Thanks, for input,
I still can't explain why this top coat is flaking off above the waterline.
If the paint was not applied correctly ( drying time, or substrate) than why is the paint below the water line is not flaking off and doing ok. You don't apply paint above and below the waterline differently. There is something different about the exposure to air and water interface that appear to be causing flaking .
wave action (or constant wetting and drying) is a possibility but I would have expected this would be a common problem with ablatives ..... but it isn't.
Perhaps the top paint layer which is exposed directly to sun is resulting in a overheating of the top layer causing it the loose adhesion from the underlayer. Below the waterline the heat is dissipated and constant and paint adhesion is fine. This would indicate that differences in paint color may affect the adhesion properties above the water line. That is , the color black (a high heat absorber) should not be appied over blue layer and result in heat differential in the layers and flaking ..
ok , just a far out idea.