Vessel Pollution & SolutionsVessel Pollution & Solutions

Richard A. Udell *Senior Trial AttorneyEnvironmental Crimes SectionU.S. Department of Justice601 D Street, NW - #2008Washington, D.C. 20004202-305-0361Richard.Udell@usdoj.gov

INTERTANKOMarch 30, 2006

Singapore

* The views expressed herein are those of the author.

Summary of U.S. EnforcementSummary of U.S. Enforcement

All types of commercial vessels All types of commercial vessels --U.S. and foreign flag.U.S. and foreign flag.Corporate: $133 million dollars in Corporate: $133 million dollars in criminal fines since 1998.criminal fines since 1998.

Plus restitution, community service Plus restitution, community service and probation with court supervised and probation with court supervised environmental compliance programs. environmental compliance programs.

Individual targets: 19 years of Individual targets: 19 years of incarceration since 1998.incarceration since 1998.

Senior shipboard officers and Senior shipboard officers and engineers and responsible shoreengineers and responsible shore--side side managers.managers.

Crimes committed for financial motive.Crimes committed for financial motive.Most cases involve Most cases involve deliberatedeliberate discharges of tons of waste discharges of tons of waste oil, sludge and other pollutants.oil, sludge and other pollutants.IntentionalIntentional bypassing of pollution prevention bypassing of pollution prevention equipment and falsification of vessel records to deceive equipment and falsification of vessel records to deceive port authorities.port authorities.ConcealmentConcealment: discharges made at night, hiding of : discharges made at night, hiding of bypass equipment, use of dispersants, tricking of OCM, bypass equipment, use of dispersants, tricking of OCM, falsification of Oil Record Book and Tank Sounding falsification of Oil Record Book and Tank Sounding Log, etc. Log, etc. Most cases involve Most cases involve obstructionobstruction of justice (witness of justice (witness tampering, destruction of evidence, alteration of tampering, destruction of evidence, alteration of documents, perjury).documents, perjury).

Summary of U.S. EnforcementSummary of U.S. EnforcementContinuedContinued

DetectionDetection

Remote Remote sensing.sensing.Routine inspections.Routine inspections.Enhanced physical and record Enhanced physical and record inspections.inspections.Targeting.Targeting.Marine casualty investigations.Marine casualty investigations.““Mystery SpillMystery Spill”” investigations.investigations.Referrals from foreign countries. Referrals from foreign countries. Whistleblower allegations.Whistleblower allegations.

MotivesMotivesTo save money on purchasing and To save money on purchasing and installing best available technology.installing best available technology.To save money on the cost of To save money on the cost of offloading waste oil in port.offloading waste oil in port.To save money on the cost of To save money on the cost of providing adequate staffing.providing adequate staffing.To save money on the cost of To save money on the cost of OWS filters, membranes.OWS filters, membranes.To save money and time on labor To save money and time on labor and maintenance. and maintenance. Financial bonuses to Chief Financial bonuses to Chief Engineers for keeping within Engineers for keeping within projected budget. projected budget. For crew members: to maintain For crew members: to maintain job in a militaryjob in a military--like chain of like chain of command.command.For crew members: violation of For crew members: violation of law is often easiest and quickest law is often easiest and quickest method to perform tasks.method to perform tasks.

050000

100000150000200000250000300000350000400000

1990 1992 1993 1994 1995 1996

Gallons Offloaded inPort

02468

101214161820

1990 1992 1993 1994 1995

Membranes 4 Required for properuse.

U.S. v. Royal Caribbean

Song of Norway Port Disposal

Song of America OWS Membrane Purchases

Each of these vessels was ISM certified and had passed Class, Flag and Port State inspections.

Prosecution GoalsProsecution GoalsProtect the environment.Protect the environment.Assure accurate ship records and Assure accurate ship records and verbal statements to port verbal statements to port authorities.authorities.Deter future criminal conduct.Deter future criminal conduct.Punish deliberate and intentional Punish deliberate and intentional violations.violations.Create an even playing field Create an even playing field where law abiding companies are where law abiding companies are not disadvantaged.not disadvantaged.

