THE EVOIKOS AND PONTOON 300 INCIDENTS - THE TECHNICAL ADVISER'SPERSPECTIVE
By
Dr. Brian Dicks, Dr. Tosh Moller, Mr. Richard Santner, ITOPFINTRODUCTION
The oil spills from the tanker EVOIKOS off Singapore and the barge PONTOON 300 in the United
Arab Emirates (UAE) were major incidents which severely tested response arrangements in the twocountries. Both spills were of persistent residual fuel oils, the former a heavy fuel oil (HFO) and thelatter an intermediate fuel oil (IFO), and both involved use of equipment stockpiles established by thePetroleum Association of Japan (PAJ) on the major oil transport routes to Japan.
The purpose of the paper is to review the two incidents in broad terms from a technical perspective, inorder to identify some of the successes and difficulties experienced during the responses and to suggest
improvements for the future. Understanding the type of oil and its behaviour once spilled is crucial torealising the technical limitations that this places on the response. The form of the response is, in turn,important to securing proper compensation, which proved to be a crucial issue in both incidents.
ITOPF's attendance on site in Singapore and Malaysia in the case of the EVOIKOS was on behalf ofthe tanker owner, his P&I insurer and the 1 97 1 International Oil Pollution Compensation Fund (1971
IOPC Fund). In the United Arab Emirates (UAE), it was solely on behalf of the 197 1 IOPC Fund.
COMPENSATION ARRANGEMENTS
Compensation for oil pollution damage caused in the case of the EVIOKOS and PONTOON 300
spills is governed by two international Conventions: the 1969 International Convention on Civil
Liability for Oil Pollution Damage (CLC 69) and the 1971 International Convention on the
Establishment of an International Fund for Compensation for Oil Pollution Damage (Fund 71).
Compensation under CLC 69 is provided by the individual tanker owner through a system ofcompulsory insurance. Supplementary compensation under the terms of the 7 1 Fund Convention isprovided through an international fund contributed to by companies receiving crude oil and fuel oil
after sea transport. The international fund is administered by the 1971 International Oil Pollution
Compensation Fund (1971 IOPC Fund). Countries that ratify Fund 71 automatically become Membersof the 1971 IOPC Fund.
Limits of compensation for CLC 69 are set in relation to the size of the tanker, up to a maximum of
about US$ 19 million. The supplementary compensation provided by the 197 1 IOPC Fund is not
related to tanker size, but is up to a fixed limit of about US$ 81 million.
At the time of the EVOIKOS spill, Singapore was party only to CLC 69, and the shipowner/insurer's
liability under this convention was about US$ 13 million. However, the spill also reached the watersof Malaysia and Indonesia, and as these countries were parties to Fund 71 as well as to CLC 69,
additional compensation up to the Fund 71 limit was potentially available in these countries.
At the time of the spill from PONTOON 300, UAE was party to both CLC 69 and Fund 7 1, but
because neither the owner of PONTOON 300 nor a pollution insurer could be identified,compensation was available only from the 1971 IOPC Fund. Since these two incidents, both Singapore
and the UAE have ratified the 1992 CLC and 1992 Fund Conventions, which provide both higher
compensation limits and a broader scope of application.

