Measuring Oil Content

Accepting that the term "oil" lacks specificity, we should accept that oil content measured can only be a reference and not a scientific value.

Scientific measurement of hydrocarbons can not be done on line, as it generally requires some kind of extraction method. A scientific instrument would be too complex for marine installation and could not analyze the effluent within the time constraint imposed by MARPOL for bilge water processing.

The solution MARPOL Annex I provides is both practical as well as reasonably accurate,and it prevents pollution from oil.

Since "oil" as used on ships covers quite a range of hydro-carbon chains, as well as oils from various origins, there is currently not one single accurate way to determine oil content expeditiously enough to use for continuous in-situ operation as is required for bilge water. Therefore Annex I does two things, it accepts that oil is a reference term and allows for reference measurement of oil content.

Today there are basically two measuring principles used. One is light scattering, the other fluorescence. None of the meters in use today, old or new, measure oil; they measure the effect of oil in the water on the light used in the analysis.

The "accuracy" of the meters has increased over the years, because IMO changed the reference mixtures used in the approval process, to better mirror real-life-bilge-water.

In the approval process the oil content meter is "calibrated" with simulated bilge water that has a known oil content. The meter is calibrated so that the meter reading corresponds to the ppm level of the sample water. The meter is not calibrated to read the oil, rather the meter is calibrated to the optical effect of the sample water.

That this is understood by the administrations is reflected by the fact that in a port state control situation, the accuracy of the meter is verified by the approved manufacturer's method rather than verification of the hydrocarbon content of the effluent in a lab analysis.

Oil and Regulations

The simple term of "oil" the oil pollution regulations, suggests that the regulations are precise. Actually, they are not, because the term oil lacks specificity.

In the oil pollution regulations, discharge of treated bilge water from machinery spaces is authorized, as long as the effluent quality is better than 5 or 15ppm oil content limit. That suggests something pretty specific, but is it?

Let us first look at "oil", what are we talking about? On a ship we are talking of fuel oil, lube oil, hydraulic oil, etc.

• In fuel oil we have a wide range of hydrocarbon chains, as it is generally a blend of residual with various cutter stocks;
• Lube oil is a complex blend of hydrocarbons plus detergents and additives, required for the job;
• And on goes the list with synthetic oils, bio oils, etc

All this to say that oil is not something defined, it is a summary expression for a range of hydrocarbon chains, meaning from the light fractions all the way to the heavy fractions in the refining process, singularly or in combination.

The absence of specificity on the term oil is not really the problem, the problem comes when attempting applying scientific limits to the determination of the oil content.

To be continued...

USCG and MARPOL Annex I

In 2008 the USCG carried out over 11,500 Port State Control exams. 18% of all deficiencies were related to Marine Pollution, with 69 MARPOL detainable deficiencies. In 2008 the USCG did 12 criminal referrals, the majority of which were MARPOL Annex I related cases. Virtually all USCG districts are represented, and the US Department of Justice handed out fines totaling about $20 million.

That was in 2008. This year the US House of Representative passed a bill allowing for an increase in USCG personnel by 1500 persons. At the same time USCG put in place a policy to improve the level of proficiency of the USCG port state control officer.

The above suggests that the capabilities and efficiencies of US port state control are improving and will continue to do so in the coming years. We suggest that ship owners and managers should look seriously at ensuring their crews are well trained, the records well kept and equipment adequately funded to reduce the risk of a port state incident.

The USCG states that they will not recommend criminal prosecution in case of a pollution incident, unless there is high level corporate involvement or willful blindness by management. USCG sees "willful blindness" in inadequate engine room budgets and spare parts availability.

The USCG has a clear plan on how to find polluters; the US DoJ has a clear perspective on how to deter polluters from polluting again; they are not doing this by the "seat of their pants". Shouldn't you have in place a "compliance management system" for "due diligence"?

The Benefits of Marine Transport

At this year's Global Greenship conference in Washington, DC, Andrew Riester of the Waterways Council, Inc. presented a summary of a paper, which the US National Waterways Foundation had co-sponsored. The Texas Transportation Institute did a "Modal Comparison of Freight Transportation Effects on the General Public", comparing US inland barge traffic with rail and road transport, which I believe can be used as a reference to the Eastern Canadian freight model, consisting of marine, truck ad rail.

According to the study, in the US 14% of intercity freight , valued at nearly $ 70 billion is transported on the inland waterways. I would guess, that the percentage of waterborne transport for Canadian inland waters is in the same range, if not nationally then regionally for the Great lakes St. Lawrence Seaway area.

What the study found was that a shift from marine to land based transport would double traffic on the Interstates and rail tonnage would increase 25%. To drive this point home, a hypothetical case study was done for St. Louis, assuming all marine freight there would shift to truck. In this scenario:

• Highway costs over 10 years would more than double
• Truck traffic on St. Louis Interstates would increase 200%
• Traffic delays would increase by 500%
• Injuries and fatalities on Interstate segments would increase from 36% to 45%
• Maintenance costs would increase 80% to 93%

I am wondering how the proposed ECA, if implemented for the Seaway System, would affect a mode shift from marine to land-based transport. The increase in cost from increased fuel costs will cause some shift in freight traffic from ship to truck or rail. With the traffic density already high on our highways, any additional trucks will cause an:

• Increase in Highway costs in the Windsor - Quebec corridor
• Increase in truck traffic
• Increase in traffic delays
• Increase in fatalities and injuries
• Increase in pollution from accidents

The ultimate question is then, how big is the net benefit of an ECA in the Seaway System?