Strafford Morss, Preservation Engineer
September 25, 1994

A. The Secretary of the Interior's:

1. Brief history:

1. September, 1985 preparation started at conference on maritime preservation hosted by National Park Service at National Maritime Museum, Fort Mason, San Francisco

2. May, 1990 STANDARDS issued by National Maritime Initiative, National Park Service

2. STANDARDS inspired by and follow format of Secretary of Interior's Standards for Historic Preservation Projects
1. STANDARDS not a manual for maritime preservation

2. Defines "ideal maritime preservation practice" through Standards and suggests ways of achieving through Guidelines

3. Arrangement of STANDARDS
1. Definitions

2. Standards

1. 8 General Standards
2. 2 Specific Standards each for,
1. Acquisition
2. Protection
3. Documentation
4. Stabilization
5. Preservation
6. Rehabilitation
7. Restoration

3. Process of Historic Vessel Preservation

1. Discussion from Planning to Interpretation

2. Final item: Approach to Treatment--Preserving Integrity

1. "Absolute requirement that vessel be kept structurally sound, weather resistant, and- -watertight... preservation of all historic fabric in vessel... impossible"

2. Personal Comment: Preservation safety valve:

1. License to steal: No
3. Guidelines
1. Acquisition
2. Protection
3. Documentation
4. Stabilization
5. Preservation
6. Rehabilitation
7. Restoration
8. Interpretation

B. Working with the STANDARDS

1. Cost Considerations

1. Historic naval vessels unique: much larger and more complex than civilian sisters

2. Recent warship project costs have run from $180,000 USS PAMPANITO (submarine), $1.465 million USS KENNEDY (destroyer), to $20.9 million USS TEXAS (battleship)

3. KENNEDY and TEXAS were able to accomplish stabilization and preservation; TEXAS also added some restoration in other areas

4. Tremendous challenge to find resources to stabilize, upgrade, or replace deteriorating physical assets

1. Strategy: put off day of reckoning; minimize hemorrhage of physical deterioration

2. Examples

1. KENNEDY, 1986-87
1. Cost dictated use of doublers instead of shell inserts; doublers of mild steel, not the alloys used in hull or deck; seal welding leaking rivets not installing new rivets

2. Contrary to Standard 6: historic fabric not replaced by: new material of same composition; material of same size; methods of replacement historically appropriate to vessel

3. Standard 6 effectively superseded by Stabilization Standard 9: "Stabilization shall reestablish structural integrity of vessel through reinforcement of structure... Stabilization shall also reestablish weather resistant conditions... and watertight integrity for a vessel afloat"

2. TEXAS, 1988-1989

1. A technical decision to use a plate thickness retention criterion less conservative than Navy practice, generated a technical requirement that resulted in using a lighter shell plate contrary to General Standard 6. The Project worked under Stabilization Standard 9
1. Using Navy practice would have required replacement of very much more than the 14,100 ft2 of shell plating actually replaced. Cost considerations rendered a decision of that type unthinkable.
2. Riveted hull structure was considered
"Distinctive techniques or examples of craftsmanship", General Standard 5.

1. New rivets were priced at $77 each; seal welding rivets at $10 each

2. Replacement plate layout was such as to save historic joggled plate riveted seams

3. Saving seams was shown to seriously interfere with making a tight joint

4. Later plate work changed the joint design to all welded: thousands of rivets that would have been loosened and seal welded by the original procedure were eliminated.

5. Cost considerations, and practicality, drove the project from General Standard 5 to Stabilization Standard 9.

1. Seal welded rivets totaled about 43,000

3. The STANDARDS were not issued during the time I was with either project

1. Texas staff historians, trying to apply the earlier Standards for Historic Preservation Projects in accordance with State Historic Preservation Officer's normal requirements for administering a Federal Grant of $5.08 million, were adamant that historic fabric, construction techniques be saved in situ. It took a long time, and very large shipyard change orders, to bring reality home.
4. In my opinion, the STANDARDS are workable
1. The implementing Guidelines require considerable updating to list and conform to more recently issued mandatory Federal requirements in various areas. "Recommended" in these areas is no longer appropriate
5. For 7306 ships, the Donation Agreement with the Navy takes precedence over the STANDARDS
1. Applicant agrees to maintain vessel at its own expense in a condition satisfactory to the Department of the Navy, in accordance with instructions that may be issued, and that no expense shall result to the United States

2. The Navy requirement is the reason that 7306 ships appear to violate many of the STANDARDS requirements and many fundamental museum-type practices

C. Regulatory Requirements and the STANDARDS' Guidelines

1. The Flag, apple pie, motherhood, and memorial/museums

1. Historic ships are industrial enterprises and are regulated as such

2. Violations of Federal Regulations are Federal Crimes

1. Recent Enforcement Actions have included fines and substantial prison terms: either or both combined

2. Some, but not all, areas of concern for the historic ship

1. Oil
2. Confined Spaces
3. Asbestos
4. Lead

3. Oil

1. Pollutant and hazardous waste

2. Certificate of Financial Responsibility for

Pollution Liability (33 CFR 130)

1. Administered by U.S. Coast Guard

2. Applicable to all waterborne craft 300 GRT and over navigating U.S. and international waters

3. Permanently moored museum ships exempt, unless

1. Transferring oil to or from ship 2. To be moved in navigable waters
3. 33 CFR 130 defines scope, how to apply, financial responsibility, fees, enforcement, and service of process
1. $10,000 fine for each violation

2. Coast Guard denies movement or vessel operation in navigable waters of United States

3. Oil spills covered by 40 CFR 300 (Superfund)

1. Planning for spills
2. Response to oil spills

4. Confined Space Entry

1. Worker killed aboard TEXAS 2/17/89 opening and entering an empty tank before certification

2. Two Standards apply

1. NFPA 306, latest edition, Control of Gas Hazards Aboard Vessel

2. 29 CFR 1910.146, Permit-Required Confined Spaces for General Industry.
Comment: Owner/operator and contractor Share responsibility for permit-required confined space entry program

3. OSHA issued a confined space shipyard rule on July 25, 1994 to go into effect October 24, 1994

1. Rule had been in works since 1988

2. Rule applies to all shipyard-related activities, not just work aboard ship

3. Read Regulation

5. Asbestos (29 CFR 1910.1001)

1. Classified as Poison

2. Read Regulation

6. Lead

1. Poison

2. 29 CFR 1910.1025- General Industry Standard

3. 29 CFR 1926.62- Construction Industry Standard

4. Read Regulations

1. Effective 2 August 1993
2. OSHA will enforce any operations disturbing lead paint under 1926.62

7. Think about your volunteers: they like their own projects and like to explore the ship's interior

1. The Law, and lawyers, say you are responsible for protecting them as well as your other employees

2. Signed releases from volunteers are only useful in the head/latrine. There are significant numbers of other people who will claim an interest in an injured volunteer and can sue.

8. The CFRs as noted will change, and you will have to change when they do.

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