For compensation to be available under the terms of the international conventions it is a requirementthat the spill response measures which are adopted are reasonable on technical grounds. Put simply,
this means that for costs to be met the response strategies and the clean-up techniques must be
appropriate in the particular circumstances. In addition, there are important consequences forclaimants if all approved claims exceed the total amount of compensation available. Each claim would
be reduced proportionately in order that the compensation is distributed fairly.
EVOIKOSThe incident
The tankers EVOIKOS (80,823 GT) and ORAPIN GLOBAL (138,037 GT) collided whilst passing
through the Strait of Singapore on 15 October 1997. The EVOIKOS, which was carrying about
130,000 tonnes of heavy fuel oil, suffered severe damage to three cargotanks and an estimated 29,000 tonnes of heavy fuel oil was spilled almost instantaneously. The
ORAPIN GLOBAL, which was in ballast, did not spill any oil.
The spilt oil initially spread from the collision point to contaminate about a dozen small islands off thesouthern coast of Singapore. Strong tidal currents caused uneven spreading and fragmentation of theoil, which at the time of spillage was fairly fluid in the warm ambient temperatures. By 19 October theviscosity of the oil had greatly increased through natural weathering and winds and currents had begun
to move the slicks away from Singapore waters and into the Malacca Strait. By the end of the first
week, the oil was approaching Malaysian shorelines in the southernmost section of the
Malacca Strait, but it did not actually hit the coast. At this stage the fragmented slicks ' which stillcontained major areas of black oil, were scattered over more than 1 50 square kilometers. A few days
later the oil covered more than twice that area.
During subsequent weeks the oil continued its north-west drift, influenced by tidal streams and local
currents, spreading further as it travelled. Because winds were light and variable the oil remained
offshore. By the beginning of November the remaining residues, which still included large patches of
black oil and extensive heavy sheens, were spread over more than 3,000 square kilometres of sea
surface. The slow northward drift continued until 12 December, when some oil finally began to comeashore in places along a 40 kilometre length of the Malaysian coast in the Province of Selangor.
Rough estimates indicate that about 100 - 200 tonnes came ashore. Figure 1 illustrates the gradualdrift of the oil from Singapore waters and into the Strait, summarising a series of aerial surveillancemaps prepared at the time. It is likely that oil began to sink as it weathered in the later stages ofdrifting, leaving a decreasing proportion available to strand on shorelines.
Clean-up operations at sea
The Maritime and Port Authority of Singapore (MPA) took charge of the clean-up operations, initially
focusing on dispersant spraying at sea and then on containment and recovery of the floating oil. Cleanup equipment stockpiled in Singapore by East Asia Response Ltd (EARL) , the Petroleum Associationof Japan (PAJ) and Semco (who were also involved with salvage) was deployed. PAJ equipment fromPort Kelang in Malaysia was also brought in to supplement local resources, with the approval of the
Malaysian authorities.
About 500 kilolitres of dispersant were reported to have been applied to the slicks from boats,although the precise quantity is not yet known. In theory, if applied in optimal proportions ( 1 :20,
dispersant:oil), this volume would have been sufficient to disperse about 10,000 tonnes of oil.
However, in practice it is difficult to achieve optimal application ratios from boats, and the process ismade more difficult and less effective because spilled oil rapidly becomes fragmented and patchily
distributed on the water surface. This spill was no exception. Large scale application of dispersant
from aircraft, which tends to be more effective at achieving efficient application of the chemicals, was
not feasible because of heavy shipping traffic in the spill area, and because of air traffic restrictions
for fixed wing aircraft in Singapore airspace. A trial application by helicopter was made (see below),
but this approach was not scaled up.
Different types of oils vary in their chemical dispersability. Heavier crudes and residual fuel oils,
which are highly viscous, may not be dispersible. Where they are dispersible, they tend to be much
more difficult to disperse than lighter crudes and fuels. Natural weathering processes also act on theoil once spilled, resulting in steadily increasing viscosity such that chemical dispersants eventually
become ineffective. This point is usually reached within a few days after spillage. The cargo of the
EVOIKOS was of moderate viscosity (2,000 mPas at 20℃) and in the high ambient temperatures was
initially dispersible. However, there proved to be differences of opinion over whether dispersion was
being achieved. The belief was widespread that a white colour in the water after dispersant had been
applied was evidence of success. In fact, the white colour results from dispersant having failed to reactproperly with the oil and having become mixed directly into the water. This may have been due toinappropriate or poor application techniques or, once the oil had become more viscous by weathering,
may have been an indication that the dispersant could no longer penetrate and disperse the oil. For
most dispersants, good dispersion is evidenced by a distinct coffee-coloured plume visible below thewater surface.
Trial applications of dispersant by helicopter and by knapsack spray, carried out during the 4th day
after the spill, showed that the oil had become very viscous and that dispersants were no longer
effective. A simple dispersion test the following day confirmed this to be the case. Nevertheless, many
responders claimed dispersants were still working, perhaps for the reason outlined above, which led tocontroversy over whether dispersant application should be continued. There is often a reluctance todiscontinue dispersant use if there are perceptions that it may be doing some good, or where response
agencies rely heavily on the technique, especially if no alternative is available. Whilst applicationfrom helicopters was stopped after the trial, spraying from boats did carry on.
Although the exact timetable of dispersant application in this response is not completely clear, it isbelieved that a significant volume was applied after the oil had become too viscous for chemicals to beeffective. Thus, it is likely that only a fraction of the potential dispersion was achieved in this case.
Subsequent attempts at recovering oil from the sea were hampered, not by an absence of appropriate
equipment, but by the lack of adequate logistical support for skimmers and booms. Although morethan fifteen heavy oil skimmers and adequate boom for oil containment were immediately available,
only a few functional systems were put in place. Particularly lacking were vessels and barges suitable
for receiving recovered oil. This is clearly an issue that requires particular attention in the future. Oilstorage vessels were eventually found, with the numbers increasing between 18 and 22 October (seeTable 1), but by the time they became operational the majority of the oil had left Singapore's waters
and was scattered over more than 150 square kilometres in the Malacca Strait.

