228 



smooth cargo tank Itottora resulting from a double bottom design should elimi- 

 nate sludge build up and. thus, the need to clean cargo tanks to iireveut this 

 occurrence; and, (b) when tanks are cleaned to prepare for dry docking and 

 overhaul, less wash water will be required for cleaning because of the elimina- 

 tion of structural members within the tanks. 



The complete environmental advantage of a segregated ballast/double bottom 

 system over load-on-top method (Regulation 15) or shoreside disposal (Reg- 

 ulation 20), is, we believe, beyond question, and is extensively documented in 

 the Coast Guard's own studies. See United States Coast Guard, Reports on 

 Parts 1 and 2 of Study I: Segregated Ballast Tankers (November, 1972 and 

 February, 1973). Neither load-on-top procedure (even v^'ith elaborate oil con- 

 tent monitoring devices) nor shoreside disposal is an acceptable alternative to 

 segregated ballast/double bottom design. To sanction the u»e of ioad-on-top 

 procedure as an alternative would amount to nothing more than the mainte- 

 nance of the status quo. This procedure, even in accordance with Regulation. 

 15, will by no means eliminate oil discharges during deballasting operations, 

 and, at best, it is only 80% effective in removing oil from overboard discharges. 

 As the Senate Commerce Committee noted in its Report on the Ports and 

 Waterways Safety Act of 1972. load-on-top procedure has, 



"Obvious, inherent shortcomings . . . first, the rolling action of a ship 

 in a seaway is not conductive to proper separation. Second, existing oil 

 water separators have generally proven inadequate for tanker ballast oper- 

 ation and even potential improvement in the technology of oil water sepa- 

 rators would certainly not seem capable of coping with the various oils 

 carried by tankers that have specific gravities close to that of water. 

 Third, the economic or geographic features of a particular trade may not 

 allow sufficient time for a tanker operator to fully utilize the load-on- 

 top procedure and, since a procedure rather than a design is involved, 

 it is subject to de facto violations on a case by case basis." S. Rept. No. 

 92-724, 92nd Cong., 2nd Sess. (1972). 

 Similarly, shoreside reception facilities, unless subject to stringent discharge 

 standards which are adequately policed and enforced, may merely transfer 

 marine pollution problems to the shore, and, in fact, concentration of oil pol- 

 lution in a specific shoreside location may be more harmful environmentally 

 than regulated discharge at sea. Further, their creation may create substan- 

 tial land use problems and have serious secondary impacts on the areas in 

 which they are located. Finally, at present, the state of the art may not be 

 sufficiently developed to indicate the type of shoreside facility best suited en* 

 vironmentally for each port. Especially as Regulation 20 is currently drafted, 

 with no provision for the standards which would govern operation of shore 

 side facilities, it can scarcely be considered an adequate alternative to segre 

 gated ballast design.^ 



Given the environmental advantages of the segregated ballast/double bottom 

 design, and the purpose of the Convention to eliminate operational pollution, 

 we believe that such a design and construction standard should be made manda- 

 tory on all oil carrying vessels. Thus, in our view, the bracketed tonnage limita- 

 tions in Regulation 11, para. 2, are far too high and wholly without justification. 

 The Coast Guard studies referred to above have demonstrated that a segregated 

 ballast/double bottom approach is cost effective down to ships as small as 20.000 

 dead weight tons.^ In point of fact, because load-on-top operations may not be 

 able to be engaged in on smaller tankers, because, if such operations are engaged 

 in, they may be relatively ineffective, and because smaller tankers carry cargoes 

 of higher toxicity and often enter shallow, crowded harbor areas, applicability 

 of the segregated ballast/double bottom requirement to such vessels is environ- 

 mentally necessary. 



Not only do we believe that the double bottom/segregated ballast standard 

 should be imposed on all ships, but we believe that the Convention should require 

 application of this standard as soon as possible after entry in force. Recognizing 

 that some lead time may be appropriate in the shipping industry to design and 

 produce a new ship, it would api)ear that the three year delivery requirement 

 suggested in Regulation 1(5) (b) to Annex I should be the outside limit, while 



=" Needless to sa.v, the supKestion in footnote 32 that In-port disposal he eonsldered, In 

 every case, as a complete alternative to secrecated ballast, is completely unacceptable. 



* That the requirement Is feasible on smaller ships Is demonstrated by the fact that. In 

 the United States. Intermediate and handy size tankers are beinc constructed, for Aeron 

 Marine Shipping Co., and Chevron Marine Transport Co., respectively, with such features. 



