces of auxiliary machinery have a lubricating oil system or are in direct contact with 

oil. 

All lubricating oil system components should be stripped from auxiliary machinery, drained and 

cleaned. Lubricating oil sumps should be drained and cleaned. 

Hydraulics 

All hydraulic systems should be assumed to have employed a petroleum- or synthetic-based fluid 

that needs to be cleaned. Hydraulic lines should be removed from the vessel, or opened and 

blown through with air until clear. Hydraulic fittings (valves and valve blocks of all types, 

cylinders, pumps, accumulators, filters, coolers) should be removed from the ship or drained 

clean. Hydraulic sumps should be opened and drained clean. 

Grease 

All grease reservoirs should be removed from the ship, or opened and cleaned. Grease lines 

should be removed or blown through until clear and all visible grease accumulations should be 

removed so that no visible sheen remains. Machinery that employs grease-packed gearboxes 

(common on deck machinery), as well as grease packed couplings, stuffing boxes, chain 

sprockets, and worm drives should be opened and cleaned of grease. Grease on chains and 

sprockets should be removed. Greased cables should be cleaned or removed from the vessel. 

Sealed rolling element bearings that contain grease can be left in-situ. Grease in other fittings 

such as stuffing boxes and glands can be left in situ if the seals are intact and the quantities are 

small (for example, less than 100 milliliters evenly distributed throughout the component). Any 

grease on the outside of the sealed bearings should be removed. 

Bilge Areas

The bilge area includes all areas that would be subject to contact with oily water, or may be a 

catch area for spills from cargo holds or storerooms, and interior surfaces which may have been 

subject to contamination through sprays, spills, or disposal. Bilge areas also include the plating 

and all surfaces of attached stiffeners and fittings. Bilge areas should be free of visible oils, 

greases, and sludge. Oil or grease films evident to the touch should be removed. All debris 

should be removed, particularly any debris contaminated with fuel, oil, or grease. Any cleaning 

fluids used to clean the bilge should be removed from the vessel. Accumulations of loose oil 

absorbent material should be limited to those amounts that cannot reasonably be picked up with 

brooms and vacuums. 
28

Photo courtesy of Laura S. Johnson

Oil absorbent pad in engine room bilge of the ex-USS Oriskany. 

Cleaning bilges is frequently complicated by poor access caused by piping, gratings, and 

equipment. In many cases, it is cheaper and easier to remove the dirty or contaminated items

that limit access than to clean the items as well as the bilge. Once clean, bilges are very 

vulnerable to recontamination. Note the following recontamination issues: 

• Piping, valves, and fittings in systems containing fuels, oils, or grease will continue to 

drip for some time after initial draining. Over a short period of time, these drips can 

necessitate a major rework cleaning effort. Therefore, drips should be captured whenever 

possible; drip pans should be emptied frequently. 

• Containers used for clean-up are vulnerable to tipping and spilling, especially in 

conditions -- such as poor lighting -- that are often found in vessels undergoing sinking 

preparation. Remove containers used for clean-up when they are full. 

• Water should not be allowed to enter bilges unless it is part of a planned clean-up effort. 

Water that otherwise enters the bilge should be handled as oily wastewater. 

In general, the approach and methods recommended for cleaning bilges are the same as for 

cleaning tanks. 

Decks and Floor Coverings

Oil and grease films on decks and floor coverings should be cleaned. Floor coverings include 

ceramic tile, linoleum and linoleum tile, carpet, and any other floor coverings. In compartments 

subject to fuel and oil spills during the vessel’s life (e.g., workshops, compartments with fuel or 

oil tank overflows or tank covers), the deck covering and underlayment should be examined for 

oil saturation. Floor coverings or underlayment that has been saturated with fuels, oils, or grease 

should be removed from the vessel. 
29

Bulkheads and Deckheads 

Bulkheads and deckheads should be cleaned of oil and grease films. Where it is evident that a 

spill or accumulation resulting from leaks has occurred, coverings should be removed to reveal 

the full extent of the spill or accumulation. 
30

ASBESTOS 

Narrative Clean-up Goal: Remove any loose asbestos and asbestos that may become 

loose during vessel sinking; remove or seal accessible friable asbestos. 

 What is asbestos?

Asbestos refers to a group of minerals that occur naturally as masses of long silky fibers. There 

are three main types of asbestos fibers:

• Chrysotile fibers (white asbestos) are fine, silky flexible white fibers. They are pliable 

and cylindrical, and arranged in bundles. This was the most commonly used asbestos in 

the United States. 

• Amosite fibers (brown asbestos) are straight, brittle fibers that are light grey to pale 

brown. This was the most commonly used asbestos in thermal system insulation. 

• Crocidolite fibers (blue asbestos) are straight blue fibers that are like tiny needles.

There are three other types of asbestos fibers: anthophyllite, tremolite, and actinolite. Unlike 

most minerals, which turn into dust particles when crushed, asbestos breaks up into fine fibers 

that may be too small to be seen by the human eye. 

Individual asbestos fibers are often mixed with a material that binds them together, forming what 

is commonly called asbestos-containing material (ACM). There are two kinds of ACM: friable 

and non-friable. 

• Friable ACM is any material containing more than 1% asbestos that, when dry, may be 

crumbled, pulverized, or reduced to powder by hand pressure. 

• Non-friable ACM is any material containing more than 1% asbestos that, when dry, 

cannot be crumbled, pulverized, or reduced to powder by hand pressure. Non-friable 

ACM is divided into two categories. 

1. Category I non-friable ACM includes asbestos-containing resilient floor 

coverings, packings, and gaskets.

2. Category II non-friable ACM includes all other non-friable ACM that is not 

included in Category I.

Asbestos is resistant to abrasion and corrosion, inert to acid and alkaline solutions, and stable at 

high temperatures. It is strong yet flexible, non-combustible, conducts electricity poorly, and is 

an effective thermal insulator.
31

 What are the potential environmental impacts of asbestos? 

Asbestos is a naturally occurring mineral. The environmental impacts caused by asbestos are 

dependent upon 1) whether asbestos is reduced to fibers or is in a non-friable form; and 2) 

whether the asbestos is air-borne or water-borne. 

Even though adverse impacts from asbestos are largely from inhalation -- which is not expected 

to be an issue in the marine environment -- vessel preparation should eliminate the possibility of 

pieces of asbestos breaking free from the vessel during the sinking operation or asbestos 

materials losing surface integrity after the vessel has been placed as an artificial reef. Loose 

asbestos pieces can lead to rafting and may be capable of washing ashore. These asbestos pieces 

could dry up, break apart, and be reintroduced into the atmosphere. Exposure to airborne 

asbestos can negatively impact human health via inhalation. 

Once a vessel has settled on the ocean floor, asbestos remaining on the vessel (e.g., intact and 

undisturbed asbestos insulation) will be covered with bacteria over time. This in turn will cause 

the asbestos fibers to sink and remain contained within the reef matrix, minimizing any potential 

direct impacts to the marine environment. (See Appendix C)

Where is asbestos found on a ship? 

Asbestos on ships may be found in many materials, including, but not limited to: 

• Bulkhead and pipe thermal insulation

• Bulkhead fire shields/fireproofing

• Uptake space insulation 

• Exhaust duct insulation

• Electrical cable materials 

• Brake linings 

• Floor tiles and deck underlay 

• Overhead and panel sheeting (cement and cellulose based)

• Steam, water, and vent flange gaskets 

• Adhesives and adhesive-like glues (e.g., mastics) and fillers

• Sound damping 

• Molded plastic products (e.g., switch handles, clutch facings)

• Sealing Putty 

• Packing in shafts and valves 

• Packing in electrical bulkhead penetrations

• Asbestos arc chutes in circuit breakers 

• Pipe hanger inserts 

• Weld shop protectors and burn covers, blankets, and any fire-fighting clothing or 

equipment

• Any other type of thermal insulating material 

NOTE: Asbestos-containing material may be found underneath materials that do not contain 
32

asbestos. Thermal system insulation and surfacing material found in vessels and vessel 

sections constructed after 1980 may be presumed to be free of asbestos-containing material. 

Photo courtesy of Laura Casey

Asbestos pipe wrapping on the ex-USS Oriskany. 

How should the vessel be prepared; what are the appropriate BMPs for asbestos? 

Asbestos can be found throughout ships, from the top of the bridge to the bilge. Identifying the 

locations and types of asbestos onboard early in the clean-up process is essential for vessel 

preparation and may involve qualified asbestos inspectors. Once the type and location of 

asbestos and asbestos-containing materials are identified, a determination should be made 

whether to remove, encapsulate, or leave the asbestos undisturbed. 

The method of demolition is particularly important to the effective management of asbestos on 

board ships. If the sinking method for the vessel includes the use of explosives, asbestoscontaining material that may become disturbed during detonation should be removed from the 

vessel. 

In addition, any asbestos that is moved or disturbed (including during clean-up operations) or can 

potentially get dislodged as the vessel sinks should be removed from the vessel. Friable asbestos 

should be sealed as a precautionary measure to prevent releases of asbestos in high 

concentrations during the sinking event. Intact and undisturbed asbestos insulation need not be 

removed. 

Engine Room and Engine Compartments

Removal or encapsulation of exposed, disturbed and deteriorated asbestos should be considered 

since it is likely that the asbestos will break free and create debris during sinking. If the asbestos 

is to be encapsulated, the encapsulation should be strong enough that its integrity will not be 

impacted by the preparation for sinking as well as the sinking itself. 
33

The primary source of friable asbestos is pipe wrappings around the main boilers and steam

fittings. On most vessels the asbestos coating, which is 1 to 3 inches thick, is covered with 

canvas and is usually painted. If work needs to be done around the piping and the covering, 

causing the asbestos to be disturbed, the disturbed material should be removed. If the covering is 

deteriorated and it is likely that the asbestos will break free during sinking, then removal or 

encapsulation with an epoxy or other non-water soluble and non-toxic sealer should be 

considered. Certain boilers and piping are covered with a very friable asbestos paste. If such 

friable asbestos is not covered with canvas and/or paint, the friable asbestos should be sealed or 

encapsulated with an epoxy or other non-water soluble and non-toxic sealer. 

Throughout the engine room there are 

numerous asbestos gaskets connecting 

piping and ductwork. If left intact, these 

gaskets usually will not release asbestos 

fibers. However, if the ductwork or 

piping needs to be cut or removed and 

vessel debris is created as a result, 

gaskets should be removed or 

encapsulated if possible. 

In some engine rooms asbestos/cellulose 

sheets are found behind power and 

electrical panels or in the overhead 

where electrical service passes. 

Undisturbed, this material is not friable. 

However, once the sheets are exposed to 

the marine environment, the sheets lose 

their integrity and can break up and raft. 

Where possible, these sheets should be 

removed. Note that asbestos cement 

sheets may also be used as panels on Photo courtesy of Laura S. Johnson

the vessel. However, these sheets are Patched asbestos pipe wrapping on the ex-USS Oriskany.

not water-soluble and therefore should 

not break apart when exposed to the 

marine environment. These sheets can stay in place unless cut, drilled or disturbed. Friable 

asbestos may also be found between bulkheads; this asbestos may remain in place because the 

asbestos is contained within the bulkheads. If, however, the bulkheads are drilled, cut, or 

disturbed, the friable asbestos that is now exposed should be encapsulated or removed. 

Ship Interior and Living Spaces

Asbestos was also used in some hatch gaskets mixed with rubber throughout ships, especially in 

watertight spaces. Under normal circumstances this will only present a problem if grinders or 

torches are used. In such cases, the gaskets should be removed prior to disturbance. 

Asbestos/asphalt floor tile was common from the 1940's to the mid-1970's. This form of 

asbestos is manufactured with the asbestos encapsulated. If preparation of the vessel requires the 

tile to be disturbed via grinding, cutting, or burning, those pieces of tile should be removed. 
34

Asbestos sheets both with cement and cellulose may be found especially in the combat 

information center, the radio room and other spaces where electrical equipment may be found. 

Cellulose/asbestos panels should be removed but cement panels are safe. As an example, while 

inspecting an old Navy tug planned for reefing off the coast of Virginia, it was determined that 

the entire interior of the wheel house was paneled with cellulose/asbestos panels and had to be 

removed. 