U.S. v. U.S. v. WalleniusWallenius Ship ManagementShip ManagementGuilty Plea in N.J. and $6.5 Million SettlementGuilty Plea in N.J. and $6.5 Million Settlement

MultiMulti--piece bypass piece bypass –– known as known as ““THE MAGIC PIPETHE MAGIC PIPE”” on board on board –– found hidden in various ship found hidden in various ship locations during USCG inspection locations during USCG inspection on November 9, 2005.on November 9, 2005.MarinflocMarinfloc Oil Water Separator not Oil Water Separator not used. used. Deliberate discharges of oil since Deliberate discharges of oil since 2002 under the command of 2002 under the command of multiple Chief Engineers.multiple Chief Engineers.Discharges of oil waste made at Discharges of oil waste made at night and boiler night and boiler blowdownblowdown used to used to clean bypass.clean bypass.Incinerator not used.Incinerator not used.Garbage Record Book and Oil Garbage Record Book and Oil Record Book falsified.Record Book falsified.

Plastic buckets of sludge, oily rags, Plastic buckets of sludge, oily rags, garbage packed in plastic bags garbage packed in plastic bags deliberately dumped.deliberately dumped.Garbage Log and Oil Record Book Garbage Log and Oil Record Book falsified.falsified.Chief Engineer denied existence of Chief Engineer denied existence of Sounding Log which another crew Sounding Log which another crew member was member was ““whiting outwhiting out”” during during the USCG inspection.the USCG inspection.Guilty Plea entered on March 22, Guilty Plea entered on March 22, 2006.2006.

Bypass pipes and hoses found in a Bypass pipes and hoses found in a USCG inspection on May 16, 2005. USCG inspection on May 16, 2005. Approximately 40 cubic meters of Approximately 40 cubic meters of sludge and a larger quantity of bilge sludge and a larger quantity of bilge waste discharged in approximately 6 waste discharged in approximately 6 months. months. Oil Record Book and a Sounding Oil Record Book and a Sounding Log were falsified to conceal Log were falsified to conceal dischargesdischargesCrew members directed to lie to the Crew members directed to lie to the Coast Guard by senior ship engineers Coast Guard by senior ship engineers and by shoreand by shore--side managers.side managers.Documents concealed on the ship.Documents concealed on the ship.Computer printer disabled, alarm Computer printer disabled, alarm printout hidden, and false statements printout hidden, and false statements made to USCG.made to USCG.

U.S. v. MSC Ship ManagementU.S. v. MSC Ship ManagementGuilty Plea in Boston and $10.5 Million SettlementGuilty Plea in Boston and $10.5 Million Settlement

MSC Elena MSC Elena BypassBypass

Suction SideDischarge to Overboard Valve

U.S. v. MSC Ship Management (Hong Kong) Ltd.

U.S. v. MSC Ship Management (Hong Kong) Ltd.

Portable Welden Pump and Flexible Rubber Hose Used to Bypass the Oil Water Separator

U.S. v. MSC Ship Management (Hong Kong) Ltd.

U.S. v. Evergreen IntU.S. v. Evergreen Int’’l.l.Guilty Pleas in 5 Major Ports and $25 Million SettlementGuilty Pleas in 5 Major Ports and $25 Million Settlement

USCG conducted proUSCG conducted pro--active active ““Priority OnePriority One”” inspections of inspections of every vessel.every vessel.Evidence of bypassing on at Evidence of bypassing on at least 7 ships.least 7 ships.Environmental Compliance Environmental Compliance Plan a condition of three year Plan a condition of three year sentence of probation:sentence of probation:

Audits of ships by outside Audits of ships by outside auditorauditorCourt Monitor to review audits Court Monitor to review audits and planand plan

U.S. v. Evergreen Int’l

Ever Given

Ever RewardU.S. v. Evergreen Int’l

Ever Gleeful Bypass HoseU.S. v. Evergreen Int’l

Ever RefineEver Refine

Oil Found in Overboard Valve OWS Test Effluent

U.S. v. D/S Progress, et al.

