A thorough international review of these matters will take place in 2 weeks' time at the IMCO symposium in Acapulco, Mexico.

I would only at this time invite attention to three particular areas: (1) Oil-in-water monitor developments in the last 2 years have been encouraging, so that the possibility of having reliable and reasonably accurate shipboard monitors is now coming closer; (2) a new technique involving the use of crude oil rather than water for washing larger inerted tankers is now being adopted, and it shows promise of being an extremely effective pollution abatement measure; (3) progress seems finally to be getting underway in solving the difficult problems of providing adequate and effective reception facilities ashore at the proper locations.

2

Accordingly, I believe substantial progress has been made, and will continue to be made, particularly if governments will now ratify the 1973 IMCO Convention.

I wish I were as confident about progress being made to prevent oil pollution from tanker accidents, but frankly I am not.

3

The basic statistics on oil pollution of the seas reviewed by you in 1971 and recently updated through 1973 tell the story. There are far too many ship accidents involving tankers, and far too much oil being spilled in the process.

I know you gentlemen are familiar with these data, so I will polluat this point refer you to the fact that in discussing worldwide pollution from tanker accidents, Messrs. Card and Snider said,

Most of the total oil outflow-81 percent-is a result of tankship sinkings, even though less than 2 percent of all tankship involvements result in the vessel sinking.

The 15 vessels lost due to structural failure accounted for 34 percent of the total oil outflow from tankship accidents.

Because of their contribution to oil outflows, a more detailed study was made of tankship total losses. There were 47 tankships of over 10,000 deadweight tons that were total losses during the 1969-1973 period. They were responsible for 81 percent of the total oil outflows of 951,000 long tons. Table 6 shows that most of these involved a sequence of failure events. Table 7 gives additional detail on the events leading to loss of structural integrity and sinking of the tankship. (Ref. 5, p. 208)

Obviously priority efforts must be directed at preventing a rather small number of tanker sinkings, and principally at those which result from structural failure, groundings and collisions.

It is well to note further that most of the deaths and major injuries result from collisions, usually followed by fire, and fire/explosions. The question then is: What can be done?

Preventing structural failures is obviously a technical problem in the first instance demanding sound design and construction.

In my view the progress made in improved structural design in the past few years-in fact, over the last decade or so has been outstanding, and most of it has been brought about by the international cooperation of enlightened tanker owners, builders and classification societies.

The computer design techniques used now are closely akin to those used in the aircraft industry, and the progress on welding, metallurgy and inspection techniques, much of it from Japan, is indeed remarkable.

2 "Crude Oil Washing," by R. Maybourn (International Chamber of Shipping), 1975. 3 "Tankers and the Ecology," by V. F. Keith, J. D. Porricelli. R. L. Storch. 1971.

4 "Tankship Accidents and Resulting Oil Outflows, 1969-1973," by J. C. Card, P. V. Ponce and W. D. Snider.

More specifics on industry programs in this respect are given in the booklet "Very Large Crude Carriers" prepared by my company last year and appended to this statement.

Any technical device is subject to failure without vigilant maintenance and inspection programs; your car, an aircraft and even a tanker.

The CHAIRMAN. I think this ought to be clear and I am sure you can help us with it when you say that progress is being made in Japan are most ships built according to the owners' design?

Mr. GRAY. No, sir. I wouldn't say that.

In regard to structural adequacy, the ships have to satisfy classification requirements as to size, thickness, quality of steels and how it is welded.

The owners' preference is really only in regard to the size of the vessel, the dimensions of the vessel, the accommodations and so forth.

The CHAIRMAN. Say that the contract is for a ship to be built in Japan and by the time it is getting ready to be built some new technology shows up. The owner accepts that from the shipbuilder?

Mr. GRAY. Certainly new technology does come forth and

The CHAIRMAN. They keep up with the events of technology as they build ships; is that right?

Mr. GRAY. I would say the owners around the world are very keen to do just that.

But I think certainly the high incidence of losses in ships 15 to 20 years old, regardless of size, type, or flag, suggests the need to look more closely at inspection and maintenance policies and requirements for the older ships.

Collisions and groundings are a different matter. Here the evidence is overwhelming that the majority of these accidents are the direct result of people on ships. Either they did something they shouldn't, or didn't do something they should, and usually they knew it but failed to avoid the accident anyway.