Table 1Date
16 Oct17 Oct18 Oct19 Oct20 Oct21 Oct22 OctOil Concentration
Heavy
Heavy
Heavy
Reducing
Light
SheensSheensOil Recovery Systems

Storage Barges

3 EARL + 4 SEMCO
4 EARL + 8 SEMCO
3 EARL + 4 SEMCO
4 EARL + 7 SEMCO
4 EARL + 7SEMCO

1
3
3
9
9

Clean-up operations on shore
Once the threat to Singapore had receded, the focus turned to shoreline cleaning on the small southern
islands which had been oiled. In all about 40 kilometres of shoreline had been contaminated, including
tourist/recreational islands, industrial areas and military facilities. Contaminated shorelines comprised
rocks, boulders, man-made sea walls, sandy beaches and mangrove swamps.
Setting achievable priorities for clean-up became crucial for a number of reasons. Shoreline cleaning
takes time and calls for substantial resources, and it is important to deal first with the areas given thehighest priority. Given the potential scale of clean-up, there were also concerns over the adequacy of
the available compensation. Under the terms of CLO '69, a maximum of about US$ 13 million wasavailable from the shipowner/insurer for all aspects of clean-up and damages, but considerable sums
had already been spent at sea, and further expenditure might also be incurred for clean-up anddamages in Malaysia and Indonesia, which would further limit available compensation for Singapore.
As noted previously, Malaysia and Indonesia were party to Fund 7 1 at the time of the spill, andclaimants in those countries have the right to supplementary compensation from the 1971 JOPO Fund
if any shortfall in their approved claims resulted from the CLC 69 limit being exceeded and pro-ration
being applied.
Cleaning recreational beaches in Singapore was deemed to be the highest priority, so Pulau Hantu andRaffles Light (see Figure 2) were treated first. A commercial contractor was engaged by the
shipowner and the P&I Club. Manual and mechanical techniques as well as dispersants and seawater
pumps were used to clean sandy beaches and sea walls. Cleaning of newly constructed recreational
and industrial facilities on an island under development (Pulau Semakau) was dealt with by thedeveloper as a high priority, with the work tailored to suit the on-going construction programme.
Extensively oiled sea walls in industrial areas and on military islands were mainly inaccessible andnot open to the public. Given that the oil had rapidly stabilised, it was recommended that only areas
where contact with vessels or personnel was likely should be cleaned, allowing natural degradation totake its course elsewhere in this already industrially-contaminated area.
Mangroves, which are also found on the industrial and military islands, are a special case, as scientificevidence points strongly to the need to leave them to natural recovery because of the high risk ofcompounding damage by attempts at clean-up. One area of newly created mangrove swamp (to replacemangrove destroyed by commercial developments) was oiled, but to date survival of the planted
seedlings seems good. These mangroves are being monitored to see if damage results from the spill.
There is no doubt that the progress of shoreline cleaning work in the Singapore islands was hamperedby the limited funds available. Had supplementary compensation from the IOPO Fund been available
in Singapore it is likely that the cleaning operation would have been concluded more quickly and to thegreater satisfaction of all parties.