. v. D/S Progress, et al.

To: D/S ProgressFm: Master, Freja JutlandicDt: 20/March/00

Re: Engine Room Crack

As we expect uscg control on arrival baltimore I believe they can found repairing place and leaks and can be problem. To avoid any mistake pls instruct proceeding re notification of this repairs to uscg.

Tks/brgdsCaptain Maric

U.S. v. D/S Progress, et al.

Source: Swedish Coast Guard

U.S. v. D/S Progress, et al.

How to Achieve Real ComplianceHow to Achieve Real ComplianceShoreShore--based management based management approaches.approaches.

AuditingAuditingTrainingTraining

Procedural approachesProcedural approachesTechnical approachesTechnical approachesApproaches to addressing Approaches to addressing culture, labor and motives.culture, labor and motives.Addressing stages of ship Addressing stages of ship management (new building, management (new building, initial operation, acquisition of initial operation, acquisition of new ships and mergers).new ships and mergers).

ComplianceComplianceProcedural ApproachesProcedural Approaches

Audit and analysis of all waste streams to determine content, Audit and analysis of all waste streams to determine content, volume, method of storage, capacity for storage, treatment volume, method of storage, capacity for storage, treatment and disposal, and estimated cost. and disposal, and estimated cost. Assignment of senior corporate officer as environmental Assignment of senior corporate officer as environmental manager who is empowered to take action.manager who is empowered to take action.Determine equipment and procedures necessary to maintain Determine equipment and procedures necessary to maintain systems and account for aging.systems and account for aging.Elimination and minimization of pollutants.Elimination and minimization of pollutants.Logs for recording waste streams and oil to sea interfaces.Logs for recording waste streams and oil to sea interfaces.Procedures to discourage routine use of bilge/ballast Procedures to discourage routine use of bilge/ballast crossovers and blind flanges.crossovers and blind flanges.Enhanced communication between shore management and Enhanced communication between shore management and line engineers and lower level crew members.line engineers and lower level crew members.Establish environmental component in routine shipEstablish environmental component in routine ship--board board and ISM safety meetings.and ISM safety meetings.

Procedural Approaches Procedural Approaches TrainingTraining

Use of inUse of in--house and outside training schools/centers.house and outside training schools/centers.Specific MARPOL training courses.Specific MARPOL training courses.Expert onExpert on--site training. site training. Documentation of training.Documentation of training.Formal written policy documents:Formal written policy documents:

Corporate compliance statementCorporate compliance statementOperational procedures regarding storage, treatment and disposalOperational procedures regarding storage, treatment and disposal of each of each waste stream and testing, use and maintenance of equipmentwaste stream and testing, use and maintenance of equipmentRecordkeeping and log entry requirementsRecordkeeping and log entry requirementsJob position descriptionsJob position descriptionsRewards and punishment for compliance/nonRewards and punishment for compliance/non--compliancecompliance

Training on obligation to be truthful with port state Training on obligation to be truthful with port state authorities and in ship records.authorities and in ship records.Assignment of responsibility regarding waste streams.Assignment of responsibility regarding waste streams.Establishing reporting lines to master and senior corporate Establishing reporting lines to master and senior corporate officer regarding nonofficer regarding non--compliance.compliance.

Procedural ApproachesProcedural ApproachesOily Water Separators & IncineratorsOily Water Separators & Incinerators

Operational tests at sea with periodic Operational tests at sea with periodic certification.certification.Training of trainers by experts and vendors.Training of trainers by experts and vendors.Establishment and verification of maintenance Establishment and verification of maintenance schedules.schedules.External audits including operational tests.External audits including operational tests.Sounding logs with signed entries per watch Sounding logs with signed entries per watch and inclusion of sounding in Main Engine Log.and inclusion of sounding in Main Engine Log.Internal monitoring, including routine Internal monitoring, including routine operational testing, reconciling and certification operational testing, reconciling and certification of records.of records.Examples of procedures to regulate OWS use: Examples of procedures to regulate OWS use:

Use restricted to certain engineers.Use restricted to certain engineers.Location Location -- Example: X Miles from shore.Example: X Miles from shore.Time Time –– Example: Daytime only.Example: Daytime only.

