I agree with the guys above, at close range all penalties should diminish, maneuvers, cloudy weather, all those things mean nothing when the shell travel time is <1sec and you could aim over open sights. For secondary guns <600m, it should be around 70% to hit, not 20%(at best). Torpedo boats are literally unstoppable in 1890, both my own and my enemy are always able to deliver their torpedoes, reload and come back again.
I had a situation where a torpedo boat had 3x engine damage, rudder, etc... essentially dead in the water but was generating a -70% to hit (enemy maneuvers). Sinking it took twice as long as it did 2x enemy CA.