Malaysia
By the time oil slicks had reached Malaysian waters in the Malacca Strait, it had already been
established that the oil was no longer amenable to chemical dispersants. The Malaysian Marine
Department (MMD) , which was in charge of response operations at sea, considered the option ofcontaining and recovering the oil before it came ashore. However, they recognised that they faced thesame difficulties witnessed in Singapore with insufficient tugs and temporary oil storage capacity tosupport such an operation. With the oil becoming increasingly viscous, all but the heaviest recovery
equipment would have been rendered ineffective. Furthermore, slicks were spreading and scatteringover hundreds, and what was eventually to become thousands, of square kilometres. Attempting
recovery operations on this scale would be extremely onerous and unlikely to achieve any significant
success. The Malacca Strait is a very busy shipping route and any such recovery operations would
also be potentially hazardous.
In light of these circumstances, the MMD were persuaded to follow a strategy of close monitoring andsurveillance using helicopter and boat services, and placing on standby adequate resources to protect
those sensitive coastal areas given the highest priority. Some containment and recovery equipment was
kept in readiness to work close inshore in these areas and some clean-up resources were put on alert torespond to any shoreline impact. The heavy oil skimmers owned by PAJ as part of the Port Kelangstockpile were deemed to be an important component of this state of readiness, butthese had been deployed to Singapore in the early stages of the incident. There were considerable
delays over their return as the Singapore authorities were reluctant to part with them in case the threat
to Singapore returned with changing winds and currents.
Initially, as the slicks left the Singapore Strait and began entering the Malacca Strait, oil patches
approached a large group of fish farms in sheltered waters around Pulau Kukup. Fish farm owners
were encouraged to use locally available materials, including plastic sheeting weighted with bricks, tosurround the fish cages, so forming a protective barrier against floating oil. In the event, the protection
was not called upon to perform, as the oil came no nearer than 500m from the outermost farms. As theoil slicks steadily moved further north in the Malacca Strait, different local divisions of the MMD took
control of the response, each maintaining the overall strategy of close monitoring, identification andprotection of highest priority resources, and placing shoreline clean-up resources on alert! standby.
After some 2 monThs, slicks had moved beyond Port Kelang and some smaller patches eventuallybecame caught in local currents and then stranded in places along a 40 kilometre stretch of theSelangor Province shoreline. This included several sandy beaches, a one-kilometre length of rocks andconcrete breakwater, and several separate areas of mangrove. Onshore clean-up operations were coordinated by the Malaysian Department of Environment with support from the MMD. Individual
district authorities within the Selangor Province organised the manual removal of oil and oily material
from sandy shores, and arrangements were made to clear the rocky and concrete breakwater areas.
Scientific evidence was heeded in the case of affected mangroves, with the oil being left to weather,and the mangroves to recover naturally.
After hitting shores, the remainder of the floating slicks moved further north-west, away from the
Malaysian coast and toward the middle of the Malacca Strait, posing an ever-decreasing threat. By
January 1998, some 2 1/2 months after the spill had occurred, the remaining monitoring operations
were finally stood down.