Independent soundings and logging by deck Independent soundings and logging by deck department of waste tanks to be included in department of waste tanks to be included in daily position reports and Bridge Log.daily position reports and Bridge Log.

Procedural ApproachesProcedural ApproachesRecord KeepingRecord Keeping

Entries in sounding, ORB, garbage and incinerator logs by Entries in sounding, ORB, garbage and incinerator logs by person who performed task. Eliminate practice of having 3person who performed task. Eliminate practice of having 3rdrd

party sign entries.party sign entries.ORB examined and signed by Chief Engineer and Master.ORB examined and signed by Chief Engineer and Master.Signature lines for all those involved in overboard discharges Signature lines for all those involved in overboard discharges and operational tests.and operational tests.SignSign--on and signon and sign--off certifications (where persons responsible off certifications (where persons responsible for operation certify their awareness of company procedures for operation certify their awareness of company procedures and certify to the use and operability of the equipment at the and certify to the use and operability of the equipment at the turnover at the beginning and end of each contract)turnover at the beginning and end of each contract)Require status of pollution prevention equipment to be Require status of pollution prevention equipment to be recorded in turnover notes of responsible engineer and Chief recorded in turnover notes of responsible engineer and Chief Engineer.Engineer.Sampling and analysis of waste streams to make sure they are Sampling and analysis of waste streams to make sure they are consistent with pollution prevention technology.consistent with pollution prevention technology.

Procedural ApproachesProcedural ApproachesRole of Shore Managers and D.P.Role of Shore Managers and D.P.

Test pollution prevention equipment with actual waste streams Test pollution prevention equipment with actual waste streams while vessel is underway.while vessel is underway.Communicate with all levels of the Engine Department and with Communicate with all levels of the Engine Department and with senior corporate officer to relay findings and concerns. senior corporate officer to relay findings and concerns. Assignment of responsibility to senior corporate officer, Port Assignment of responsibility to senior corporate officer, Port Engineers and Chief Engineers. Engineers and Chief Engineers. Assure adequacy of internal audits and implementation of Assure adequacy of internal audits and implementation of corrective actions. corrective actions. Review of maintenance, log entries and turnover notes.Review of maintenance, log entries and turnover notes.Monitor workloads to make sure that crew prioritizes Monitor workloads to make sure that crew prioritizes environmental compliance.environmental compliance.Assure adequate budget, including waste removal and spare parts.Assure adequate budget, including waste removal and spare parts.Establish comprehensive check list for internal/external Establish comprehensive check list for internal/external inspections/audits. inspections/audits. Explore new technologies. Explore new technologies.

Procedural ApproachesProcedural ApproachesHow to Encourage Employees to Make Internal Reports

Take measures to convince employees Take measures to convince employees that company really wants compliance that company really wants compliance with all applicable laws, including with all applicable laws, including MARPOL.MARPOL.DeDe--couple costs from compliance.couple costs from compliance.Display top level commitment. Display top level commitment. Establish direct and anonymous lines of Establish direct and anonymous lines of communication to senior management. communication to senior management. Zero tolerance for violators and for those Zero tolerance for violators and for those who retaliate against those who report who retaliate against those who report violations.violations.Reward employees who report violations.Reward employees who report violations.Establish safety and environmental Establish safety and environmental compliance as positive factors in compliance as positive factors in employee personnel evaluations.employee personnel evaluations.

Procedural ApproachesProcedural ApproachesAuditsAudits

Internal/external audits while vessel is at sea.Internal/external audits while vessel is at sea.Audits designed to Audits designed to investigateinvestigate environmental compliance.environmental compliance.Use of a comprehensive checklist.Use of a comprehensive checklist.Getting beyond the checklist.Getting beyond the checklist.Unannounced inspections/audits.Unannounced inspections/audits.Verification and analysis:Verification and analysis:

of routine maintenanceof routine maintenanceof disposal recordsof disposal recordsof internal record keeping policiesof internal record keeping policiesof record accuracyof record accuracyof trainingof trainingof written policiesof written policies

Operational testing of key equipment while vessel is underway usOperational testing of key equipment while vessel is underway using actual waste ing actual waste streams.streams.Interviews with all crew members.Interviews with all crew members.Written audit findings.Written audit findings.Review of audits by shoreReview of audits by shore--side management including senior corporate officer.side management including senior corporate officer.PostPost--audit meetings.audit meetings.Implementation and tracking of audit findings and corrective actImplementation and tracking of audit findings and corrective actions.ions.