Exterior Spaces 

There are a few areas on the exterior of ships where asbestos was used. Asbestos may have been 

mixed with paint and applied as a coating near some vents and hatches. Also, some hatches may 

have gaskets that contain asbestos. In either case, the material does not need to be removed 

unless these exterior areas require grinding or cutting. 
35

POLYCHLORINATED BIPHENYLS (PCBs)

Narrative Clean-up Goal: Remove all manufactured products containing greater than or 

equal to (≥) 50 parts per million (ppm) of solid PCBs; remove all liquid PCBs regardless 

of concentration; remove all materials contaminated by PCB spills where the 

concentration of the original PCB source is ≥ 50 ppm. 

 What are PCBs? 

PCBs belong to a broad family of man-made organic chemicals known as chlorinated 

hydrocarbons. PCBs, which were domestically manufactured from 1929 until their manufacture 

was banned in 1979, have a range of toxicity and vary in consistency from thin, light-colored 

liquids to yellow or black waxy solids. Due to their non-flammability, chemical stability, high 

boiling point, and electrical insulating properties, PCBs were used in hundreds of industrial and 

commercial applications including electrical, heat transfer, and hydraulic equipment; as 

plasticizers in paints, plastics, and rubber products; in pigments, dyes, and carbonless copy 

paper; and many other industrial applications. 

What are the potential environmental impacts of PCBs? 

PCBs have been demonstrated to cause a variety of adverse health effects. PCBs have been 

shown to cause cancer in animals and have also been shown to cause a number of serious noncancer health effects in animals, 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 and non-carcinogenic effects of PCBs. The 

different health effects of PCBs may be interrelated, as alterations in one system may have 

significant implications for the other systems of the body. EPA’s peer reviewed cancer 

reassessment concluded that PCBs are probable human carcinogens. In addition, PCBs are 

persistent and bioaccumulative. PCBs bioaccumulate in fatty or lipid-rich tissues. PCBs have a 

limited solubility in aqueous solutions and PCBs can leach into a marine or aqueous environment 

(sediment and water column) where they can be taken up by organisms in the food web. PCBs 

bioaccumulate in fish and other animals; PCBs also bind to sediments. As a result, people who 

ingest fish may be exposed to PCBs that have been released into the environment and 

bioaccumulated in the fish they are ingesting. 

There is a risk of human exposure during vessel preparation and after sinking the vessel. During 

vessel preparation, typical routes of human exposure include inhalation, accidental ingestion, or 

dermal contact. After sinking, exposure routes may be limited to accidental ingestion of or 

contact with contaminated water and sediments, or ingestion of contaminated fish, shellfish, or 

crustaceans. (See Appendix C) 

 
36

Where are PCBs found on a ship?

Although no longer commercially produced in the United States, PCBs are most likely to be 

present in vessels deployed before the 1979 PCB ban. For such vessels, PCBs may be found in 

both the solid (waxy) and liquid (oily) forms in equipment and materials onboard ships. The 

equipment that may contain PCBs in concentrations of ≥ 50 ppm and the manufactured products 

containing ≥ 50 ppm of solid PCBs, include: 

Materials and items that could contain solid PCBs 

• Cable insulation 

• Rubber and felt gaskets 

• Thermal insulation material including fiberglass, felt, foam, and cork 

• Voltage regulators, switches, reclosers, bushings, and electromagnets 

• Electronic equipment, switchboards, and consoles 

• Adhesives and tapes 

• Oil-based paint 

• Caulking 

• Rubber isolation mounts 

• Foundation mounts 

• Pipe hangers 

• Plastics 

Materials and items that could contain liquid PCBs 

• Oil used in electrical equipment and motors, anchor windlasses, hydraulic systems, and 

leaks and spills from such items 

Materials and items that could contain either liquid or solid PCBs 

• Transformers, capacitors, and electronic equipment with capacitors and transformers 

inside 

• Fluorescent light ballasts 

• Surface contamination of machinery and other solid surfaces 

Items containing PCBs may be found throughout a ship and are not always easily identifiable or 

readily accessible. PCBs may be found in a variety of shipboard materials, but the location and 

concentration can vary from item to item and within classes of items. PCB-containing materials 

also are likely to vary from ship to ship, and even ships in the same class can contain differing 

types and amounts of PCB-containing materials. While these materials may be found throughout 

a ship, several areas on ships may have an increased likelihood of containing PCB-bearing 

materials: areas or rooms subject to high heat or fire situations such as boiler rooms, engine 

rooms, electrical/radio rooms, weapons storage areas, or areas with hydraulic equipment. Be 

aware that these pieces of equipment or systems are vulnerable to leaks and spills, which could 

leave spill residues behind and contaminate porous materials (e.g., carpet, wood, rubber/plastic 

mats, paint). 
37

 

 

Photo courtesy of Laura S. Johnson

Ex-USS Oriskany electronic equipment stripped of capacitors and transformers. 

How should the vessel be prepared; what are the appropriate BMPs for PCBs?

PCBs are regulated for disposal under 40 CFR Part 761, and will be discussed in this context. 

The PCB regulations require manufactured products containing ≥ 50 ppm of solid PCBs (PCB 

bulk product waste) and materials contaminated by spills of liquids containing PCBs (PCB 

remediation waste) to be properly disposed. Although the ship itself is being “reused” or 

“recycled” as an artificial reef, the PCBs must be properly disposed. Disposal requirements for 

each type of PCB waste are referenced below (also see Appendix B). 

Where there is reason to suspect that equipment or manufactured products containing solid PCBs

may contain PCBs ≥ 50 ppm, either remove the equipment or component from the vessel, or 

provide proof that the equipment or component is free of PCBs, unless a PCB bulk product waste 

disposal approval has been obtained under 40 CFR 761.62(c) (see below). 

Under TSCA regulations, a spill of liquids containing PCBs ≥ 50 ppm is considered an illegal 

disposal of PCBs. Material(s) contaminated by such a spill must be cleaned or removed and 

disposed of, unless a risk-based disposal approval has been obtained under 40 CFR 761.61(c). 

Spill residues and materials contaminated by these spills are regulated differently than bulk 

product waste (see below). 

The design and implementation of a representative sampling and analytical plan can help 

determine the presence or absence of PCBs in materials containing solid PCBs at ≥ 50 ppm or 

materials containing PCBs as the result of spills. If the data from the sampling and analytical 
38

plan indicates the absence of PCBs, the ship and its components are not subject to the PCB 

provisions of TSCA. 

Liquid Materials Manufactured with PCBs 

Remove all liquid-filled electrical equipment suspected of containing PCBs or PCBcontaminated dielectric fluid, regardless of PCB concentration. Materials such as lubricating oils 

and greases used for winches and cargo-handling machinery, hydraulic fluids, heat transfer 

fluids, and waste oils should be removed from the vessel in accordance with the guidance in the 

“Oil and Fuel” section of this document. 

Photo courtesy of Laura Casey

Engine room electrical cabling on the ex-USS Oriskany. 

Manufactured Products Containing Solid PCBs 

Remove all manufactured products containing ≥ 50 ppm of solid PCBs, which includes, but is 

not limited to, felt gasket and faying material, cables, paints, rubber gaskets, as well as battle 

lanterns and fluorescent light ballasts. 

Thermally removing PCB-containing materials is generally not authorized without prior written 

approval. Because PCB sampling and analytical procedures can be expensive and time 

consuming, there may be situations when the cost of sampling and analysis far exceeds the cost 

for removal and disposal. In some cases, vessel-to-reef projects have shown that removal of all 

electrical cables and wires suspected of containing PCBs was the most economical course of 

action. 
39

 

While the complete removal of all manufactured products containing ≥ 50 ppm of solid PCBs is 

recommended, EPA recognizes that in some vessels it may not be feasible to identify and remove 

every such item. If such materials cannot be feasibly identified and/or removed, an application 

to EPA for a risk-based approval to dispose of the PCB bulk product waste in a marine 

environment for purposes of creating an artificial reef is required pursuant to 40 CFR 761.62(c). 

(EPA’s decision includes consideration of a risk assessment submitted by the applicant, and a 

public participation process. Please consult the responsible EPA office for more information.)3

 

Materials Containing PCBs as a Result of Spills 

Remove all materials containing ≥ 50 ppm of PCBs due to PCB spills. In addition, depending on 

the concentration of the spilled PCBs and the date when the spill occurred, it may be necessary to 

remove materials currently containing less than 50 ppm of PCBs due to spills.4

 If it is not known 

when a spill occurred, you should generally assume that it occurred after July 1, 1979. 

During vessel clean-up/preparation, attention should be directed to locations on the ship that are 

known to house equipment and systems that typically contain PCB liquids. Because such 

equipment or systems are vulnerable to leaks and spills during the lifetime of the vessel, the 

areas surrounding the equipment or systems are likely contaminated by liquids containing PCBs. 

If there is no information regarding whether a spill occurred and/or the PCB concentration of any 

spilled liquid, design and implement a representative sampling plan to verify that there are no 

PCBs present in the areas surrounding the liquid-filled equipment or systems. If the sampling 

results indicate presence of PCBs as a result of a spill of liquids containing PCBs, remove the 

spill residue and the materials contaminated by the spill (e.g., remove paint from a contaminated 

surface such as a metal deck, strip the contaminated area down to bare metal in accordance with 

40 CFR 761.79(b)(i)(B)). If spill residues or materials contaminated by PCB spills cannot be 

feasibly removed, an application to EPA for a risk-based approval to dispose of the PCBs in a 

marine environment for purposes of creating an artificial reef is required pursuant to 40 CFR 

761.61(c). (EPA’s decision includes consideration of a risk assessment submitted by the 

applicant, and a public participation process. Please consult the responsible EPA office for more 

information (see footnote # 3).)

3 Any vessel owner and/or sponsor should carefully consider the amount of time, resources and financial 

commitments necessary to address the identification, removal, and disposal of non-liquid PCB-containing materials 

and materials contaminated by spills of liquids containing PCBs before finally deciding if a vessel is suitable for 

reefing, and well in advance of commencing clean-up. EPA strongly recommends vessel owners and/or sponsors to 

begin discussions as soon as possible with the PCB coordinator for the EPA Region in which the vessel is proposed 

to be sunk. A list of EPA’s current PCB coordinators may be found at www.epa.gov/pcb/coordin.html. 

4

 For PCB spills that occurred between April 18, 1978, and July 1, 1979, and where the original source was ≥ 500 

ppm PCBs, remove all materials containing any concentration of PCBs. For PCB spills that occurred after July 1, 

1979, and where the original source was ≥ 50 ppm PCBs, remove all materials containing any concentration of 

PCBs. Remove all materials currently containing ≥ 50 ppm PCBs as a result of spills (of any concentration) that 

occurred prior to April 18, 1978. Consult the PCB regulations at 40 CFR 761.3, 761.50(b)(3) and 761.61. 
40

PAINT 

Narrative Clean-up Goal: Remove harmful exterior hull anti-fouling systems that are 

determined to be active; remove exfoliating (peeling) and exfoliated paint.

 

What types of paint and anti-fouling systems are used on ships, and where are they 

found? 

Paint and preservative coatings can be found on both interior and exterior surfaces of a ship. 

Particularly on older ships, paint may be flammable or may contain toxic compounds, such as 

polychlorinated biphenyls (PCBs), heavy metals (e.g., lead, barium, cadmium, chromium, and 

zinc), and biocides. Lead compounds, such as red lead tetraoxide (Pb3O4) and lead chromate, 

have been used extensively in marine paint. Other paints containing biocides, such as organotin 

(including compounds such as tributyl tin), have been used on the hulls of ships to prevent the 

buildup of marine organisms (e.g., bacteria, protozoa, barnacles, and algae). 

Paints 

Paint above the water line (topside paint) is not designed to leach because these paints are 

designed to protect topside surfaces from physical degradation and do not typically contain 

antifoulant biocides like that of anti-fouling coatings. However, these paints may contain added 

biocides. 

Anti-fouling System 

For most types of candidate vessels for reefing, the paint-related contaminants of concern are 

limited to exterior hull coatings below the water line. These hull coatings consist primarily of

anti-fouling (AF) agents (biocides) such as copper, organotin compounds, and zinc. 

 

 

Photo courtesy of Laura S. Johnson

Exfoliating ceiling paint on the ex-USS Oriskany before being cleaned. 
41

What are the potential environmental impacts of paints? 

Scientific investigations by governments and international organizations have shown that certain 

anti-fouling systems (AFS) used on vessels pose a substantial risk of both acute and chronic 

toxicity and other adverse impacts to ecologically and economically important non-target marine 

organisms. Because this document 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. (See Appendix C) 

 How should the vessel be prepared; what are the appropriate BMPs for paints? 