Indonesia
There is no information on any pollution impact in Indonesia. However, the relevant authorities were
kept informed by the Malaysian authorities of the presence of oil in the Malacca Strait.
PONTOON 300
The Incident
On 7 January 1998, intermediate fuel oil (IFO) was spilled from the sea-going barge PONTOON 300,
whilst under tow off the United Arab Emirates by the tug FALCON 1. The barge had reportedly
become swamped by the heavy seas generated by strong and blustery winds from the north, known
locally as 'shamal'. Whilst taking on water, the barge had been losing oil, and during the course of thenight of 8 January it sank and settled on an even keel on the bottom at a depth of 2 1 metres, about six
nautical miles off Hamriyah Free Port. PONTOON 300 is a flat-top barge of 4,233 gross tons.
Although designed for deck cargoes, the barge was on this voyage carrying her cargo of LEO in 24
buoyancy tanks. In addition to these tanks, divers later reported signs of diesel oil having been loaded
in fore and aft ballast spaces on the barge.
A regular trade of oil shipments from the northern Gulf in barges such as the PONTOON 300 has
developed over the last few years and there are reports of a number of similar incidents having
occurred recently. On 14 January 1998, just a week after the PONTOON 300 spill, another tug andbarge, with all names and identification marks painted over, were seen trailing black oil close to where
the PONTOON 300 had sunk (see Figure 3). This second flat-top barge, later identified as KAPAR 2,
was listing heavily and at times half submerged with waves breaking across the deck. The total
quantity of oil seen behind the tow was estimated at little more than 20 tonnes, and fortunately it
proved possible to bring the barge into Hamriyah port and offload the oil cargo without further mishap.
Both PONTOON 300 and KARAR 2 were carrying similarcargoes of IFO.
The salvage of the PONTOON 300 and its remaining cargo was undertaken by a local salvage
contractor. Divers found that eight of the portside tank covers were missing, indicating that 3,000 to
4,000 tonnes of IFO had been lost, but the spill volume was later revised to 8,000 tonnes. During thefollowing weeks work was carried out to plug and seal the various points of seepage but a further spillof about 300 tonnes occurred on 9th January. Contingency measures in case of further oil spillage
during salvage were put in place by the UAE authorities and salvors. The salvage operation proved
complicated because of damage to internal bulkheads. Mter four attempts, the barge was finally raised,
upside down, and towed into Hamriyah port on 6th February. After oil residues had been removed, thebarge was towed 17 nautical miles out to sea and scuttled on 17 February.
For the first 6 days after the initial spill oil was drifting within 5 nautical miles of the coast. During themorning of 13 January onshore winds increased suddenly to gale force strength as another shamalreached the UAE coast, coinciding with spring high tides. As a result, all the oil drifting offshore wasdriven ashore and deposited at the very top of sandy beaches and in the adjoining vegetation. The
spilled oil contaminated beaches in five emirates: Dubsi, Sharjah, Ajman, Umm Al Quwain and Ras
Al Khaymah (see Figure 3) . The only oil remaining offshore was a small continuous release from thesunken wreck.
IEO is naturally dispersible and could be observed dispersing in the heavy surf created by the shamalon 13 January, which lasted for several days. Natural dispersion significantly reduced the quantity of
spilled oil stranded on the shorelines.
Oil spill response measures
In a major spill affecting more than one Emirate, the Federal Environment Agency (PEA) will takeoverall charge and appoint a response committee and an OSC. However, there is no National

Contingency Plan to set out chains of command or operational procedures and the FEA has no
specialised spill response equipment, but relies on port authorities and the oil industry for resources.
The Frontier and Coast Guard Service (FOGS) provides vessels for on-water surveillance and the Air
Wing of the Ministry of Interior can undertake aerial surveillance. Several port authorities operatetugs equipped with dispersant spraying gear and hold small stocks of clean-up equipment.
The Abu Dhabi National Oil Company (ADNOC) has offshore boom, skimmers dispersant andhelicopter-mounted spraying units at five strategic locations, and as members of the Gulf Area Oil
Companies Mutual Aid Organization (GAOCMAO), ADNOC may request assistance from othermember companies around the Gulf.
The Petroleum Association of Japan (PAJ) has sited a small stockpile of response equipment in Abu
Dhabi comprising heavy oil skimmers, boom and portable storage tanks. The PAJ equipment is stored
and operated by a local contractor, Lamnalco. A private contractor, Fairdeal, has several skimming
vessels and other specialised equipment located at Fujairah and Dubai. Most industrial plants withseawater intakes have booms available. Supplementary resources can also be requested by thegovernment through the Marine Emergencies Mutual Aid Centre (MEMAC), based in Bahrain.
Although control of major oil spills is the responsibility of FEA, very little was done initially to deal
with the stranded oil because of uncertainty over compensation. Neither the barge owner nor apollution insurer could be located for PONTOON 300. This meant that the shipowner and/ or pollution
insurer could not be prevailed upon to take an active role in the organization of clean-up, for example
by contracting resources and manpower. More importantly, the lack of a shipowner and insurer meantthat there was no compensation available under the terms of CLO 69. The 1971 IOPC Fund wasapplicable, but is established only to pay compensation and is not constituted to contract resources or
manpower. Thus, a government agency or private organization must first put in place the necessarycontractual arrangements, thereby taking on the financial commitment, and later claim compensationfrom the IOPO Fund.
The initiative was taken by a small clean-up team from ADNOC to begin recovering oil, working fromthe shore. Other clean-up contractors were later appointed by FEA and the PAJ stockpile was also
mobilised. ADNOC recovered about 60 tonnes of oil at Umm Al Quwain on 1 1 and 12 January,which was disposed of to landfill. Additional small quantities of floating oil were recovered in thefollowing week, but by 19 January there was no floating oil to recover, all the oil having stranded.
Manual cleaning of shorelines started on 12 January with about 100 workers supported by mechanicaldiggers, and collected oily sand was subsequently removed to landfill. However, co-ordination andcontrol of the clean-up operations by PEA was hampered by a severe lack of resources arid funding.
Beach clean-up funded by FEA was therefore suspended for almost two months towards the end ofJanuary. Storms in late January resulted in many beaches being scoured of oil and thus cleaned
naturally.
After two months Lamnalco came forward and undertook to resume the remaining beach cleaning
work with a view to claiming compensation from the 1971 IOPO Fund. A programme of bulk oilremoval which met the Fund's technical criteria was drawn up by IOPC Fund experts and agreed withby FEA and Lamnalco, thus maximising the likelihood of full cost recovery under Fund 7 1 . Two
IOPC Fund experts were appointed to monitor clean-up progress, and liaise regularly with the FEA.
On completion of each sector of shoreline, a joint inspection was carried out with the authorities with aview to agreeing that an acceptable end point had been reached. The programme ensured that the great
majority of oil was removed to landfill, leaving only traces which were deemed to no longer represent