Internal Monitoring

Analysis of RecordsAnalysis of Records

Alarm PrintoutOil Record Book vs. Bridge Log

Internal Monitoring

Analysis of RecordsAnalysis of Records

Internal Monitoring

Separator discharges exceeding design rates

OWS Rated Capacity 2 m3/hr

Internal Monitoring

Analysis of Analysis of ORBsORBsInternal Monitoring

Data entered to discover fluid losses, discharges, patterns of discharges, inconsistencies, equipment capabilities to make determinations compliance and ORB accuracy.

Technical ApproachesTechnical ApproachesInstallation of Installation of best available technology(OWS, OCM, Incinerator, ODME, MSDS, (OWS, OCM, Incinerator, ODME, MSDS, etc.etc.Upgrade related equipment to minimize Upgrade related equipment to minimize waste production. waste production. PrePre--processing of waste (staged operations).processing of waste (staged operations).Increase tank capacity for various waste Increase tank capacity for various waste streams.streams.System modification to allow inSystem modification to allow in--port testing port testing of treatment systems and development of of treatment systems and development of ClassClass--approved test procedures. approved test procedures. Sampling and testing of waste streams and Sampling and testing of waste streams and effluent to verify technology.effluent to verify technology.Use of cleaning agents consistent with Use of cleaning agents consistent with equipment design and capability.equipment design and capability.

Technical ApproachesTechnical ApproachesControl DevicesControl Devices

Uniquely numbered Uniquely numbered environmental tags on environmental tags on flanges to prevent flanges to prevent unauthorized unauthorized bypassing.bypassing.Use of seals on Use of seals on overboard valves and overboard valves and cross connections.cross connections.Placards.Placards.Surveillance cameras.Surveillance cameras.

Note: Control devices alone cannot guarantee compliance.Control devices alone cannot guarantee compliance.

Technical ApproachesTechnical ApproachesControl DevicesControl Devices

Use of tamper resistant recorder Use of tamper resistant recorder systems, alarms and printouts to systems, alarms and printouts to verify equipment operation, valve verify equipment operation, valve position, flow, OWS position, flow, OWS ppmppm, , incineration, position, etc. incineration, position, etc. Lock boxes/cages on monitoring Lock boxes/cages on monitoring equipment.equipment.Interlocks to prevent tricking of Interlocks to prevent tricking of monitoring equipment. monitoring equipment. Use of meters to record Use of meters to record equipment runequipment run--time and volume time and volume for all engine room pumps.for all engine room pumps.Need to consider how HDQ will Need to consider how HDQ will receive and evaluate this receive and evaluate this information.information.

Note: Control devices alone cannot guarantee compliance.Control devices alone cannot guarantee compliance.

Addressing MotivesAddressing MotivesTo save on cost of offloading To save on cost of offloading waste in port.waste in port.

Response: Response: Emphasize environmental compliance. Have waste removal Emphasize environmental compliance. Have waste removal available in every port. Minimize waste stream. Have flexible available in every port. Minimize waste stream. Have flexible budget for budget for environmental compliance. Remove any financial incentives for cenvironmental compliance. Remove any financial incentives for crew to rew to pollute. Reward compliance. Punish violators.pollute. Reward compliance. Punish violators.

To save on cost of parts and To save on cost of parts and to save maintenance time to save maintenance time necessary if equipment used necessary if equipment used properly.properly.