Anti-fouling Underwater Hull Coatings 

If there is minimal active biocide remaining on the vessel, no preparation to the underwater hull 

area is necessary. It can be assumed that biocide activity is minimal if the anti-fouling coating 

on a candidate vessel is more than twelve years old and essentially all the underwater hull area is 

covered with marine growth. 

When assessing the efficacy of the anti-fouling system, existing documentation relating to the 

anti-fouling properties of the hull coating could provide supporting information when 

determining if such coatings should be removed. Sources of such supporting information 

include, but are not limited to, any documentation related to the following: the type and age of 

the existing AFS, the most recent repainting or dry-dock cycle, and the most recent underwater 

hull cleaning. When necessary, such information may be supplemented by a physical, 

underwater hull examination by trained divers or remote operating vehicles. Repair and 

maintenance records for the vessel should provide the dates when the vessel was last removed 

from the water for hull maintenance. 

If anti-fouling coatings on candidate vessels are at least twelve years old and essentially all the 

underwater hull area is covered with marine growth, the AF coatings can be left in place without 

further evaluation, as they are no longer likely to be harmful. If satisfactory evidence relating to 

underwater hull coating types and coating application dates is not available, and if the AF 

coating seems to be inhibiting fouling growth according to established AF paint efficacy, further 

evaluations should be carried out to ascertain the current anti-fouling properties of the coating. 

If it is determined that the AFS is active, the system should be removed to prevent the release of 

the AFS’s harmful biocides. 

Interior and Exterior, Above the Waterline Paints 

In some cases, interior and exterior paints onboard vessels may contribute to debris/floatable 

materials or contain other contaminants of concern. Interior paint and paint above the waterline 

should be evaluated according to the guidance presented under the “PCB” and 

“Solids/Debris/Floatables” sections when appropriate. If paint is found to contain PCBs, then 

the protocols found in the “PCB” section of this document should be followed. 
42

Removal of intact paints generally is not necessary. Topside paint may contain other 

constituents, such as trace metals or biocides. Unlike underwater hull paint containing high 

concentrations of biocides designed to leach rapidly, topside paints are designed for long life. 

They also may contain significantly lower levels of these substances than hull coatings. 

However, exfoliating paint (paint that is blistering, peeling, and pitting) and exfoliated paint 

(paint chips and flakes) should be removed. 
43

SOLIDS/DEBRIS/FLOATABLES 

Narrative Clean-up Goal: Remove loose debris, including materials or equipment not 

permanently attached to the vessel, which could be transported into the water column 

during a sinking event. 

What are solids/debris/floatables? 

Solids, debris, and floatables are loose materials that could break free from the vessel during 

transportation and placement as an artificial reef, thereby adversely affecting the ecological or

aesthetic value of the marine 

environment or posing a risk to 

humans or animals. These materials 

can consist of vessel debris and 

clean-up debris. Vessel debris refers 

to material that was once part of the 

vessel or was generated during vessel 

clean-up operations and has been 

removed or disconnected from its 

original location on the vessel. 

Clean-up related debris is material 

that was not a part of the vessel, but 

rather was brought on the vessel 

during preparation operations. 

What are the potential 

environmental impacts 

of solids, debris, and 

floatables? 

Marine debris consists of solid 

materials of human origin discarded 

at sea. Floatable material/debris is 

any unsecured foreign matter that 

floats, remains suspended in the 

water column, or washes up on 

shore. Floatable materials can Photo courtesy of Laura S. Johnson

Solids, debris, floatables, and exfoliating paint on a vessel of 

the MARAD James River Reserve Fleet. travel long distances in the ocean 

and be deposited far from their 

source. The degradability of 

floatable materials and marine debris 

influences the persistence of these items in the marine environment. Most marine debris does 

not biodegrade readily. The longer that introduced materials remain in the marine environment, 

the greater the threat they pose to the environment. 
44

Some potential impacts of solids/debris/floatables to the marine environment include: 

• Marine life is endangered by entanglement, ingestion, or both; injury, infection, and death 

may often occur when marine animals encounter debris of this nature. For example, 

floating debris may act as an attractant for marine animals that would try to use it as 

shelter or a food source, thereby potentially causing injury or death and altering behavior 

and/or distribution of indigenous species; 

• Alteration of the ecosystem and its processes may occur throughout the water column as 

a result of debris introduced into the marine environment. Debris settling on the bottom 

may change benthic floral and faunal habitat structure, potentially causing a direct 

deleterious impact on members of the benthic community (i.e., injury or mortality) or 

indirect impact to other species linked in the benthic food web; 

• Recurring clean-up for coastal communities impacted by the debris -- which could be 

costly; and 

• Increasing the risk of spills and other environmental impacts resulting from potential 

danger to navigation (e.g., hull damage, damage to propellers, and damage to cooling and 

propulsion systems). 

 Where are solids/debris/floatables found on ships? 

Solids, debris, and floatables can be found anywhere within the vessel as well as on the decks. 

How should the vessel be prepared; what are the appropriate BMPs for 

solids/debris/floatables? 

Vessel Debris 

All material or equipment that is not an integral part of a permanently attached appurtenance and 

that could become separated from the vessel during sinking should be removed from the ship 

prior to sinking. Ship’s surfaces (e.g., decks, bulkheads, overheads, and surfaces of 

appurtenances) should be thoroughly cleaned to remove all dirt, loose scale, trash, exfoliating 

paint, paint chips, hazardous materials, and other foreign matter (including netting material). 

Deck drains should be proven clear of debris. Consideration should also be given to the removal 

of items that could become a floatable over time (e.g., floatable fiberglass insulation, floatable 

foam). 

When assessing vessel debris removal, consideration should be given to the following: 

• no vessel debris contaminated with hydrocarbons or hazardous material should 

remain in the vessel; 

• vessel debris that is heavy and/or bulky fitted equipment, and was disconnected or 

otherwise detached from the structure of the vessel for cleaning or inspection can 
45

remain in its original compartment subject to issues of diver safety. Otherwise, 

vessel debris should be contained in a sealed compartment or structural tank that 

is below the waterline of the ship and underneath the largest section of the 

superstructure; 

• vessel debris should not be placed in a compartment or structural tank that will be 

sealed until both the compartment and the debris have been inspected; and 

• vessel debris remaining on the vessel should always be negatively buoyant. 

Any vessel debris determined to be acceptable to remain on the vessel for sinking should be 

cleaned as understood in the context of this guidance. 

Clean-up Related Debris 

Clean-up debris that was introduced to the vessel solely for cleaning purposes and final 

preparation of the vessel should always be removed. This would include items such as tools, 

generators, warning tape, and temporary wooden covers. 

Introduced Debris

Foreign material should not be placed on the vessel solely for disposal. However, material 

needed for the reefing operation (e.g., clean concrete or rock for ballast) or of a commemorative 

nature (e.g., plaques and markers) is not considered debris for the purposes this document. 
46

OTHER MATERIALS OF ENVIRONMENTAL CONCERN 

Narrative Clean-up Goal: Remove other materials that may negatively impact the 

biological, physical, or chemical characteristics of the marine environment. 

 What are other materials of environmental concern? 

Refer to the list provided below.

What are the potential environmental impacts of other materials of environmental 

concern? 

When placed in the marine environment, materials of environmental concern can have adverse 

effects on fish, wildlife, shellfish, recreation, or municipal water supplies. Adverse effects on the 

environment include any of the impacts mentioned in the preceding sections of the document. 

The magnitude of the impact of these materials on the marine environment will be related to the 

nature of the material, the level of toxicity, and the ecological resources that could come in 

contact with “other material of environmental concern.” 

 

 Where are other materials of environmental concern found on ships? 

Other materials of environmental concern can be found anywhere within the vessel as well as on 

the decks. 

How should the vessel be prepared; what are the appropriate BMPs for other materials 

of environmental concern? 

Shipboard equipment or materials with constituents that can leach into the water column (e.g., 

petroleum products, batteries, and/or mercury-containing switches) should be removed from the 

vessel prior to sinking. Fluorescent light tubes and ballasts should be removed. Waste water 

resulting from clean-up processes, including but not limited to, decontamination, contaminated 

rain water, and water from rinsing of tanks and lines, should be properly collected and disposed. 

Antifreeze and Coolants 

Antifreeze and coolant mediums, other than untreated sea water, should be drained and removed 

from the vessel, and the equipment should be flushed. 

Batteries 

All batteries should be removed from the vessel. This includes batteries that are part of fitted 

equipment. 
47

Fire Extinguishing Systems

Fire extinguishing systems should be fully decommissioned. Except for fire-fighting systems 

that employ untreated seawater or fresh water, all fire-fighting compounds should be removed 

from the ship. Storage containers, if left in situ, should be cleaned, flushed, and re-closed for 

transit. Any lines that have been charged with any fire-fighting product other than untreated 

seawater or fresh water should be treated in the same manner as fuel lines and oil piping. 

Refrigerants and Halons 

All refrigerants and halons should be removed from the vessel. 

Mercury 

Ship system components using mercury (e.g., some gyroscopes, vacuum measurement gauges, 

some laboratory equipment, some light switches, some older radar displays) should be removed 

from the vessel. All portable thermometers and other measuring equipment employing mercury 

should be removed intact from the vessel. Any other extant mercury or items containing 

mercury should be removed from the vessel. Even minute quantities of mercury may be of 

concern and should be removed. Note that there is a health hazard associated with airborne 

mercury. 

Photo courtesy of Laura Casey

Mercury removed from smoke detector onboard the ex-USS Oriskany. 

Lead

Lead ballast bars, shielding and fittings should be removed from the vessel if the reef site is 

located in fresh or brackish water. 
48

Black and Gray Water

Remove black water (sewerage) and gray water (waste water from sinks, showers, galleys, 

dishwashers) from the vessel; flush the lines. 

Radioactive Materials 

Ex-warships, research vessels, and a few other types of vessels may have used equipment 

containing low-level radioactive material. Residual radioactivity and any source of non-naturally 

occurring radioactive materials such as luminescent devices should be removed (except where it 

may safely be left on the ship in accordance with the references below). The Navy is more 

familiar with addressing this material generally aboard vessels, and as such, the Navy has 

guidance and established procedures regarding the removal and disposal of radioactive materials. 

For this reason, it is recommended that the procedures for removal and disposal of radioactive 

materials follow that provided in DLA INST 4145.8, "Material Management for Radioactive 

Items in the DoD" and implementing instructions. Another reference that may be useful is the 

American National Standard Institute’s standard N13.12-1999, “Surface and Volumetric 

Radioactivity Standards for Clearance.” This document contains tables of surface contamination 

criteria developed to allow users of radioactive material to demonstrate that the material or 

equipment can be safely released with no further regulatory control. 

Invasive Species 

Assess the presence of invasive species that could be transported to and survive at the artificial 

reef location on the hull of the ship or from other locations on or in the vessel such as ballast and 

bilge tanks. If a viable invasive species is found that may be expected to survive at the artificial 

reef site, that species should be removed or eliminated; the vessel should be clean of all such 

living organisms. 
49

Considerations for Other In-water Uses of Obsolete Vessels 

Photo courtesy of Florida Fish and Wildlife Conservation Commission

Diver exploring the ex-USS Spiegel Grove artificial reef. 
50

DIVING OPPORTUNITIES 

The narrative goals set out under the section “Guidance for Preparing Vessels to Create Artificial 

Reef Habitat” also should be achieved while preparing a vessel for diver opportunities. For 

example, if preparation for diver use calls for the removal of wall paneling that will in turn 

expose any materials of concern that were identified in the aforementioned section, the 

respective narrative goals should be addressed (e.g., if asbestos is exposed once the panel is 

removed, the objectives of the asbestos narrative goal should be met). 

Additional vessel preparation to support the in-water use of recreational diving may include: 

• Removal of sharp and protruding objects along the divers' access path which could snag 

on divers' equipment or otherwise pose a danger to the divers. 

• Removal of doors and access hatches and widening of openings to allow safe access for 

divers. 

• Widening of corridors by removal of some wall paneling and provision of large openings 

in the exterior of the ship to allow light to penetrate and help ensure safe diver access. 

• Sealing entrances into restrictive compartments such as the boiler rooms and engine 

rooms to help ensure diver safety. 

