The Coulombi Egg tanker was approved by the IMO September 1997. Immediately afterwards USA via USCG admiral Kramek declared that no Coulombi Egg tanker would be allowed in the USA!
The Coast Guard Authorization Act of 1998 however mandated the Secretary of Transportation to commission the Marine Board of the National Research Council's (NRC) Transportation Research Board (TRB) to develop a rationally based approach and method for assessing the environmental performance of alternative tanker designs relative to the double-hull standard.
The result was Special Report 259 'Environmental Performance of Tanker Designs in Collision and Grounding: Method for Comparison' issued by the Transportation Research Board. It can be read here!
The Coulombi Egg tanker had previously briefly been discussed at the US Congress.
Under the auspices of the Marine Board, the NRC convened an 11-member Committee on Evaluating Double-Hull Tanker Design Alternatives with appropriate scientific and technical expertise in risk assessment, tanker design, tanker operations, crashworthiness of ships, and costs and damages (including environmental damages) related to oil spills. The recommendations of the committee are at the bottom of the page. Heiwa Co supports all recommendations. Soon the COULOMBI EGG tankers can sail to the USA!
The committee as a whole met five times between June 1999 and January 2001, and subgroups met periodically throughout that time. The early meetings included extensive presentations in sessions open to the public, during which experts from government, academia, and industry described a variety of issues and views for the committee. The final report represents a synthesis of the information gathered by the committee, which encompassed the data, analytical tools, and simulation methods currently available for the development of a rationally based approach for assessing the environmental performance of alternative tanker designs relative to the double-hull standard. Unfortunately Heiwa Co was neither informed about nor invited to any sessions of the committee.
Committee members had extensive experience in the day-to-day operations of all relevant technologies, as well as in the overall analysis of operations and risks and in systems management.
The 11 members of the 'Committee on Evaluating Double-Hull Tanker Design Alternatives' were:
Kirsi K. Tikka, Chair, Professor of Naval
Architecture, Webb Institute, Glen Cove, New York
They were assisted by the following Transportation Research Board Staff:
Beverly M. Huey, Study Director, Transportation
Sponsoring Liaisons persons were:
H. Paul Cojeen, Chief, Naval Architecture
Division, United States Coast Guard, Washington, D.C.
Other Agency Representatives were
David Chapman, National Oceanic and Atmospheric
None of the above has ever contacted Heiwa Co to find out the latest developments about the only alternative design approved by the IMO as per Marpol I/13F(5) - the COULOMBI EGG tanker - from its designer and developer. However, Heiwa Co thanks them all for a good job done. It is the beginning of the approval of the COULOMBI EGG by the USCG.
Below follows a review of Special Report 259 'Environmental Performance of Tanker Designs in Collision and Grounding: Method for Comparison'.
U.S. law (OPA90) allows for the evaluation and approval of alternative designs that can be determined to have equal or better performance than the double hull in protecting the environment. To date, however, the United States Coast Guard (USCG) has not made that determination for any alternative design as no American methods exist. Therefore the COULOMBI EGG tanker design has not been reviewed by the USCG. The International Maritime Organization (IMO) rule Marpol I/13F mandates two equivalent designs - double hull design and the mid-height deck design and may approve alternative design under Marpol I/13F(5). The only such approved design is evidently the COULOMBI EGG oil tanker 1997, developed by Heiwa Co. The U.S. of A has not adopted Marpol I/13F. Heiwa Co believes that U.S. technical regulations regarding oil tankers should be more consistent with international law (Marpol I).
The U.S. Congress requested that the study under review be undertaken by a committee under the auspices of the Marine Board of the National Research Council's (NRC) Transportation Research Board to determine whether a methodology could be established for measuring the equivalency of alternatives to double-hull designs with regard to environmental performance. Congress made this request through the USCG Authorization Act of 1998, but specified that the investigation be conducted independently of past USCG policy on double-hull equivalency (even if many of the committee members had participated in previous investigations). The committee was charged to develop a rationally based approach for assessing the environmental performance of alternative tanker designs relative to the double-hull standard. The proposed methodology was then to be applied to double-hull tankers and alternative designs (e.g. the COULOMBI EGG ) to demonstrate that it could be used for an assessment. This was a good start - but the committee never applied its methodology to any alternative design. The USCG has not approved any alternative design, but the IMO has - the COULOMBI EGG tanker 1997. Why didn't the committee use the COULOMBI EGG design in its study?