I know this, the Coast Guard knows this, and the Congress must know it, as the obvious solution for many of these accidents is traffic control as mandated by Title I.

I think all agree that particularly for the prevention of collisions, and many harbor groundings as well, VTS-vessel traffic systemsis clearly the most effective answer.

It is indeed unfortunate that here we are in the midseventies just inaugurating VTS in U.S. waters when significant numbers of other countries are going into second and third generation systems following in some cases over twenty years of outstanding experience with VTS.

Even more fundamental than VTS in my estimation, however, is the quality and performance of the people in charge of ships of all types, principally the deck officers and pilots.

However, paragraph 1 of title II says, if I may paraphrase, that "the Congress finds... existing standards of design, construction. must be improved . . ." and in paragraph 7 goes to specify that "regulations . . . shall improve vessel maneuvering and stopping ability, reduce possibility of collisions and groundings and reduce cargo loss following... accidents."

I find this desire to make tankers themselves "accident proof" entirely understandable, just as I want the safest possible automobile to drive, or plane to fly in with my family.

Just as with those other moving objects, however, large amounts of energy are involved so it becomes virtually impossible to build in safety features which will be truly effective in preventing oil outflow following severe accidents.

Nonetheless, if some degree of effectiveness is in prospect, a concept must be seriously considered.

Adequate maneuvering capability for ships of all types should obviously be a prerequisite to entering harbors, shallow waters or traffic situations.

In my opinion most modern tankers already possess excellent inherent maneuvering capability and additional fundamental propeller, rudder, or powerplant design changes would usually provide no measurable improvement in their performance.

In this regard, I must respectfully disagree with the many allegations to the contrary.

I feel from the material referenced therein and the statements included in Senate Report 92-724, particularly on pages 17, 18 and 19, that the Senate has perhaps not been adequately informed as to the maneuverability of tankers generally and particularly new large tankers. The Senate report makes general reference to maneuvering inadequacy, and then alludes to promising devices for consideration, some of which had initially been described by Messrs. Porricelli et al. Nowhere, however, can I find that the value of these devices was considered. Also, the Porricelli paper appears to be the principal technical reference actually considered in your 1971-1972 hearings.

A paper which I presented in 1973 entitled "Large Tanker Maneuvering" which I believe puts the subject in truer perspective, is appended.

6

This work is described in greater detail in two papers presented by Messrs. van Berlekom, Goddard 5 and Crane in the years 1972 and 1973 to the Society of Naval Architects and Marine Engineers. The technical quality of this work is I believe attested to by the fact that van Berlekom and Goddard received the SNAME prize for best paper of 1972, and Crane received honorable mention in 1973 for his paper.

The work described therein was largely conducted by Exxon research naval architects starting in the midsixties with a broad program to study theoretical and practical aspects of tanker maneuvering. I will not attempt here to review these technical studies, but I commend them for review by the appropriate technical groups or agencies.

I would like, however, to summarize some of the most significant findings, supporting them as appropriate with certain practical observations bearing on this subject of maneuvering.

The basic test of adequate maneuverability for any ship is that its behavior must be predictable and reliable under all circumstances to be encountered.

5 "Maneuvering in Large Tankers," by W. B. van Berlekom and T. A. Goddard, (Society of Naval Architects and Marine Engineers), 1972.

"Maneuvering Safety of Large Tankers: Stopping, Turning, and Speed Selection," by C. L. Crane, Jr. (Society of Naval Architects and Marine Engineers), 1973.

This includes the ability to go straight, to turn, and to stop, in both deep and shallow water, and at a range of speeds down to a few knots.

Well designed modern tankers with single screws and single rudders meet these criteria admirably and have repeatedly shown so. Let me cite some examples.

For over 5 years now underway lightering of VLCCS by smaller tankers of 30,000 to 115,000 dwt has been taking place entirely safely and routinely, often in very shallow water, during either day or night, and without any tug or lateral thruster assistance.

I am no expert on this-in the sense that I have not been master of such vessels but I have been aboard a 225,000 dwt VLCC during such an operation conducted at under 3 knots speed with, at times, 10 feet or less of water under the keel. Steering and course control of the ship was excellent throughout.