a threat to either public usage or natural resources. The FEA accepted this pragmatic approach,leading to a satisfactory conclusion to the work by the end of April.
Sensitive resources and evidence of pollution damage
A range of sensitive resources are to be found on the UAE coastlines, including a marine research
institute, commercial fishing and industrial water intakes. The Marine Resources Research Centre(MRRC) is run by the Ministry of Agriculture and Fisheries for aquaculture research and development.
The presence of oil near the seawater intake prompted its closure for several days. The facility thenrelied on re-circulation pumps and additional aeration to maintain water quality in the cultivation tanks.
On 10th January the intake was re-opened at High Water during the day when confirmed to be free ofdrifting oil, but some oily sheens were nevertheless drawn m. The losses likely to have occurred at
MRRC take the form of physical contamination of cultivation facilities, extra costs in supplementing
sea water supplies by tank trucks and disruption of cultivation programmes for fish and prawns.
Although no compensation claims have been submitted yet, there seems little doubt that local fishing
was disrupted by the spill, and that delays to beach cleaning resulting from uncertainty overcompensation compounded any damage. The delays also affected bookings at beach hotels whereshoreline contamination was heaviest.

CONCLUSIONSEVOIKOS・ The oil spilled in the EVOIKOS incident remained afloat in a narrow waterway for 2 1/2 months
as a result of the high viscosity of the oil and calm weather conditions.
・ High oil viscosity was the main factor limiting dispersant effectiveness.
・ Attempts to recover oil using booms and skimmers were hampered initially by a lack of barges
for storing collected oil. By the time barges became available the bulk of the oil had drifted outof Singapore waters and spread over a large area.
・ A realistic and successful strategy of monitoring drifting oil and protecting key sensitive resour
ces was adopted by the Malaysian authorities.
・ Because compensation available under the terms of CLC 69 may be insufficient for the paymentof all valid claims, there is a risk that claimants in Singapore may receive only partial compens
ation since Singapore had not ratified Fund 7 1 at the time of the EVOIKOS incident.ingapore
has now ratified CLO 92 and Fund 92, which will be in force on 3 1 December 1998 and which
provide both higher compensation limits and a broader scope of application.
PONTOON 300
・ Although the UAE had ratified CLO 69, only Fund 71 was applied in the PONTOON 300 inci
dent since no shipowner or pollution insurer could be identified.
・ The clean-up operation was interrupted due to a lack of government funds but was resumed after
seven weeks when a successful solution for resuming the clean-up was found involving close cooperation between the government authority, a commercial clean-up contractor and the IOPC
Fund.
・ The UAE has now ratified the CLC 92 and Fund 92, which will come into force on 19
November 1998