The committee was asked to ensure that the proposed methodology would be applicable to conditions prevailing in U.S. waters. The committee's charge also included refining and adjusting existing tanker damage extent functions used for measuring the crashworthiness of tank vessel structures. In addition, the committee was to develop a generalized spill cost database and use this database in formulating a rationally based approach for the calculation of an environmental index. This is all very good.
It is stated in the report that a number of organizations have submitted proposed alternatives to double-hull designs to either the USCG (for the United States) or IMO (representing the international community), both of which have developed regulations addressing minimum tanker design standards.
As far as Heiwa Co is informed only one alternative tanker design has been submitted (1995) to the IMO for approval - the COULOMBI EGG tanker - and approval was granted 1997. No other design has ever been submitted to the IMO 1995-2002. The alternatives referred to are generally fanciful oil tank designs, which cannot realistically be incorporated in a real oil tanker - access, cleaning, ventilation, maintenance and safety, etc. of the ship are not considered.
The committee believes that the COULOMBI EGG design was proposed by the Swedish government (sic), but the Swedish government had nothing to do with the COULOMBI EGG design. A designer and developer of an alternative design must only ask one nation (full) member ot the IMO to sponsor the application at the IMO. The designer/developer must self prepare all the approval work. In this case the acting director Roger Sundström of the Swedish National Maritime Administration - Sjöfartsverket - asked - or proposed to - the designer (Anders Björkman) 1994 that Sweden should sponsor the application at the IMO. In fact Egypt had already agreed to sponsor it 1992, but it was agreed that using Sweden was easier - the original application could be in English in lieu of Arabic (both languages are however working languages of the IMO but the former is more used).
The writers of the report - the committee - state that several other concepts have been developed in the United States. However, none has been submitted to the IMO for formal assessment and possible approval and the committee does not wonder why. The reason is that the COULOMBI EGG design is no. 1! INTERTANKO concluded the same thing already in 1992.
The report correctly says that the IMO method of comparing designs is based on a formula that assigns relative weighting factors to three outflow parameters related to spill size (zero, mean, and extreme outflow) and that use of these weighting factors was based on IMO's decision to select a formula that would ensure the equivalency of the double-hull and mid-deck designs. This may be so. In reality the mid-deck design provided better collision protection than double hull (fewer spills) and had much lower total outflows in groundings (but more smaller spills) - the formula was a compromize. The IMO methodology uses historical distributions of ship structural damage of single hull tankers which were thought to be representative for double hull and mid-deck tankers and alternative designs built of steel. Designs based on innovative structural concepts would be given special consideration. However - in order to get approved - any alternative, new design has to virtually spill no oil at all in any accident - and this the COULOMBI EGG tanker achieves using an innovative arrangement of normal steel structure. You do not have to develop an innovative structural concept to eliminate spills - locate the cargo in a safe location (based on damage statistics) or so that it does not flow out in accidents and the problem is solved. Evidently conventional steel tanker structure should be used.
The committee has successfully tried to establish a methodology for comparing the environmental performance of alternative tanker designs by the development of a new approach. The methodology developed by the committee is divided into three main components: (1) structural damage and oil outflow calculation, (2) consequence assessment, and (3) design comparison. This is very good. It is old fashioned COULOMBI EGG tanker basic design concept.
For the first component, the committee selected scenarios (collision and grounding events) that represented conditions in U.S. waters, specifically in those areas with a high density of tanker traffic. It should have included explosions and fires also, but they might be too difficult to assess. Once the collision and grounding events had been identified, the committee used damage models to determine the structural damage and resulting outflow in each accident.
The second component of the methodology involves the assessment of consequences from an accidental spill. The committee used an environmental impact model that predicts oil fate and transport, and allows for random sampling of weather conditions on the basis of historical weather data. This model provides a number of physical consequence measures, such as the area of the sheen, the toxicity in the water column, and the length and area of oiled shoreline. The committee decided to limit the assessment of consequences to these physical measures instead of extending it to impacts on biological resources. Doing so would keep the analysis as systematic and well specified as possible without necessitating difficult decisions as to what threshold levels would damage biological resources and how those resources are valued.
