Incident Investigation Lessons Learned: Alledged Pollution at El Dekheila, Egypt

Lessons learned

The Company has issued an investigation report on an alledged sea water pollution by a managed vessel at El Dekheila Port, Egypt on 29th December 2019.

 

BRIEF DESCRIPTION OF THE INCIDENT

On the 26th of December, 2019 at 14:00 hrs the subject vessel arrived at El Dekheila. The pilot boarded the captioned vessel on the 28th of December, 2019 at 15:42 hrs for berthing, which took place at 18:00 hrs alongside quay number 91 A at MIDOR terminal at El Dekheila port, for loading purposes.

On the 28th of December, 2019 at 20:00 hrs, the vessel’s Master issued a letter of protest that he observed carbon soot (black powder) floating at the seawater surface during and after the vessel’s berthing alongside MIDOR terminal quay # 91 A, as the terminal has been notified verbally initially followed by a written LOI which was later signed by the Terminal Representative.

On the 28th of December, 2019 at 20:00 hrs, the tanks inspection took place by Messrs. SAYBOLT (Terminal Representative) and the vessel's tanks were accepted for loading. Shortly thereafter, the loading operation commenced at 20:12 hrs.

On the 29th of December, 2019 at 17:00 hrs, the terminal representative / policeman boarded the vessel and informed the vessel’s Master verbally that the vessel caused pollution.

Immediately upon office notification by the ship’s Master on allegations made against the vessel on 29th December the P&I Club was advised and a local surveyor was appointed to investigate this allegation. The Deputy DPA also flew over the same night to attend the vessel.

At the time of our attendance on 29th of December, 2019 pm, the surrounding area of the vessel not clear for inspection due to insufficient lighting however the following were verified from his investigation:

  • The scuppers plugs which located at the deck sides' were in place, as we observed the save‐all plugs also in place.

  • The bunker stations were clean

  • Engine room, which found cleaned and tidy.

  • Overboard valves were sealed as the company implements an environmental tagging system

  • International oil pollution prevention certificate (IOPP), oil record book, the deck log extract, the oil spill kit, and the vessel’s SMPEP and other documentation were reviewed thoroughly and all found in order.

On subsequent visit on the following day (30th of December 2019, am) a visually inspection of the surrounding area of the vessel was carried out and no oil patches were observed surrounding the vessel as well as no traces of oil have been observed clinging at the vessel's hull.

Regarding the claim placed against the vessel by the Egyptian Environmental Agency (EEAA) and the allegations that:

  1. The inspection committee found multiple oil spots resulted from the mentioned vessel during washing the vessels tanks and being thrown into the sea;

  2. Through inspection it was found that the vessel’s crew threw chemicals to disperse the oil spots with three found; one of which in between vessel’s hull, one between the rear of the ship and quay 91/A and the third in next area and

  3. The committee failing to take samples due to chemicals through on the oil spots causing disperse

 The following are the investigation findings against these allegations:

  1. The claim of observed oil patches IWO the subject vessel due to cleaning of the vessel's tanks and discharging the cleaning residues into the seawater, is considered unsubstantiated due to the following facts:

  •  

    The subject vessel arrived at El Dekheila with empty cargo tanks.

     

  •  

    The cargo tanks were checked / measured by Messrs. Saybolt (Terminal representative) prior the commencement of loading on the 28th of December, 2019 to determine onboard quantity, as the OBQ report revealed to nil sounding which confirm that the subject tanks were empty, and then the vessel's tanks were accepted for loading on the same date at 20:00 hrs.

     

  •  

    The loading operation commenced on the 28th of December, 2019 at 20:12 hrs.

     

  •  

    On the 28th of December, 2019 at 24:00 hrs, all tanks loaded with a part of the assigned quantities.

     

  •  

    The committee attended at the terminal and carried out the inspection on the 29th of December, 2019 at 15:00 hrs, which was after about 19 hours of the vessel's loading commencement time.

     

    Basis on the above denied the possibility cause of the pollution is discharging the cargo tanks cleaning residues into the seawater.

  1. Apart of the above recorded that the de‐ballasting operation commenced on the 28th of December, 2019 at 22:30 hrs and was completed on the 29th of December, 2019 at 14:00 hrs, as the time of the completion of de‐ballasting was close to the time of the committee attendance, but the committee not claiming for existence of dirty water (incase that the ballast water was dirty) and claiming for existence of oil patches, which led us also to deny the idea that de –ballasting could be the cause of the reported pollution.