When preparing the vessel for diver opportunities, careful consideration also should be given to 

vessel stability (for transport and sinking operations) as well as vessel integrity (for the life of the 

vessel once placed at the reef site). 
51

Appendix A

Federal Statutes Related to the Transfer of Obsolete MARAD and Navy 

Vessels for Use as Artificial Reefs 

National Defense Authorization Act for Fiscal Year 2004 

The National Defense Authorization Act for Fiscal Year 2004 (PL 108-136) included two 

provisions relating to the use of vessels as artificial reefs. One such provision, § 3516 (PL 108-

136, Div. C, Title XXXV, § 3516, Nov. 24, 2003, 117 Stat. 1795), amended the Bob Stump 

National Defense Authorization Act for Fiscal Year 2003 (PL 107-314, Div. C, Title XXXV, § 

3504(b), Dec. 2, 2002, 116 Stat. 2754; 16 U.S.C. 1220 note) to read in pertinent part as follows: 

 Title XXXV – Maritime Administration 

 Subtitle A – Maritime Administration Reauthorization 

 Section 3516. AUTHORITY TO CONVEY OBSOLETE VESSELS 

 TO UNITED STATES, TERRITORIES, AND FOREIGN 

 COUNTRIES FOR REEFING 

 

 (b) Environmental Best Management Practices for Preparing Vessels for Use 

as Artificial Reefs.— 

 (1) Not later than March 31, 2004, the Secretary of Transportation, acting 

through the Maritime Administration, and the Administrator of the Environmental 

Protection Agency shall jointly develop guidance recommending environmental best 

management practices to be used in the preparation of vessels for use as artificial 

reefs. 

 (2) The guidance recommending environmental best management practices 

under paragraph (1) shall be developed in consultation with the heads of other federal 

agencies, and State agencies, having an interest in the use of vessels as artificial reefs. 

 

 (3) The environmental best management practices under paragraph (1) 

shall -- 

 (A) include recommended practices for the preparation of vessels for use as 

artificial reefs to ensure that vessels so prepared will be environmentally sound 

in their use as artificial reefs; 

 (B) promote consistent use of such practices nationwide; 

 (C) provide a basis for estimating the costs associated with the preparation of 

vessels for use as artificial reefs; and 

 (D) include mechanisms to enhance the utility of the Artificial Reefing 

Program of the Maritime Administration as an option for the disposal of 

obsolete vessels. 

 (4) The environmental best management practices developed under 

paragraph (1) shall serve as national guidance for federal agencies for the preparation 

of vessels for use as artificial reefs. 
52

 (5) Not later than March 31, 2004, the Secretary of Transportation, acting 

through the Maritime Administration, and the Administrator of the Environmental 

Protection Agency shall jointly establish an application process for governments of 

States, commonwealths, and United States territories and possessions, and foreign 

governments, for the preparation of vessels for use as artificial reefs, including 

documentation and certification requirements for that application process. 

 (6) The Secretary of Transportation shall submit to Congress a report on the 

environmental best management practices developed under paragraph (1) through the 

existing ship disposal reporting requirements in section 3502 of Floyd D. Spence 

National Defense Authorization Act for Fiscal Year 2001 (as enacted into law by 

Public Law 106-398; 1654A-492) [Pub.L. 106-398, Div. C, Title XXXV, § 3502, Oct. 

30, 2000, 114 Stat. 1654A-492, which is not classified to the Code]. The report shall 

describe such practices, and may include such other matters as the Secretary considers 

appropriate. 

The second such provision, § 1013 (PL 108-136, Div. A, Title X, § 1013, Nov. 24, 2003, 117 

Stat. 1590), amended Title 10 of the United States Code by adding § 7306b. New § 7306b(a) 

authorizes the Secretary of the Navy to transfer vessels stricken from the Naval Vessel Register 

for use as an artificial reef. New § 7306b(c) requires the Secretary of the Navy to ensure that the 

preparation of a vessel transferred pursuant to 10 U.S.C. § 7306b(a) for use as an artificial reef is 

conducted in accordance with the environmental best management practices developed pursuant 

to 16 U.S.C. § 1220 note and applicable environmental laws. The complete text of Section 1013 

of the National Defense Authorization Act for Fiscal Year 2004 is as follows: 

 Title X – General Provisions 

 Subtitle B – Naval Vessels and Shipyards 

 Section 1013. TRANSFER OF VESELS STRICKEN FROM THE 

 NAVAL VESSEL REGISTER FOR USE AS ARTIFICIAL REEFS. 

 

(a) AUTHORITY TO MAKE TRANSFER- Chapter 633 of title 10, United States 

Code, is amended by inserting after section 7306a the following new section: 

`Sec. 7306b. Vessels stricken from Naval Vessel Register: transfer by gift or 

otherwise for use as artificial reefs 

`(a) AUTHORITY TO MAKE TRANSFER- The Secretary of the Navy may 

transfer, by gift or otherwise, any vessel stricken from the Naval Vessel Register 

to any State, Commonwealth, or possession of the United States, or any municipal 

corporation or political subdivision thereof, for use as provided in subsection (b). 

`(b) VESSEL TO BE USED AS ARTIFICIAL REEF- An agreement for the 

transfer of a vessel under subsection (a) shall require that-- 

`(1) the recipient use, site, construct, monitor, and manage the vessel only 

as an artificial reef in accordance with the requirements of the National 
53

Fishing Enhancement Act of 1984 (33 U.S.C. 2101 et seq.), except that the 

recipient may use the artificial reef to enhance diving opportunities if that 

use does not have an adverse effect on fishery resources (as that term is 

defined in section 2(14) of the Magnuson-Stevens Fishery Conservation 

and Management Act (16 U.S.C. 1802(14)); and 

`(2) the recipient obtain, and bear all responsibility for complying with, 

applicable federal, State, interstate, and local permits for using, siting, 

constructing, monitoring, and managing the vessel as an artificial reef. 

`(c) PREPARATION OF VESSEL FOR USE AS ARTIFICIAL REEF- The 

Secretary shall ensure that the preparation of a vessel transferred under subsection 

(a) for use as an artificial reef is conducted in accordance with-- 

`(1) the environmental best management practices developed pursuant to 

section 3504(b) of the Bob Stump National Defense Authorization Act for 

Fiscal Year 2003 (Public Law 107-314; 16 U.S.C. 1220 note); and 

`(2) any applicable environmental laws. 

`(d) COST SHARING- The Secretary may share with the recipient of a vessel 

transferred under subsection (a) any costs associated with transferring the vessel 

under that subsection, including costs of the preparation of the vessel under 

subsection (c). 

`(e) NO LIMITATION ON NUMBER OF VESSELS TRANSFERABLE TO 

PARTICULAR RECIPIENT- A State, Commonwealth, or possession of the 

United States, or any municipal corporation or political subdivision thereof, may 

be the recipient of more than one vessel transferred under subsection (a). 

`(f) ADDITIONAL TERMS AND CONDITIONS- The Secretary may require 

such additional terms and conditions in connection with a transfer authorized by 

subsection (a) as the Secretary considers appropriate. 

`(g) CONSTRUCTION- Nothing in this section shall be construed to establish a 

preference for the use as artificial reefs of vessels stricken from the Naval Vessel 

Register in lieu of other authorized uses of such vessels, including the domestic 

scrapping of such vessels, or other disposals of such vessels, under this chapter or 

other applicable authority.'. 

(b) CLERICAL AMENDMENT- The table of sections at the beginning of such 

chapter is amended by inserting after the item relating to section 7306a the following 

new item: 

 `7306b. Vessels stricken from Naval Vessel Register: transfer by gift or 

 otherwise for use as artificial reefs.'. 
54

Transfer of Obsolete Vessels by the Department of Transportation 

Public Law 92-402 (16 U.S.C. 1220, et. seq.) authorizes the U.S. Maritime Administration 

(MARAD), under the Department of Transportation, to transfer obsolete ships to any state for 

use as an artificial reef. In addition, MARAD’s authority was amended by Public Law 107-314 

section 3504, as amended by Public Law 108-136, to allow MARAD to provide financial 

assistance to states for environmental preparation, towing, and/or sinking and also allows 

MARAD to transfer obsolete vessels to U.S. territories and foreign countries for use as artificial 

reefs. 

 Title XXVI – Conservation 

 Chapter 25B – Reefs for Marine Life Conservation 

 

§ 1220. State applications for obsolete ships for use as offshore reefs

(a) Conservation of marine life 

Any State may apply to the Secretary of Transportation (hereafter referred to in this 

chapter as the "Secretary") for obsolete ships which, but for the operation of this 

chapter, would be designated by the Secretary for scrapping if the State intends to sink 

such ships for use as an offshore artificial reef for the conservation of marine life. 

(b) Manner and form of applications; minimum requirements 

A State shall apply for obsolete ships under this chapter in such manner and form as 

the Secretary shall prescribe, but such application shall include at least (1) the location 

at which the State proposes to sink the ships, (2) a certificate from the Administrator, 

Environmental Protection Agency, that the proposed use of the particular vessel or 

vessels requested by the State will be compatible with water quality standards and 

other appropriate environmental protection requirements, and (3) statements and 

estimates with respect to the conservation goals which are sought to be achieved by 

use of the ships. 

(c) Copies to federal officers for official comments and views 

Before taking any action with respect to an application submitted under this chapter, 

the Secretary shall provide copies of the application to the Secretary of the Interior, 

the Secretary of Defense, and any other appropriate federal officer, and shall consider 

comments and views of such officers with respect to the application. 

§ 1220a. Transfer of title; terms and conditions

If, after consideration of such comments and views as are received pursuant to section 

1220(c) of this title, the Secretary finds that the use of obsolete ships proposed by a 

State will not violate any federal law, contribute to degradation of the marine 

environment, create undue interference with commercial fishing or navigation, and is 

not frivolous, he may transfer without consideration to the State all right, title, and 
55

interest of the United States in and to any obsolete ships which are available for 

transfer under this chapter if-- 

(1) the State gives to the Secretary such assurances as he deems necessary that such 

ships will be utilized and maintained only for the purposes stated in the application 

and, when sunk, will be charted and marked as a hazard to navigation; 

(2) the State agrees to secure any licenses or permits which may be required under the 

provisions of any other applicable federal law; 

(3) the State agrees to such other terms and conditions as the Secretary shall require in 

order to protect the marine environment and other interests of the United States; and 

(4) the transfer would be at no cost to the Government (except for any financial 

assistance provided under section 1220(c)(1) of this title) with the State taking 

delivery of such obsolete ships and titles in an "as-is-- where-is" condition at such 

place and time designated as may be determined by the Secretary of Transportation. 

§ 1220b. Obsolete ships available; number; equitable administration

A State may apply for more than one obsolete ship under this chapter. The Secretary 

shall, however, taking into account the number of obsolete ships which may be or 

become available for transfer under this chapter, administer this chapter in an 

equitable manner with respect to the various States. 

§ 1220c. Denial of applications; finality of decision

A decision by the Secretary denying any application for a obsolete ship under this 

chapter is final. 

§ 1220c-1. Financial assistance to State to prepare transferred ship

(a) Assistance authorized 

The Secretary, subject to the availability of appropriations, may provide, to any State 

to which an obsolete ship is transferred under this chapter, financial assistance to 

prepare the ship for use as an artificial reef, including for-- 

(1) environmental remediation; 

(2) towing; and 

(3) sinking. 

(b) Amount of assistance 

The Secretary shall determine the amount of assistance under this section with respect 

to an obsolete ship based on— 

(1) the total amount available for providing assistance under this section; 

(2) the benefit achieved by providing assistance for that ship; and 

(3) the cost effectiveness of disposing of the ship by transfer under this chapter and 

provision of assistance under this section, compared to other disposal options for that 

ship. 
56

(c) Terms and conditions 

The Secretary-- 

(1) shall require a State seeking assistance under this section to provide cost data and 

other information determined by the Secretary to be necessary to justify and document 

the assistance; and 

(2) may require a State receiving such assistance to comply with terms and conditions 

necessary to protect the environment and the interests of the United States. 

§ 1220d. "Obsolete ship" defined 

For purposes of sections 1220, 1220a, 1220b, and 1220c of this title, the term 

"obsolete ship" means any vessel owned by the Department of Transportation that has 

been determined to be of insufficient value for commercial or national defense 

purposes to warrant its maintenance and preservation in the national defense reserve 

fleet and has been designated as an artificial reef candidate. 
57

Appendix B 

Federal Environmental Laws Relevant for Consideration in the Preparation 

of a Vessel for Use as an Artificial Reef 

This Appendix identifies selected federal statutes relevant for consideration in preparation of a 

vessel for use as an artificial reef. For these statutes, the Appendix explains their potential 

relevance and briefly summarizes the relevant provisions. The first set of statutes briefly 

summarized are environmental laws administered by EPA which may be relevant to the removal 

of material from vessels or the disposal of such removed material. In addition, although this 

document focuses on environmental best management practices for vessel preparation, for the 

reader’s convenience the Appendix also briefly summarizes federal statutes establishing permit 

requirements for the actual placement of the vessel as an artificial reef. Finally, the Appendix 

briefly describes a number of other significant federal environmental statutes that may affect 

issuance of such permits or the actual conduct of placement activities. 