In addition to the physical consequence measures, the committee considered several non-environmental measures of consequence, including spill cleanup and response costs, the value of lost product, and third-party damages. These measures were eliminated from the final analysis for several reasons. The value of lost product, measured on a per gallon basis, is not expected to vary significantly with spill size. More important, the collective best judgment of the committee was that the physical consequence metrics used in the analysis are reasonable proxy measures for likely third-party losses and cleanup and response costs.
The final component of the methodology involves the comparison of two designs.
By subjecting each design to the same set of accident scenarios, one can directly compare the resulting performance of the designs for each scenario. Since the relative impact on the environment can be assessed for each design, the better-performing design is evident for each accident scenario. All this is also very good.
But then the committee study in the report went a little wrong. The committee prepared two examples to demonstrate the application of the methodology and perform an initial test of its validity. Both examples involved comparing the performance of a double-hull design (with many small cargo tanks) with that of a conventional single-hull design (sic) with a normal number of cargo tanks - but maybe not optimally located ballast tanks! One example used vessels with a 150 000-deadweight ton (DWT) capacity and the other vessels with a 40 000-DWT capacity design. The apparent reason for this was that none of the alternative designs proposed to USCG was available to the committee in sufficient detail (sic) to be used in the examples.
Why the IMO mandatory design - mid-deck - and the only IMO approved alternative - COULOMBI EGG - was not used is unclear. Nobody asked Heiwa Co to provide the details. Why use a conventional single hull design, that is phased out, for the demonstration? The COULOMBI EGG tanker is also single hull - it is damaged exactly as a conventional single hull tanker - the only difference is that no oil spills!
The committee selected four case study locations in U.S. waters: Big Stone Anchorage (Delaware Bay), Galveston lightering area (Gulf of Mexico), Carquinez Strait Bridge (San Francisco Bay), and Farallon Islands (Offshore San Francisco). These locations have large volumes of tanker traffic, and adequate oil spill modelling data are available for each. These four locations also demonstrate sufficient variation in site characteristics and conditions to provide an adequate test of the components of the methodology. The committee ran a total of 80 000 accident scenarios (10 000 collision and 10 000 grounding events) for each of two designs (conventional single-hull and double-hull) of the two different sizes (150 000 and 40 000 DWT).
To determine environmental consequences for these events, the committee conducted a separate analysis and generated a set of consequence functions for the necessary range of oil outflows, also considering such factors as weather, oil types, and geography for the selected locations. With four sites, 200 weather events, two oil types (crude and product), and seven spill volumes, a total of 11 200 spills was simulated in the models used. The seven spill volumes were chosen to represent the full range of possibilities.
The consequence functions selected by the committee represent ratios of the environmental consequence for a spill of a certain size to that for a 500 000-gallon reference spill. The consequence function is not linear. That is, for spills smaller than the reference spill size, the consequence for each gallon spilled is relatively greater than for the reference size, and that difference continues to increase as the spill size decreases.
The opposite is true for larger spills. For example, for a spill of 100 times the reference size (a spill of 50 million gallons) the environmental consequence function would be only about 8 times greater. To test the validity of this result, the committee also conducted several sensitivity analyses--for different oil types, different case study sites, and different consequence metrics. These analyses provide upper and lower bounds for the consequence function graph and can be used to make the final design comparisons more accurate and complete.
Each of the 80 000 outflows was converted to a consequence measure, relative to the 500 000-gallon spill equivalent. By calculating and analysing the differences in this measure across the scenarios, one can determine the relative performance of two designs. However, this is not meant to be predictive of environmental consequences for any specific spill.
The double hull tankers (with many small cargo tanks) evidently spillt less oil in fewer spills and caused much less (20 times!) total damages in economical terms (in U.S. waters) than the conventional single hull tanker (to be phased out). Small spills evidently cost less to mop up than big spill, but small spill scost more per gallon to mop up than big spills.