  2. The claim of the vessel using chemicals to disperse the oil spots is unsubstantiated as the committee never boarded the vessel to conduct sampling and or inspection has on board although repetitively requested by the Master, the attending P&I Surveyor, the Agent. During our inspection the SMPEP kit and equipment found intact and the actual quantities of the cleanup chemicals were as per relevant inventory.

Despite the above presented to APA / EEAA, the vessel was fined by Alexandra Environmental Affairs Agency for alleged pollution (260 square meters).

Also during our Deputy DPA inspection, there were some visual evidence indicating that the source could be the coal storage facility nearby. 

The subject departed on 31st December at 17:20 LT.

 

LESSONS LEARNT, EXPERIENCE TRANSFER

Even though theinvestigation is considered completed, the part of investigation is critical and active at all times. No limitation applies for this case to re-open if deemed necessary and further evaluation / actions to be taken if needed.

It is unfortunate for a new build vessel with less than three months in the water to be victimized and penalized for a pollution that was not caused from this vessel.

Particular attention shall be paid to below procedures when entering Egypt, and particularly if you find a polluted area, what is required in order to avoid being victimized:

Prior to Entering Port;

IWO E/R

  • Keep E/R floors and bilges dry & clean

  • Assure that all overboard are sealed with numbered seals, further, make sure that an entry(s) with seals numbers / valves are made to the E/R logbook & Oil Record book with proper dates

  • Assure that necessary instructions for OWS is properly posted, relative overboard valve is secured with instructions for not use is clearly displayed

  • Assure that not any unauthorized piping / connections are existing

  • Assure that enough free volumes are available in the dirty oil tanks

  • Keep the Oil Record Book updated with all quantities of bunkers, oils, sludge disposals are recorded and matching the existing situation

  • Keep all delivery receipts of sludge and dirty oil available

IWO Deck

  • Keep the ballasting record updated (sounding & operations)

  • Keep the forward and aft mooring stations and any other deck machinery (together with their related hydraulic stations if any) clean and dry

  • Keep all savealls clean and dray

  • Keep all deck scuppers closed

  • Assure that necessary posters are displayed IWO bunker and sludge stations

 Approaching Berth;

  • Lookout watch to thoroughly inspect the berth and seawaters IWO berth for any spilled pollutants

  • If any pollution is noted, the pilot and the port authority must be immediately informed, and entry to the logbook is made

  • To notify the Office (DPA/Operations Dept), P&I local correspondent and a LOP may be drafted and handled to the Agent (as necessary)

  • Photographing, as far as it will be possible, at time of approach, is to be conducted if any pollution is detected

During Staying A/S Berth; 

  • Deck duty officer / crewmember to report to master for any drifting polluted spot approach ng vessel

  • To inform port authority and entry to the logbook to be made if any pollutants spot drifted IWO vessel

  • To notify the Office (DPA/Operations Dept), P&I local correspondent and a LoP may be drafted and handled to the agent (as necessary)

  • Photographing, as far as it will be possible, at time of approach, is to be conducted if any pollution is detected

If any Port Authority and / or EEAA Representatives attended onboard; 

  • To identify those representatives (presumably, that the visitors book will be maintained properly for any attendants onboard). If it would be possible, master may receive a letter from them (even with handwriting), clarifying their mission onboard

  • To IMMEDIATELY notify the Office (DPA/Operations Dept), P&I local correspondent (by phone), if it would be possible, delay those officials until the P&I representative arrives onboard

  • Any samples must be collected in identified and sealed tanks and a statement with description of samples taken to be made in this regard and to be countersigned, however, they may refuse to sign, but master and officers witnesses will sign and stamp with ship’s stamp.

  • A typical copy of samples taken must be retained onboard

 

Furthermore, strict compliance with Company’s requirements for such cases as such not to be taken lightly and be communicated immediately to the DPA and Operations Department shall be adhered to. In that way, the Company will be assist/guide you in the proper third party reporting, make further arrangements by P&I representatives to board the vessel the soonest possible to assist you etc. and in that way assure the vessel will not be victimized.

 

Source: Z. Lempesi / HSQE Manager

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