The information in this Appendix is intended only for the convenience of the reader in order to 

provide a useful starting point for identifying the principal environmental statutes of interest. 

The Appendix is not intended to be an exhaustive list of every conceivably relevant statute, nor 

do the brief summaries in this list alter or replace any requirements, regulations, or applicable 

guidance under those statutes that are summarized. Readers also should be aware that in 2000, 

EPA published tips for regulatory compliance for ship scrapping, and that document contains 

additional guidance that may be useful in preparation of a vessel for use as an artificial reef. See 

www.epa.gov/oecaerth/resources/publications/civil/federal/shipscrapguide.pdf. 

State and local laws also may apply to vessel preparation or placement for use as an artificial 

reef, and interested readers should consult with appropriate State and local authorities to identify 

such further requirements. 

EPA-Administered Federal Environmental Laws Relevant to Vessel Preparation 

C The Clean Air Act (CAA), 42 U.S.C. '' 7401, et seq., generally addresses the emission 

of air pollutants. Among other things, it directs EPA to establish minimum national 

standards for air quality, and assigns primary responsibility to the states to assure 

compliance with the standards through State Implementation Plans (SIPs). State-specific 

SIPs may impose requirements that are more prescriptive, more stringent, or more 

specific than the minimum national standards. Among national standards relevant for 

vessel preparation, EPA has established a National Emissions Standards for Hazardous 

Air Pollutants (NESHAP) for asbestos at 40 CFR Part 61 Subpart M. The asbestos 

NESHAP is intended to minimize the release of asbestos fibers during demolition and 

renovation activities, which would include asbestos removal when preparing a vessel for 

use as an artificial reef. EPA has delegated authority to inspect and enforce the asbestos 

NESHAP to most states, which, as noted, may have requirements that are more stringent 

than federal requirements. Other NESHAPs also may be relevant to removal of other 

materials on vessels, and may be found at 40 CFR Parts 61 and 63. In addition, Title VI 

of the Act directs EPA to establish requirements for the control of substances that 

contribute to stratospheric ozone depletion, which include substances such as halons used 
58

in fire suppression systems and certain refrigerants, that the best management practices in 

this guidance recommend be removed from a vessel in preparation for its use as an 

artificial reef. The recovered ozone-depleting refrigerants and halons should be delivered 

to an EPA-approved refrigerant and/or halon reclaimer for proper handling. Regulations 

addressing recycling and reuse of such removed refrigerants and halons, including 

chlorofluorocarbons and hydrofluorocarbons (sometimes referred to under the trade name 

Freon), appear at 40 CFR Part 82. 

C The Clean Water Act (CWA), 33 U.S.C. '' 1251, et seq., generally regulates the addition 

of pollutants from a point source to waters of the United States. The definition of point 

source includes a “vessel or other floating craft.” CWA requirements are implemented, 

among other things, through permits under either section 402 (the National Pollutant 

Discharge Elimination System (NPDES) permitting program) or section 404 (the 

permitting program for dredged and fill material). Pollutants generated in the preparation 

of a vessel for use as an artificial reef that are discharged to waters of the U.S., including 

via contaminated storm water, require NPDES permit authorization. The NPDES 

permitting program is primarily administered by states, with EPA oversight. In addition 

to the CWA’s NPDES permitting program, section 311 establishes a program for the 

prevention and abatement of, and remedial response to, oil and hazardous substance 

spills. See 40 CFR Parts 110, 112, 116, and 117. Section 311 imposes requirements for 

reporting the release of oil and hazardous substances, which might be relevant to the 

preparation of a vessel for use as an artificial reef should preparation result in such a 

release. Section 311 is jointly administered by EPA and the U.S. Coast Guard, depending 

on the location of the source. (For discussion of CWA section 404 permitting and the 

placement of vessels as artificial reefs, refer to the section of this Appendix describing 

federal laws that establish permitting requirements for placement of artificial reefs). 

C The Comprehensive Environmental Response, Compensation, and Liability Act 

(CERCLA), 42 U.S.C. §§ 9601, et seq., better known as the "Superfund Act," addresses 

cleanup of hazardous substances. CERCLA and its implementation documents empower 

EPA and other agencies to identify and prioritize sites for cleanup, and to order or carry 

out environmental remediation. Subject to limited defenses, CERCLA imposes strict 

liability for environmental cleanup on persons connected to facilities from which there 

are releases into the environment. CERCLA also mandates reporting to the National 

Response Center of hazardous substance releases. In conjunction with CWA section 311, 

CERCLA provides for federal preparation of the National Contingency Plan for 

responding to a hazardous substances release. As noted regarding CWA section 311, 

CERCLA is relevant to the preparation of a vessel for use as an artificial reef in its 

release reporting requirements, particularly for oil and hazardous substances. CERCLA 

is administered by federal agencies, not states.

C The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), 7 U.S.C. §§ 136, et 

seq., generally regulates the registration, labeling, distribution, sale, and use of pesticides. 

EPA regulates anti-foulant paints, including those containing organotins, copper, and 

other pesticidal compounds under FIFRA. EPA has relied on FIFRA and the Organotin 

Anti-fouling Paint Control Act of 1988 (33 U.S.C. §§ 2401, et seq.) for authority to 

impose requirements, such as certification and training for applicators and label 
59

 

requirements dealing with tributyl tin (TBT) application and disposal. TBT anti-fouling 

paint label requirements include provisions directing that all paint chips, spent abrasives, 

and any other waste products from paint removal be disposed of in a sanitary landfill. 53 

Fed. Reg. 39022, 39038, col. 3 (October 4, 1988). In addition, use of any pesticide in the 

preparation of a vessel for use as an artificial reef must comply with label requirements. 

For the most part, FIFRA is administered by EPA, though some states have primary 

enforcement responsibility for FIFRA use violations. 

C The Marine Protection, Research and Sanctuaries Act (MPRSA), 33 U.S.C. §§ 1401, et 

seq., prohibits, unless authorized by an MPRSA permit, (1) transportation of material 

from the United States for the purpose of ocean dumping; (2) transportation of material 

from anywhere for the purpose of ocean dumping by federal agencies or U.S. flagged 

vessels; and (3) dumping of material transported from outside the United States into the 

territorial sea of the United States. If any materials removed from vessels being prepared 

for use as an artificial reef were subsequently proposed for ocean dumping, a permit 

under the MPRSA would be necessary. Denial of such a permit request, however, would 

be highly likely because land-based alternatives (the consideration of which are required 

for MPRSA permit issuance) typically would be available. In addition, it would seem 

improbable that such a proposal could satisfy the other applicable environmental criteria 

of the MPRSA and implementing regulations. The MPRSA is administered by EPA and 

the U.S. Army Corps of Engineers, not states.5

C The Resource Conservation and Recovery Act (RCRA), 42 U.S.C. §§ 6901, controls the 

management of hazardous wastes “from cradle to grave.” If, in the preparation of a 

vessel for use as an artificial reef, a waste is generated that is specifically listed as 

hazardous or exhibits any hazardous characteristics, e.g. toxicity, and the waste is not 

excluded or exempt from the RCRA Subtitle C regulations, then this waste would be 

considered hazardous waste and subject to all applicable RCRA regulations. See 40 CFR 

Parts 260 and 261. Depending upon the volume of hazardous wastes that are generated 

and the length of time the hazardous wastes are accumulated, RCRA regulations provide 

conditional exemptions from some of the regulatory requirements. In most states, EPA 

has authorized the State to administer some or all of RCRA requirements under state law 

in lieu of federal law and, depending on the state, state law may include requirements that 

are more stringent or prescriptive than federal law. Hazardous waste and used oil must 

be managed according to RCRA regulations. 

C The Toxic Substance Control Act (TSCA), 15 U.S.C. '' 2601, et seq., bans the 

manufacture, processing, use, and distribution in commerce of polychlorinated biphenyls 

(PCBs) and directs EPA to set regulations for the disposal of PCBs. TSCA requirements 

generally determine the degree of necessary PCB removal from vessels being prepared 

for use as an artificial reef. Although TSCA imposes requirements for toxic substances 

other than PCBs, TSCA’s PCB requirements are uniquely relevant to preparation of a 

5

 The MPRSA definition of “dumping” excludes the construction of fixed structures or artificial islands, as well as 

deposits of materials for the purpose of developing or maintaining fisheries resources, when otherwise regulated by 

federal or state law (or occurring pursuant to authorized federal or state programs). Because the placement of a 

vessel to create an artificial reef in waters subject to jurisdiction of the United States is regulated under other federal 

laws, the actual placement of vessels for use as an artificial reef is not subject to regulation under the MPRSA. 
60

 

vessel for use as an artificial reef because of the likely presence of PCBs on many 

obsolete vessels. More specific guidance on the applicability of TSCA’s PCB 

requirements to vessels being prepared for use as an artificial reef is provided in the 

section of the environmental best management practices addressing PCBs, and readers 

should refer to that section for further information. 

Federal Environmental Laws Establishing Permit Requirements for Placement of Vessels as 

Artificial Reefs 

C Section 404 of the CWA, 33 U.S.C. ' 1344, establishes a permitting program for the 

discharge of dredged or fill material to waters of the Unites States. Placement of a vessel 

in waters of the United States as an artificial reef would constitute a discharge of fill 

material, and therefore would require a CWA section 404 permit. 33 CFR 323.2(e) & (f). 

For CWA purposes, “waters of the United States” include most inland waters as well as 

the waters of the territorial sea, which, under the CWA, is measured from the baseline 

(i.e., the line of ordinary low water along that portion of the coast which is in direct 

contact with the open sea and the line marking the seaward limit of inland waters) in a 

seaward direction a distance of three miles. Section 404 permitting is primarily 

administered by the U.S. Army Corps of Engineers (Corps), using environmental 

guidelines set out in EPA regulations appearing at 40 CFR Part 230. Among other 

things, except as provided by 40 CFR 230.5(b) and 230.7(b)(1) (relating to activities 

covered by an applicable general permit), these guidelines require consideration of 

practicable alternatives to the proposed discharge, and in the case of proposed discharges 

to special aquatic sites, presume that all practicable alternatives not involving a discharge 

into a special aquatic site have less adverse impact on the aquatic ecosystem, unless 

clearly demonstrated otherwise. 40 CFR 230.5(c); 230.10(a). Special aquatic sites are 

identified at 40 CFR Part 230 Subpart E and include, among other things, marine 

sanctuaries and coral reefs. In addition to evaluation for compliance with these 

guidelines, section 404 permits are also subject to the Corps’ public interest review under 

33 CFR 320.4. Corps regulations relevant to the CWA section 404 permitting program 

appear at 33 CFR Parts 320, 323, 325, 328, and 331. Though EPA has authorized two 

States to administer the section 404 permitting program for certain waters in those States, 

these State programs probably would not to be relevant to the placement of a vessel for 

use as an artificial reef because states may not assume section 404 permitting authority 

for discharges of fill material to waters supporting commercial navigation, waters subject 

to the ebb and flow of the tide, or waters of the territorial seas, where a former 

vessel/artificial reef would likely be sited. 

C Section 10 of the Rivers and Harbors Act of 1899 (RHA), 33 U.S.C. '' 403, requires a 

permit from the Corps for, among other things, the construction of any structure 

(including artificial reefs) in or over any “navigable water of the United States” as that 

term is defined at 33 CFR Part 329.6

 Structures or work outside the limits of “navigable 

waters of the United States” also require a section 10 permit if the structure or work 

6

 In cases where the waters in which the vessel is being placed for use as an artificial reef are subject to both RHA 

section 10 and CWA section 404 permitting (e.g., the 3 mile territorial sea), Corps practice is to issue a single 

consolidated permit satisfying the requirements of both these statutes. 
61

affects the course, location, or condition of the waterbody in such a manner as to impact 

on navigational capacity. Under section 4(e) of the Outer Continental Shelf Lands Act, 

43 U.S.C. § 1333(e), RHA section 10 permit requirements also apply to the creation of 

structures on the Outer Continental Shelf of the United States, including artificial reefs. 