My company has recently conducted full-scale trials of tankers moored together while underway over a wide range of conditions and found coursekeeping, steering and speed control excellent throughout. Discussion with pilots and masters handling the new larger tankers has repeatedly indicated that those with firsthand knowledge of the ships regard modern tankers, and particularly VLCCs, as amongst the most maneuverable, well-found ships in the world.

In my own conversations with pilots, more often than not it is the large high-powered multiscrew container ships about which most complaints are heard due to their tendency to be blown about by wind.

The experience gained with tens of thousands of tankers successfully transiting the Suez Canal, both loaded and in ballast, has repeatedly shown that narrow, shallow waterways can safely be negotiated by this class of ship. This experience of course is mainly in tankers of 50,000 to 80,000 dwt, a size of particular interest in U.S.

waters.

In order to verify these operational experiences my company made extensive technical investigations, including full-scale trials in the Suez Canal with a 90,000 dwt tanker in 1965 and modeling of the crucial parts of the canal in 1967 for training VLCC masters at Port Revel in Grenoble, France.

There are numerous other practical and theoretical examples of the maneuvering ability of modern tankers, but I hope those given make my point.

It is therefore with a sense of amazement and frustration that we see repeated statements suggesting that tankers, particularly large ones, can't maneuver predictably.

7

One such article appearing last year under the prestigious auspices of the National Science Foundation and referring to hydrodynamicists at three of our Nation's leading universities would, I am sure, lead its readers to believe both that shallow water effects were invented-or first discovered-by VLCCs and that these ships are unmanageable at something under 6 knots.

This is complete nonsense as anyone who has sailed or handled these ships knows.

7 "Controllin Ships in Heavy Traffic," Mosaic, (National Science Foundation), January/ February 1975, p. 2.

The only explanation I can find for such beliefs, and for the fact that a good deal of the research in the United States is just now starting to study subjects long since investigated in Europe and Japan, is the fact much of our marine scientific community has not participated in investigations of tanker maneuvering, which have taken place around the rest of the world.

For instance, 1976 will see the commissioning of the first shiphandling simulators in the United States, whereas Holland already had two at the beginning of the decade. And the Grenoble model training facility built by Exxon 10 years ago has not yet been duplicated. Perhaps against this background it is not surprising to see so-called maneuvering proposals of the type under consideration now in Alaska, and already mandated by the State of Washington, supposedly to improve ship stopping. We investigated all of these concepts, and more, in the early 1970s and if I may quote from my 1973 paper:

A variety of means have been suggested for decreasing the stopping distance of large tankers, particularly for stopping from high speeds. Regrettably the technical viability, and the effectiveness of some of the more extreme suggestions are frequently omitted by their proponents. We have compared some of these in Table 1 in terms of what might be needed to achieve a 20% reduction in estimated stopping distance from a full speed of 16 knots.

Device

Water parachutes..
Water brake flaps.

Braking rockets...

Braking jet engines...

TABLE 1.-FOR A 20-PERCENT REDUCTION FROM 16 KN

Specifications

Twelve 10-ft-diameter parachutes towed alongside the ship.

1 flap on each side of the ship, extending perpendicularly out from the ship's sides like ears. Each flap 10 ft wide and 30 ft high.

Total rocket motor thrust of 80,000 lbs for 8 mins. Could be accomplished with 8 rockets operating consecutively for 1 min each.

4 Boeing 707-type engines operated at near takeoff condition. (These would have a total sustained thrust of 35 long tons or 20,000 lbs each.)

Without having investigated the economics or structural requirements for any of these schemes, we would characterize them as very likely being expensive, not very effective and, in some cases even dangerous. Some represent essentially "1 shot" measures as well. Higher backing power is also being suggested as a means for decreasing stopping distance. To be consistent with the table above and to achieve a 20% reduction in stopping distance from a speed of 16 knots would require an 80% increase in a VLCC's backing power. While this is technically possible we think it more to the point to recognize that the same 20% reduction in stopping distance could be achieved by simply reducing the initial speed from 16 to 14 knots.

While the above data relate to stopping from full speed, we believe a more important matter involves stopping from a slow maneuvering speed such as 6 knots. Table 2 summarizes approximate reductions in stopping distance for various design changes for a VLCC operating at 6 knots.