It would have been very interesting to know the result of a comparison double hull versus an IMO approved, alternative design, i.e. mid-deck or COULOMBI EGG. The two latter perform much better in collisions and it would have been interesting to know the savings in money terms. In groundings the two alternative designs rely on hydrostatic loading to reduce spill volumes and the USCG has suggested that it is not good enough - due to the U.S. Clean Waters act (sic)! But the Clean Waters Act also apply to collisions! With the new methodology the real groundings costs can be estimated. Are the costs for many small spills due to hydrostatic loading of tankers higher compared with the rare grounding spills from double-hull? And if so - is the extra damage grounding costs for approved alternative designs in excess of the saved costs in collisions?
The study only involves U.S. cleaning-up operations - it would be interesting to know the relative costs to clean up spills in, e.g. Europe, Singapore and Japan, and it should be considered in an overall evaluation.
It is interesting to note that the cause of the latest, well-published spill had nothing to do with collision or grounding (or fire and explosion) - the 'Erika'. The proximate cause is still unknown - heavy weather, structural fault, faulty cargo loading? Who knows? But an alternative design that performs better in heavy weather and with more redundancy against structural faults and faulty cargo loading than double-hull should be credited. What will happen when the next 'Erika' accident occurs outside the U.S - with a double hull tanker?
Since the committee did not attempt to determine the likelihood of any of the scenarios actually occurring, the analysis cannot be used to determine the real savings that might accrue to use of a particular design in a given time period. The latter is a very different and more difficult problem that would require a detailed risk analysis of a specific port area with defined operations and traffic patterns. This is the type of analysis that would be required, for example, if one wanted to determine whether the additional costs of an alternative design were justified, the Committee concludes this part of the study.
The interesting thing is that COULOMBI EGG probably costs less than double hull to build - and maintain - no extra costs!
The committee developed a rationally based approach for assessing the performance of alternative tanker designs on the basis of their relative ability to prevent environmental damage from oil spills following collision and grounding accidents. This methodology can be used as a tool by regulatory authorities in determining whether to approve an alternative to the double-hull tanker design. This is extremely good.
First, however, a few other things need to be accomplished, the committee concludes: (1) peer review of the methodology; (2) testing of the methodology; and (3) a comprehensive review of the methodology by stakeholders, including the tanker industry and environmental groups, as well as regulatory, oversight, and review organizations. The methodology is a significant improvement over existing methods; however, it needs further refinement to enhance its accuracy and reliability.
This writer agrees fully (even if nothing seems to have been done since the report was issued and nobody ever informed the writer about developments). Even if the COULOMBI EGG tanker is already approved by the IMO, a new review according to the new methodology can only confirm that the COULOMBI EGG tanker is the superior design.
Based on its work, the committee makes the following recommendations, left, in the report with Heiwa Co comments right.
The committee understands that to implement all of its recommendations will require substantial time and effort on the part of the USCG, but has neither estimated the cost involved nor determined whether the USCG has the necessary resources available.
Therefore, the committee cannot propose an appropriate schedule for the recommended tasks, nor can it set priorities for this work relative to the USCG's other responsibilities.
The committee does, however, believe that the work presented to illustrate the proposed methodology provides a foundation that can be used by the USCG in its implementation efforts.
The COULOMBI EGG is fully approved under Marpol I/13F and its current guidelines and will naturally continue to excel using any other guidelines or methodologies. The reason is simple - the COULOMBI EGG was developed 1989-1995 based on the thinking of the TRB committee 1999-2001. It is sad that the committee does not make any reference to this well documented work in its report. And it is time that the USCG seriously studies the COULOMBI EGG tanker - all the relevant information for approval is available since 1995. The USCG work should evidently start with the only alternative design approved by the IMO - the COULOMBI EGG tanker.
Heiwa Co invites students at U.S. universities and other interested parties to apply the committee's methodology to compare the COULOMBI EGG tanker design with the double hull. The relevant computer programs are available in the U.S. and the application could be used as a graduation thesis or part of a research program. USCG should support such work. Heiwa Co looks forward to the day the USCG approves the COULOMBI EGG and reports it to Congress and the Secretary of Transportation. The U.S. deserve the best tanker design - the COULOMBI EGG !
In spite of above, 2016, USA still do not accept the Coulombi Egg tanker. The reason is very simple. Just ask me and I will tell you.