33 CFR 322.3(b). Issuance of permits under RHA section 10 involves a public interest 

review by the Corps in accordance with 33 CFR 320.4. To help safeguard navigational 

and other marine uses, Corps permits for artificial reefs have required that permittees 

notify the National Oceanic & Atmospheric Administration (NOAA) prior to, and upon 

completion of, the reefing activity, including a drawing certifying the location and 

configuration of the completed activity. 33 CFR Part 325, Appendix A, special condition 

B.5. Corps regulations relevant to the RHA section 10 permitting program appear at 33 

CFR Parts 320, 322, 325, 329, and 331. 

Other Significant Federal Environmental Statutes That May Affect Issuance of Permits or 

Licenses for Artificial Reefs or the Conduct of Placement Activities.

C The Liberty Ship Act, 16 U.S.C. '' 1220, et seq., authorizes states to apply to the 

Secretary of the Department of Transportation (DOT) for the use of DOT-owned obsolete 

vessels, including obsolete vessels of the Maritime Administration, as an artificial reef for 

the conservation of marine life. The Liberty Ship Act requires that the state application 

to DOT include a certification from EPA that the proposed use of the vessel will be 

compatible with “applicable water quality standards and other appropriate environmental 

protection requirements.” 16 U.S.C. ' 1220 (b). The ability to meet such standards and 

requirements will be affected by what materials are onboard the vessel. 

C The National Fishing Enhancement Act of 1984 (NFEA), 33 U.S.C. '' 2101, et seq., 

applies to all artificial reefs in waters of the United States or on the Outer Continental 

Shelf for the purpose of enhancing fishery resources. Section 204 of NFEA obligates 

NOAA to issue a national artificial reef plan that addresses issues such as siting and 

design criteria. Additionally, NFEA section 205 establishes further requirements to be 

applied by the Corps in the exercise of its previously described permitting authority for 

placement of artificial reefs under RHA section 10 or CWA section 404. Such 

requirements are reflected in the previously identified Corps permitting regulations for 

artificial reefs (e.g., 33 CFR 320.3(o), 322.5(b), and 325.1(d)(8)). 

C The Coastal Zone Management Act (CZMA), 16 U.S.C. 1451, et seq., establishes a 

federal/state partnership to provide for the comprehensive management of coastal 

resources. Under CZMA section 307(c)(3), applicants for a required federal license or 

permit to conduct an activity affecting the coastal zone of a state with an approved 

coastal management program need to provide the federal permitting agency and the 

relevant state with a certification that the proposed activity complies with the enforceable 

policies of the state’s approved program and will be conducted in a manner that is 

consistent with the program. Under CZMA section 307(c)(1), a federal agency activity 

that affects the coastal zone must be carried out in a manner which is consistent to the 

maximum extent practicable with the enforceable policies of an approved coastal 

management program. Relevant implementing regulations established by NOAA (which 

is responsible for federal administration of the CZMA) appear at 15 CFR Part 930, 
62

 

Subpart C (consistency for federal agency activities) and Subpart D (consistency for 

activities requiring a federal license or permit). NOAA's CZMA regulations were 

recently amended. 71 Fed. Reg. 788 (Jan. 5, 2006). The regulations provide that in the 

case of federal agency applications for federal licenses or permits, as well certain general 

permits proposed by a federal agency, review will be conducted under the Subpart C 

regulations. See 15 CFR 930.31(d) & 930.52. Corps regulations implementing the 

CZMA for its RHA section 10 and CWA section 404 permit programs appear at 33 CFR 

320.3(b), 320.4(h), and 325.2(b)(2). 

C The National Environmental Policy Act of 1969 (NEPA), 42 U.S.C. §§ 4321, et seq., 

requires that federal agencies include in their decision-making processes appropriate and 

careful consideration of the environmental effects of, and alternatives to, their actions. 

NEPA section 102(2)(C) includes a requirement for preparation of an environmental 

impact statements (EIS) for “major federal actions significantly affecting the quality of 

the human environment.” For proposed federal actions where the environmental effects 

are unclear, the agency often prepares an environmental assessment, which is a brief and 

concise document containing sufficient evidence and analysis for the agency to determine 

whether to prepare an EIS or to issue a finding of no significant impact. 40 CFR 

1501.4(b), 1508.9(a)(1), 1508.13. Council on Environmental Quality regulations 

implementing NEPA appear at 40 CFR Parts 1500 – 1518. Corps regulations 

implementing NEPA for its RHA section 10 and CWA section 404 permit programs 

appear at 33 CFR 320.3(d) and Part 325, Appendix B. 

C Under Clean Air Act section 309, 42 U.S.C. § 7609, EPA reviews and comments on the 

environmental impacts of several types of actions of other federal agencies, including all 

actions subject to the requirement under the National Environmental Policy Act to 

prepare an Environmental Impact Statement. EPA comments in writing and make those 

comments available to the public. If EPA determines that the action is unsatisfactory 

from the standpoint of public health or welfare or environmental quality, EPA refers the 

matter to the Council on Environmental Quality. 

C The Endangered Species Act (ESA), 16 U.S.C. §§ 1531, et seq., addresses the 

conservation of federally-listed threatened and endangered species and the ecosystems on 

which those species depend. ESA section 7 requires that federal agencies, in consultation 

with the National Marine Fisheries Service and/or the U.S. Fish and Wildlife Service7

, 

ensure that any action authorized, funded, or carried out by the agency (including 

issuance of federal permits) is not likely to jeopardize the continued existence of listed 

species or result in the adverse modification of their designated critical habitat. 

Whenever such an agency action may affect a listed species or critical habitat, the 

interagency consultation requirement is triggered, and the ESA section 7 procedural 

requirements at 50 CFR Part 402 apply. In addition, ESA section 9 generally prohibits 

anyone from taking listed animal species without authorization. “Take” is defined in 

ESA section 3(19) to include harming and killing. Authorization to take is generally 

granted through the section 7 consultation process, in exchange for measures to minimize 

7

 The National Marine Fisheries Service is now referred to as NOAA Fisheries, and is generally responsible for 

marine species under the ESA. The U.S. Fish and Wildlife Service is generally responsible for terrestrial and 

freshwater species. 
63

the take. Detailed information regarding ESA compliance can be found online at 

http://www.nmfs.noaa.gov/pr/species/esa.htm and 

http://www.fws.gov/endangered/wildlife.html. EPA’s CWA section 404(b)(1) guidelines 

also address ESA issues in the context of CWA section 404 permitting and appear at 40 

CFR 230.30. Corps regulations implementing the ESA for its RHA section 10 and CWA 

section 404 permit programs appear at 33 CFR 320.3(i) and 325.2(b)(5). 

C The Fish and Wildlife Coordination Act, 16 U.S.C. §§ 661, et seq., provides that 

whenever the waters or channel of a waterbody are proposed or authorized to be modified 

by a public or private agency under federal permit or license, the agency first shall 

consult with the USFWS and the head of the state agency responsible for wildlife 

resources. The purpose of this consultation is to promote conservation of wildlife 

resources by preventing loss of and damage to such resources and to provide for the 

development and improvement of wildlife resources in connection with the agency 

action. Although the recommendations of the Secretary of the Interior and state officials 

are not binding, the federal agency must give them full consideration. In addition, EPA’s 

CWA section 404(b)(1) guidelines address wildlife issues in the context of section 404 

permitting and appear at 40 CFR Part 230, Subpart D. Corps regulations implementing 

the Fish and Wildlife Coordination Act for its RHA section 10 and CWA section 404 

permit programs appear at 33 CFR 320.3(e) and 320.4(c). 

C Title III of the National Marine Sanctuaries Act (NMSA), 16 U.S.C. §§ 1431, et seq., 

authorizes the Secretary of Commerce to designate and manage national marine 

sanctuaries. Under NMSA section 304(d), federal agency actions (including private 

activities authorized by federal permits) that are likely to destroy, cause the loss of, or 

injure sanctuary resources are subject to consultation with the Secretary of Commerce. If 

the Secretary finds that a federal action is likely to have this effect, the Secretary must 

recommend feasible alternatives to protect resources, and if the agency does not follow 

those alternatives it must provide a written statement explaining why. The marine 

sanctuary program is administered by NOAA, which has promulgated implementing 

regulations at 15 CFR Part 922. Part 922 specifically identifies all designated marine 

sanctuaries and their boundaries, as well as applicable regulations and restrictions 

governing their use. EPA’s CWA section 404(b)(1) guidelines also address marine 

sanctuaries in the context of section 404 permitting and appear at 40 CFR 230.40. Corps 

regulations implementing these NMSA provisions for its RHA section 10 and CWA 

section 404 permit programs appear at 33 CFR 320.3(c) and 320.4(i). 

C The Magnuson-Stevens Fishery Conservation and Management Act (Magnuson-Stevens 

Act), 16 U.S.C. §§ 1801, et seq., is the principal federal law addressing the conservation 

and management of fisheries resources. Among other things, Magnuson-Stevens Act 

section 305(b)(1) provides that fisheries management plans developed under the 

Magnuson-Stevens Act must identify essential fish habitat (EFH). Magnuson-Stevens 

Act section 3(10) defines EFH as “...those waters and substrate necessary to fish for 

spawning, breeding, feeding, or growth to maturity.” Under section 305(b)(2), federal 

agencies are directed to consult with the Secretary of Commerce with respect to any 

action to be authorized, funded, or undertaken that may adversely affect any identified 

EFH. If the Secretary determines the action would adversely affect such EFH, the 
64

Secretary is to recommend measures that could be taken by the agency to conserve the 

EFH. The agency must respond to such recommendations in writing, including a 

description of measures proposed by the agency for avoiding, mitigating, or offsetting the 

impact of the activity on the EFH. Under Magnuson-Stevens Act section 305(b)(4), if the 

agency’s response is inconsistent with the Secretary’s recommendations, the agency must 

explain why. The locations of EFH identified under the Act can be found online at 

http://www.nmfs.noaa.gov/habitat/habitatprotection/efh/fish_manage_c.htm. NOAA 

regulations implementing the EFH provisions of the Act appear at 50 CFR Part 600, 

Subparts J and K. 

 

C The Marine Mammal Protection Act of 1972 (MMPA), 16 U.S.C. §§ 1361,1362, 1371-

1384 note, 1386-1389, 1401-1407, 1411-1417, 1421-1421h, is the principal federal 

legislation addressing marine mammal species protection and conservation. MMPA 

section 102 prohibits, with certain exceptions, the take of marine mammals in United 

States waters and by U.S. citizens on the high seas, and the importation of marine 

mammals and marine mammal products into the United States. Marine mammals subject 

to the MMPA are defined in MMPA section 3(6) to include both species that are 

morphologically adapted to the marine environment (e.g., sea otters, manatees, seals, 

walruses, dolphins, whales) or which primarily inhabit the marine environment (e.g., 

polar bears). MMPA section 3(13) provides that “take” means to harass, hunt, capture, or 

kill, or to attempt to do so. Depending on the species of marine mammal involved, 

MMPA section 3(12) divides MMPA implementation responsibility between the 

Department of the Interior (USFWS) and the Department of Commerce (NOAA). Under 

this division of responsibility NOAA manages the majority of marine mammals, 

including whales, dolphins, porpoises, seals, and sea lions, while the USFWS manages 

five species: polar bears, walrus, sea otters, manatees, and dugongs. Relevant 

implementing regulations appear at 50 C.F.R Part 216 (NOAA) and 50 CFR Part 18 

(USFWS). Corps regulations implementing the MMPA for its RHA section 10 and CWA 

section 404 permit programs appear at 33 CFR 320.3(k). 

C Section 401 of the Clean Water Act (33 U.S.C. 1341) requires that any applicant for a 

federal license or permit (e.g., an EPA-issued NPDES permits or a Corps-issued section 

404 permit) to conduct an activity that may result in a discharge into waters of the United 

States shall provide the permitting agency a certification from the state in which the 

discharge originates certifying that the license or permit complies with CWA 

requirements, including applicable state water quality standards. No federal license or 

permit subject to CWA section 401 may be issued unless the state either grants or waives 

certification. As a result, CWA section 401 provides states with the ability to preclude 

the issuance of federal permits or licenses subject to section 401 by denying certification, 

as well as the ability to indirectly impose conditions upon such federal permits or licenses 

by placing limitations or conditions on its section 401 certification. EPA regulations 

implementing CWA section 401 appear at 40 CFR Part 121. Corps regulations 

implementing the CWA section 401 its RHA section 10 and CWA section 404 permit 

programs appear at 33 CFR 320.3(a), 320.4(d), and 325.2(b)(1). 
65

Appendix C

Information related to materials found on scuttled vessels that may have potentially hazardous 

effects on the marine environment*

*The text provided in this appendix is an excerpt from the 2005 “Policy Statement of the National Marine Sanctuary 

Program: Artificial Reef Permitting Guidelines.” 

