Oil Leak 15 VOC’s

A little more from our letter received from the MCA in response to our legal challenge, or rather the accompanying document provided by Intertek.

On the point of VOC’s emissions – Intertek highlight the issues that people in boats may be in the vicinity of operations and dolphin health may be affected. while these points were raised, they also missed the fact that VOC’s can be windblown to nearby areas of human habitation. Regardless, their reply:

“The PoCF is mitigating VOC’s where the technology is available onboard. The alternative would be to trade only with vessels that offer VOC recovery systems. VOC recovery is a complex process and requires shore side facilities. A more practical potential mitigation is to undertake VOC balancing using an additional hose. Operations will only be undertaken at established anchorages (with the exception of 18a). MCA do not consider this a great issue”

The first two sentences contradict the first – essentially VOC recovery can only be done with shore side facilities. That’s what happens currently at Nigg – it is generally not undertaken at sea. So, to translate, that should read “The PoCF is not mitigating VOC’s as it is undertaking the operations at sea where they cannot be recovered”.

VOC balancing is inherently difficult – if you get the balance wrong then there is a risk of explosion.

The MCA should consider it a great issue – not only does MARPOL AnnexVI have emission reductions standards which the CFPA proposal would fail to meet, these gases are carcinogenic and affect the health of both humans, dolphins and other marine life. To ignore the issue completely is an unreasonable response and critical in the assessment of impact on both humans and the environment.

Some further reading if you want to get into it:

http://www.imo.org/en/OurWork/Environment/PollutionPrevention/AirPollution/Pages/Air-Pollution.aspx

http://www.imo.org/en/OurWork/Environment/PollutionPrevention/AirPollution/Documents/Circ-680.pdf

https://www.intertanko.com/upload/WeeklyNews/NMVOC%20Training.ppt

http://ec.europa.eu/environment/air/pdf/vocloading.pdf

http://response.restoration.noaa.gov/about/media/toxicity-oil-whats-big-deal.html