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Negotiations Ongoing to Break Mothball Fleet Using 


Mare Island Dry Docks


California DTSC concerned over PCB hot spot


By Marc Garman

Talks between Lennar Mare Island, The City of Vallejo and CDDS (California Dry Dock Solutions LLC) were stalled until recently. CDDS is a subsidiary of Allied Defense Recycling of Texas. The firm proposes to dismantle the Suisun Bay mothball fleet using the dry docks on Mare Island. According to a source in City Hall, the project was at risk of being “killed” over requirements imposed by the California Department of Toxic Substances Control (DTSC), but a compromise is eminent.


According to CDDS spokesperson Jay Anast, the issue with DTSC is over PCB (polychlorinated biphenyl) contamination in the mud off dry dock #2. This area would require dredging. Anast cited a prior Navy report which indicated that the contamination began, “about 50 feet below water surface” and that CDDS only intends to dredge to a depth of 30 feet. “We will not be dredging near the 50 ft mark and therefore would not be disturbing it.”, said Anast, who continued to explain that his company would be testing dredge spoils prior to disposal in deep water on the far side of Mare Island. Testing of dredge spoils prior to disposal is required by the State of California.

The testing would cost CDDS approximately $120,000. “That's an economic risk we're willing to take.” said Anast who continued to explain that DTSC has been insisting on a “specific or discrete” testing process that would require a representative sample of the mud in the suspect area be taken every five feet in every direction to create a 3 dimensional map prior to any dredging taking place. The cost for this process would be in excess of $1million and at CDDS's expense whether the project moves forward or not. “It's like getting a safety report on a car just before you put it in the shredder.” said Anast explaining that the dredge spoils would have to be tested prior to disposal anyhow, and that the 3 dimensional map of toxicity in the area would become completely irrelevant once dredging took place.

When questioned about the impact falling metal prices might have on the project going forward, Anast explained that MARAD (US Maritime Administration) which oversees the project “takes into account metal prices and we bid on the project accordingly.” He added that “You can't break ships based on metal prices or you are doomed to fail.”

Regarding risks involved in towing the older and more fragile ships the six miles to Mare Island Anast indicated that he was confident that they could be moved without danger in calm weather, at a speed of two knots per hour and with the tide. He also added that it was not necessary to address flaking paint issues on the hulls for such a short tow.

It seems that CDDS is confident that breaking the mothball fleet on Mare Island is economically and logistically feasible provided they can finalize a compromise with DTSC. Both Lennar and The City are ready to move forward.

Such an operation would provide jobs and revenue, but raises environmental concerns. Of course, leaving the Suisun Bay fleet as it is also raises environmental concerns...especially as the older ships continue to decay and potentially sink thus multiplying the problem.

Aside from the issue of contamination in dredge spoils, the ships themselves contain a broad range of toxic materials that must be remediated. DTSC is not known to compromise unless they receive a push from the state or federal level. If they are willing to compromise now, will they be willing to compromise in the disposal of toxic materials from the ships themselves? Or are the DTSC requirements unnecessarily stringent as CDDS spokesman Jay Anast has indicated?

This article has certainly raised more questions than it has answered. VIB is attempting to contact DTSC in order to get additional perspective as well. So, consider this the first in a series as we further examine the issues, both negative and positive surrounding the re-use of the Mare Island dry docks for the task of ship dismantling.