Scuttled Vessels

The scuttling of vessels requires particular attention in this policy because of their size and 

potential toxicological effects on the environment. As discussed above, sunken ships potentially 

attract divers away from natural reefs and thus may be beneficial to natural reefs in National 

Marine Sanctuaries. However, there is a wide array of concerns that must be addressed before 

intentionally sinking a ship. 

The removal of petroleum products, hazardous materials, paint cans, batteries, plastics, oil, and 

fuel is specified on the U.S. Coast Guard’s Ocean Disposal/Artificial Reef Inspection form. 

Additionally, under the Toxic Substances Control Act (TSCA), the EPA has the authority to 

gather information on and regulate chemical substances and mixtures imminently hazardous or 

presenting unreasonable risk of injury to public health or the environment. Despite these 

controls, some materials of concern may still remain on items used as artificial reef material. 

Such materials include: asbestos, polychlorinated biphenols (PCBs), iron, lead paint, and 

antifouling paint. The National Marine Sanctuaries Program (NMSP) should consider the risks 

associated with materials remaining on vessels to be used as artificial reefs. The NMSP will 

consult with appropriate agencies (i.e., U.S. EPA, MARAD) to determine the best management 

practices to use in evaluating materials for pollution potential). 

Asbestos is the name given to six naturally occurring minerals that are used as insulators and fire 

retardants. Several studies have investigated the effects of asbestos on fish (Batterman and Cook 

1981, Belanger et al. 1990, Belanger et al 1986, Woodhead et al. 1983). The findings indicate 

that asbestos concentrations on the order of 106 to 108 fibers/L may cause epidermal lesions, 

epithelial hypertrophy, kidney damage, decreased orientation and swimming ability, degradation 

of the lateral line, reduced growth, and increased mortality in fish. Undisturbed, non-friable (not 

easily crumbled) asbestos has been found to be relatively harmless (Garcia and Salzwedel 1995, 

Montoya et al 1985). 

PCBs may still exist in water-tight gaskets, cable insulation, paint, transformers, capacitors, and 

other components of decommissioned Navy vessels (Martore et al.1996, Eisler and Belisle 

1996). These chemicals have been implicated in: reduced primary productivity in 

phytoplankton; reduced hatchability of contaminated fish and bird eggs; reproductive failure in 

seals; altered steroid levels and subsequent reproductive impairment in fish and sea stars; 

reduced fertilization efficiency in sea urchins; and reduced plasma retinal and thyroid hormone 

levels potentially leading to increased susceptibility to microbial infections, reproductive 

disorders and other pathological alternation in seals and other marine mammals (Adams and 

Slaughter-Williams 1988, Brouwer et al. 1989, Clark 1992, den Besten et al. 1991). 

Antifouling paints typically containing tributyltin (TBT) and copper (Cu) are often used to paint 

vessel hulls to inhibit the growth of organisms below the water line. An IMO convention to 
66

 

control the use of harmful anti-fouling systems on ships was adopted on October 5, 2001. The 

convention will prohibit the use of harmful organotins, including TBT, in anti-fouling paints 

used on ships and establish a mechanism to prevent the potential future use of other harmful 

substances in anti-fouling systems. TBT has been found to be toxic to non-target, non-fouling 

organisms at low levels (approximately 7.5-10.5 ng TBT/L). One of its most marked effects has 

been the induction of shell thickening and growth anomalies in oysters and imposex in the 

dogwhelk Nucella lapillus potentially leading to sterility (Gibbs et al. 1998).8

 The discovery of 

the highly toxic nature of TBT-based paints has led many countries to ban the use of these paints 

for non-aluminum hulled vessels less than 25 meters in length. Copper, though an effective 

antifoulant, has not been shown to cause extensive effects on non-target organisms at relatively 

low levels. When present in high concentrations, however, copper can be toxic to aquatic life 

(Sorrenson 1991). In a study conducted when a cargo ship collided with part of the Great Barrier 

Reef and remained grounded for 12 days, sediment containing 8.0 mg kg super(-1) TBT, 72 mg 

kg super(-1) Cu and 92 mg kg super(-1) Zn was found to significantly inhibit larval settlement 

and metamorphosis (Negri et al. 2002). At this level of contamination, larvae survived but 

contracted to a spherical shape and swimming and searching behavior ceased. At higher 

contamination levels, 100% mortality was recorded. These results indicate that the contamination 

of sediment by anti-fouling paint has the potential to significantly reduce coral recruitment in the 

immediate vicinity of the site and that this contamination may threaten the recovery of the 

resident coral community unless the paint is removed. 

Iron, an essential element like copper, can be contributed to the environment from steel hulls of 

sunken vessels. As an essential element, iron levels will tend to be closely regulated by 

organisms, and thus, it is unlikely that any pollution-derived effects will be observed except in 

severe and localized cases (Thompson 1990). Corals living in seawater with high iron 

concentrations have been shown to incorporate the iron into their skeletons (Brown et al. 1991). 

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 (Coale et al. 1996, Frost 1996, Matsunaga et al. 1994, Takeda 1998, Wells et al.

1995). Hence the concern of unnatural iron inputs from artificial reefs seems to center not on the 

occurrence of adverse toxicological effects in marine organisms, but rather on the alteration of 

the composition of natural assemblages of algae and species which compete with algae. 

Lead paint has been used on the interiors of some vessels. Lead has no biological function and, 

therefore, exhibits accumulation trends in organisms (Thompson 1990). Corals have been shown 

to incorporate lead into their skeletons (Dodge and Gilbert 1984). Unicellular algae and sea 

urchins appear to be the most sensitive marine organisms (Berhard 1980). Growth inhibition has 

been observed in the algae species Thalassiosira pseudonana and Porphyridium marinum

exposed to lead as well as in sea urchins. 

References 

Adams, J.A. and S. Slaughter-Williams. 1988. The effects of PCBs on fertilization and 

morphology in Arbacia punctulata. Water Air Soil Pullot. 38: 299-310. 

Batterman, A.L. and P.M. Cook. 1981. Determination of mineral fiber concentrations in fish 

tissues. Can. J. Fish. Aquat. Sci. 38: 952-959. 

8

 Imposex is defined as the development of specific male sexual organs in females. 
67

Belanger, S.E., K. Schurr, D.A. Allen, and A.F. Gohara. 1986. Effects of chrysotile asbestos on 

coho salmon and green sunfish: evidence of pathological stress. Environ. Res. 39: 74-85. 

Belanger, S.E., D.S. Cherry, and J. Cairns, Jr. 1990. Functional and pathological impairment of 

Japanese Medaka (Oryzias latipes) by long-term asbestos exposure. Aquat. Toxicol. 17: 

133-154. 

Brouwer, A., P.J.H. Reijnders, and J.H. Koeman. 1989. Polychlorinated biphenol (PCB)- 

contaminated fish induces vitamin A and thyroid hormone deficiency in the common 

seal. Aquatic Toxicology. 15: 99-106. 

Brown, B.E., A.W. Tudhope, M.D.A. Le Tissier, and T.P. Scoffin. 1991. A novel mechanism for 

iron incorporation into coral skeletons. Coral Reefs 10: 211-215. 

Clark, R.B. 1992. Marine Pollution. Clarendon Press, Oxford, 172. 

Coale, K.H., S.E. Fitzwater, R.M. Gordon, K.S. Johnson, and R.T. Barber. 1996. Control of 

community growth and export production by upwelled iron in the equatorial Pacific 

Ocean. Lett. Nature 379: 621-624. 

den Beston, P.J., J.M.L. Elenbaas, J.R. Maas, S.J. Dieleman, H.J. Herwig, and P.A. Voogt. 1991. 

Effects of cadmium and polychlorinated biphenols on steroid metabolism and 

cytochrome P-450 monooxygenase system in the sea star Asterias rubens L. 

AquaticToxicology. 20: 95-100. 

Frost, B.W. 1996. Phytoplankton bloom on iron rations. Nature 383: 475-476. 

Garcia, C.B. and H. Salzwedel. 1995. Successional patterns on fouling plates in the Bay of Santa 

Marta, Colombian Caribbean. An. Inst. Invest. Mar. Punta de Betin. 24: 95-121. 

Gibbs, P.E., P.L. Pascoe, and G.R. Burt. 1988. Sex change in the female dog-whelck, Nucella 

lapillus, induced by tributyltin from antifouling paints. J. Mar. Biol. Ass. U.K. 68:715-

731. 

Martore, R.M., T.D. Mathews, and M. Bell. 1998. Levels of PCBs and heavy metals in biota 

found on ex-military ships used as artificial reefs. South Carolina Department of Natural 

Resources, Charleston, South Carolina. 

Matsunaga, K., Y. Suzuki, K. Kuma, and I. Kudo. 1994. Diffusion of Fe(II) from an iron 

propagation cage and its effect on tissue iron and pigments of macroalgae on the cage. J. 

Appl. Phycol. 6: 397-403. 

Montoya, A.J., Q.R. Quesada, Z.E. Madriz, M.E. Castro, and P.O. Urpi. 1985. Comparative 

analysis of substrates for collection of mangrove oyster spat in Viscaya estuary, Limon, 

Costa Rica. Rev. Biol. Trop. 33: 1-6. 

Negri, A.P., L.D. Smith, N.S. Webster, A.J. Heyward. 2002. Understanding ship-grounding 

impacts on a coral reef: potential effects of anti-foulant paint contamination on coral 

recruitment. Mar. Pollut. Bull. Vol. 44: 111-117. 

Sorrenson, E.M. 1991. Metal poisoning in fish. CRC Press, Inc., Boca Raton, 374 pp. 

Takeda, S. 1998. Influence of iron availability on nutrient consumption ratio of diatoms in 

oceanic waters. Nature 393: 774-777. 

Thompson, D.R. 1990. Metal levels in marine vertebrates. In R.W. Furness and P.S. Rainbow 

(eds.), Heavy Metals in the Marine Environment. CRC Press, Inc., Boca Raton, pp 143-

183. 

Wells, M.L. N.M. Price, and K.W. Bruland. 1995. Iron chemistry in seawater and its relationship 

to phytoplankton: a workshop report. Mar. Chem. 48: 157-182. 

Woodhead, A.D., R.B. Setlow, and V. Pond. 1983. The effects of chronic exposure to asbestos 

fibers in the Amazon molly, Poecelia Formosa. Environ. International. 9:173-176. 
68

Appendix D 

Developing Workplans for Vessel Preparation Prior to Reefing

Determining the type and location of the potential sources of contamination from a vessel 

intended for use as an artificial reef should be conducted as part of a workplan for vessel clean 

up and preparation. The purpose of such a workplan is to assure that materials of concern 

potentially contributing to pollution of the marine environment are addressed prior to reefing. 

The development of a workplan also can allow for more effective clean-up efforts during vessel 

preparation by considering activities such as recycling and reuse operations and possibly diver 

safety preparations. Any such salvage operations should occur in a manner that will minimize 

debris and contamination with oils or other products that have to be cleaned up at a later date. 

This activity may allow for improved access for subsequent clean-up efforts. 

Information which may be useful in the preparation of a workplan could include: 

• Asbestos documentation for the vessel; 

• PCB documentation for the vessel; 

• Documentation that naval vessels have been previously demilitarized and certified to 

be radiologically decontaminated; 

• Documentation that refrigerants and halons have been removed from shipboard 

systems; 

• Information on hazardous materials onboard the vessel; 

• Information on exterior hull paint which could include paint type and date of last 

application; 

• General drawings of machinery, compartments, and tank layouts; 

• Description of vessel dimensions including size, weight, and superstructure materials; 

• Tank soundings describing the volume and contents of fuel oil tanks prior to 

preparation for reefing; 

• List of items with beneficial reuse potential to be salvaged prior to sinking; 

• Assessment of applicable laws and regulations, including permit requirements; and 

• Reef site surveys and proposed site preparation. 

An assessment of the above mentioned information could then direct the actions needed for 

preparation of the reef project workplan. Some general workplan preparation actions include: 

• Assess vessel drawings and dimensions; 

• Identify which items will remain on the vessel; 

• Identify items to be salvaged prior to sinking; 

• Estimate economic viability of the reef project (including permit costs and 

timeframes); 

• Determine if the vessel is a good candidate (i.e., does the workplan fall within 

reasonable time and financial commitments); 

• Coordinate with all regulatory agencies, local, regional, State and federal, as well as 

stakeholders, during all project phases; 

• Apply for and receive the appropriate permits for the project;
69

• Remove hazardous materials and clean vessel; 

• Inspect vessel to clear all findings (that the workplan for removal of materials as well 

as the vessel clean-up is met); 

• Conduct vessel stability analysis; 

• Develop strategy for vessel sinking; 

• Notify NOAA to update nautical charts once the ship has settled on the ocean floor; 

and 

• Deploy relevant aids to navigation and mooring/marker buoys at the site. 
70

Appendix E 

General Principles for a Vessel Clean-up Operation 

In order to prepare a vessel intended to create an artificial reef, a workplan should be developed 

to direct cleaning operations – as described in Appendix D. Salvage operations should take place 

first, being careful to minimize debris and contamination with oils or other products that will 

need cleaning sometime during the vessel preparation. Other vessel clean-up preparations to be 

considered include: 

• Re-use/recycle/dispose of all or some vessel components – besides ferrous scrap 

materials, there may be high-value components onboard the vessel, such as nonferrous metals (e.g., copper, aluminum, nickel), and re-useable equipment such as 

generators, machines, pumps, and cranes; 

• Generally, clean-up operations should begin at the highest part of the compartment or 

tank and proceed downwards to the bilge; 

• Deal with the large concentrations of oil and hazardous products early in the 

operation; 

• Keep compartments clean and make concerted efforts to avoid spillage during salvage 

and clean-up operations; and 

• Consider removing, instead of cleaning, heavily contaminated machinery and piping. 

Removal may be quicker and less expensive. Removal may also allow for less 

overall effort in clean-up as access to the contaminated machinery and piping is 

improved and ongoing contamination from drips and seepage is minimized. 
71

 

Appendix F 

Recommended Checklist for Documenting Vessel Clean-up Using this Guidance9, 10

I. Specify particular material of concern 

II. Describe narrative clean-up goal for that material of concern 

III. Conduct surveys and assessments to determine current conditions/amounts of material of 

concern and document and describe: 

9 Survey design and assessment methodologies 

9 Who conducted survey/assessment 

9 When survey/assessment was conducted 

9 Results of survey/assessment 

IV. Discuss how the narrative clean-up goal for the given material of concern was achieved 

(vessel preparation/clean-up initiated specifically for vessel-to-reef project) 

9 Who carried out the work? 

9 When was the work completed? 

9 What cleaning method was used? What preparation was done to address this 

material of concern? How was the narrative clean-up goal achieved? 

9 For some materials, the narrative clean-up goal is the removal of all of that given 

material (e.g., oil and fuel, solids/debris/floatables, antifreeze and coolants, fire 

extinguishing systems, batteries, refrigerants and halons, mercury, black and gray 

water, invasive species). For these materials of concern, has the removal of all 

the specified material been verified? How much of the material was removed and 

what was done with it after removal? 

9 For some materials of concern, the narrative goal allows for some materials to 

remain on the vessel if prepared properly (e.g., asbestos, paint, lead ballast bars, 

radioactive materials, negatively buoyant vessel debris). For these materials of 

9 This template would be used for each material of concern as presented in the BMPs (e.g., oil and fuel; asbestos; 

PCBs; paint; solids/debris/floatables; and batteries, antifreeze, coolants, mercury, radioactive materials and other 

materials of environmental concern).

10 This checklist is not a regulatory requirement, nor is it a requirement to submit this information to any particular 

governmental or quasi-governmental agency, State or Federal. However, this checklist outlines the type of 

information that might be useful to show that the goals in this guidance document have been met. 
72

concern, how much of the specified material was removed and how much remains 

on the vessel (e.g., approximately how many lead ballast bars, approximately how 

much surface area is still covered with paint, how many rooms/compartments still 

contain friable or nonfriable asbestos-containing material)? 

-Was the material prepared with the intention of leaving it on board? 

-Is the material encapsulated (friable asbestos) or covered with growth 

(active anti-fouling paint)? Enclosed in a room (negatively buoyant vessel 

debris)? 

9 How has the completed work been verified? 

V. Identify who prepared this document 

9 Name(s) and title(s) 

9 Contact information 
73

Appendix G 

Suggested Cleaning Methods for Oils, Fuels 

and Semi-solids (Greases) 

Tanks 

Methods for cleaning tanks include but are not limited to: 

• Mechanical Cleaning: Mechanical cleaning involves mechanical removal of sludge and 

remaining fluids and wiping down all surfaces with oil absorbent material. Although 

manpower intensive, this cleaning method limits the spread of contamination and does 

not require large volumes of fluids that are expensive to dispose. 

• Steam or Hot Water Cleaning: This method is quite effective, although it requires special 

equipment and generates large volumes of oily water. If this method is considered, a plan 

should be developed so that oily water generated during this cleaning method is dealt 

with in accordance with all applicable regulations. Surfactants or soaps are not 

recommended, as they tend to emulsify any oil present and make the oily water 

exceptionally difficult to treat. This would likely create higher disposal costs. In tanks 

where deckheads and sides are reasonably free of contamination, pressure washing can 

cause significant contamination of these otherwise clean surfaces through splashing, 

misting, and carry-over. 

• Solvent Washing: Solvent washing may be an option where there are especially difficult 

residuals or deposits that need removal. Note that the use of solvents will require special 

handling and disposal of all liquid product generated as wastes. 

In rare cases, especially where low-grade fuels have been stored, it may be necessary to resort to 

advanced tank cleaning methods such as ultrasonic or special solvents. It may also be 

advantageous to use a combination of several different methods, depending on the nature and 

location of the contamination. In general, mechanical cleaning would be the first method to try, 

followed by steam/hot water washing, then solvent washing in extremely difficult situations. 

Whatever method is selected, the effluent and water should be collected and treated. Large 

volumes will require the services of a pumper truck or barge, while smaller quantities should be 

collected and stored in drums and removed from the vessel. Caution should be used during all 

transfer operations to avoid spills. If transferring large quantities of oil or oil contaminated 

liquid, a boom around the vessel should be used to minimize the extent or spreading of a release. 

Fuel and Oil Pipe Fittings, Piping with Manifolds, and Filling Points 

Filling points: All filling stations or deck fittings that were used for receiving fuels or 

oils should be opened and cleaned. Access to the filling stations and deck fittings is 

necessary to ensure that they are completely drained and free of such fuels or oils. This 

will typically require access from the bottom and the top. 
74

Fuel and Oil Piping Including Manifolds: Fuel and oil piping (including non-segregated 

ballast systems) should be drained of all fuel and oil. The cleaning and opening of pipes 

varies according to the type of fuel or oil that was contained in the lines. In general, the 

more viscous the fuel or oil, the more opening of pipes and cleaning activity will be 

required. For very viscous products (e.g., No. 6 fuel oil or Bunker C fuel as described in 

the “Oil and Fuel” section of this document), all piping and fittings should be fully 

opened for visual inspection. 

Vertical piping runs should have all valves completely opened and any blanking flanges 

or spectacle plates removed for cleaning. Horizontal piping runs should be opened at low 

spots. Once draining of piping systems is completed, no visual evidence of weeping 

should exist at openings.

Fuel and Oil Piping Fittings: Fittings consist of valves, site glasses, coolers, siphon 

breakers, and filters. A visual examination of internals, or a cut through the lowest point 

of the fitting may be useful. Where fittings are of complex construction or have more 

than one oil-tight compartment (as in coolers), then access to all sub-compartments or 

components may be necessary. No visual evidence of weeping should exist at openings. 

Unless the piping is clearly identified as being part of a non-hydrocarbon system or there 

is clear evidence to indicate that the system was not part of a hydrocarbon containing 

system (e.g., seawater piping to coolers, fresh water piping to domestic spaces), it should 

be assumed that the piping contained fuel or oil. Fittings should be cleaned, or removed 

from the vessel. 

Bilge Compartments and Piping 

All piping that runs through the bilge areas of machinery spaces should be assumed to be 

contaminated by fuel, oil, or greases until proven otherwise. Piping in bilge spaces should 

follow the clean-up suggestions as presented in the subsection above entitled “Fuel and Oil 

Piping Including Manifolds.” 

Combustion Engines 

Structure: Remove access panels, explosion doors, handhold doors, 

maintenance panels, gear covers, bearing covers/retaining plates, 

as necessary to remove oil. Visible oil should be removed from all 

internal components. The surrounding and support structure 

should be made accessible for inspection, especially the area under 

the engine. At least one main bearing should be opened to 

determine if the design allows oil to be trapped, thereby indicating 

whether all bearings should be opened and cleaned. 

 Fuel System: All fuel system components should be cleaned or removed from 

the engine. These include injectors, carburetors, supply, 
75

distribution and return lines, filters, pumps, relief valves, pressure 

regulating mechanisms, governors, and heat exchangers. Removal 

of these items will prevent fuel seepage from their connections. If 

these items are to be sunk with the vessel, they should be opened, 

cleaned, and prepared for inspection. 

 Lubricating Lubricating oil sumps should be drained and opened for 

 Oil System: cleaning and visual inspection. This may require that additional 

 access openings be made. All lubricating oil piping, both internal 

 and external to the engine, should either be removed or drained. 

 Lubricating oil system components should either be cleaned or 

 removed from the vessel. Internal oil gallery plugs should be 

 removed. Pedestal and thrust bearings should be drained. Engine 

 driven oil pumps should be pulled or cleaned. Engine oil filling 

 and dirty oil drainage arrangements should be removed or cleaned. 

 

 Other Systems: Other components and systems susceptible to contamination with 

 fuels, oils, or greases (e.g., superchargers, turbochargers, air filters) 

should be examined visually and cleaned if they are present. 
76

REFERENCES 

Delaware Department of Natural Resources and Environmental Control’s (DNREC) 

 Program Summary and Endorsement of NYC Transit’s Plan to Use Subway Cars as 

 Artificial Reef Material. 2001. 

Environment Canada. 1998. Cleanup Guidelines for Ocean Disposal of Ocean Vessels. Artificial 

 Reef Society of British Columbia website. 

 [http://www.artificialreef.bc.ca/ARresources/cleanup_guidelines.html] 

Environment Canada. 1998. Cleanup Standards for Ocean Disposal of Vessels. Artificial 

 Reef Society of British Columbia website. 

 [http://www.artificialreef.bc.ca/ARresources/cleanup_standards.html] 

Lukens, Ronald R. 1997. Guidelines for Marine Artificial Reef Materials. Final report of the 

Artificial Reef Subcommittee of the Technical coordinating committee Gulf States Marine 

Fisheries Commission. 

 [http://www.gsmfc.org/pubs/SFRP/Guidelines_for_Marine_Artificial_Reef_Materials_January_1997.pdf] 

London Convention. Revised 2003. Waste-Specific Guidelines for Vessels Proposed for 

 Disposal at Sea (Waste Assessment Guidelines for Vessels). 

 [http://www.londonconvention.org/documents/guidelines/4%20-%20Vessels.pdf] 

OSPAR Commission. 1999. OSPAR Guidelines on Artificial Reefs in relation to Living Marine 

Resources. OSPAR Convention for the Protection of the Marine Environment of the 

North-East Atlantic. (Reference Number: 1999-13). ANNEX 6 (Ref. Section 3.24). 

San Diego Oceans Foundation, Marine Technology Society, and the Artificial Reef Society of 

 British Columbia. 2000. Proceedings from Artificial Reef Conference: Converting 

 Unused Ships and Structures to Enhance Ocean Environments. San Diego, 

 California. 

Telephone conversation with Captain Spencer Slate, ex-USS Spiegel Grove vessel-to-reef 

 project co-manager. April 17, 2006. 

U.S. Department of Commerce. 1985. National Artificial Reef Plan. NOAA Technical 

 Memorandum NMFS OF-6. National Marine Fisheries Service. Washington, D.C. 

U.S. Department of Commerce. 2002. Draft National Artificial Reef Plan (February 2002). 

 NOAA, National Marine Fisheries Service. Silver Spring, Maryland. 

U.S. EPA. 2000. A Guide for Ship Scrappers: Tips for Regulatory Compliance. 

 EPA/315-B-00-001. Environmental Protection Agency. Washington, D.C. 

U.S. Navy. Material Management for Radioactive Items in the DoD. DLA INST 4145.8. 
 

U.S. Environmental Protection Agency U.S. Maritime Administration 

EPA842-B-06-002 

May 2006