Response: Response: Emphasize environmental compliance. Have waste removal Emphasize environmental compliance. Have waste removal available in every port. Minimize waste streams. Have flexibleavailable in every port. Minimize waste streams. Have flexible budget for budget for environmental compliance. Remove any financial incentives for cenvironmental compliance. Remove any financial incentives for crew to rew to pollute. Reward compliance. Punish violators. Make essential ppollute. Reward compliance. Punish violators. Make essential parts a budget arts a budget line item. Make Port Engineer responsible for having spares on line item. Make Port Engineer responsible for having spares on board. board. Consider need for equipment upgrade. Consider need for equipment upgrade.

Corporate culture: Corporate culture: Environmental compliance Environmental compliance perceived to be low priority in perceived to be low priority in relation to other priorities. relation to other priorities.

Response: Response: Emphasize environmental compliance. Display top level Emphasize environmental compliance. Display top level environmental commitment through training, policies, audits, etcenvironmental commitment through training, policies, audits, etc. Make . Make environmental compliance a positive factor in personnel evaluatienvironmental compliance a positive factor in personnel evaluations. Reward ons. Reward compliance. Punish violators. Emphasize importance through audcompliance. Punish violators. Emphasize importance through audits, its, turnover, maintenance schedules, and shoreturnover, maintenance schedules, and shore--side supervision. side supervision. Communication with those directly responsible. Consider additioCommunication with those directly responsible. Consider additional staffing. nal staffing.

Equipment not operable.Equipment not operable. Response: Response: Emphasize environmental compliance. Determine root cause. Emphasize environmental compliance. Determine root cause. Consider upgrade. Minimize waste streams. Make operability eveConsider upgrade. Minimize waste streams. Make operability everyoneryone’’s s responsibility. Open lines of communication with shore and flexiresponsibility. Open lines of communication with shore and flexible budget to ble budget to handle contingencies. handle contingencies.

Fear of losing job. Blind Fear of losing job. Blind obedience to authority.obedience to authority.

Response: Response: All of the above. Address cultural issues. Establish direct liAll of the above. Address cultural issues. Establish direct lines nes for reporting violations. Reward and protect employees who makefor reporting violations. Reward and protect employees who make internal internal reports. Zero tolerance for retaliation against employees who rreports. Zero tolerance for retaliation against employees who report violators. eport violators. Report violators to flag state and to port state authorities.Report violators to flag state and to port state authorities.

No fear of getting caught or No fear of getting caught or being subjected to being subjected to consequences by employer. consequences by employer.

Response: Response: Create shoreCreate shore--side and shipboard accountability. Establish side and shipboard accountability. Establish internal procedures that make violations more difficult to commiinternal procedures that make violations more difficult to commit without t without detection. Reward and protect employees who make internal repordetection. Reward and protect employees who make internal reports. Punish ts. Punish violators. Zero tolerance for retaliation against employees whoviolators. Zero tolerance for retaliation against employees who report report violators. Report violators to flag state and to port state autviolators. Report violators to flag state and to port state authorities.horities.

Response Dictates OutcomesResponse Dictates OutcomesDOJ and EPA have existing voluntary disclosure DOJ and EPA have existing voluntary disclosure programs that can lead to nonprograms that can lead to non--prosecution or leniency as prosecution or leniency as appropriate.appropriate.A company under investigation may choose to:A company under investigation may choose to:

Cooperate (including waive privilege and work product Cooperate (including waive privilege and work product doctrine and provide the government with facts from an doctrine and provide the government with facts from an internal investigation).internal investigation).Conduct a comprehensive internal investigation and Conduct a comprehensive internal investigation and determine root causes.determine root causes.Audit entire fleet and take prompt and effective remedial Audit entire fleet and take prompt and effective remedial measures to achieve fleetmeasures to achieve fleet--wide compliance.wide compliance.Promptly and thoroughly produce requested records.Promptly and thoroughly produce requested records.Take disciplinary action taken against violators. Take disciplinary action taken against violators. Support seafarers.Support seafarers.Accept responsibility.Accept responsibility.

How a company responds to an investigation may be How a company responds to an investigation may be factored into the outcome of the case, as well as help factored into the outcome of the case, as well as help determine the companydetermine the company’’s future image. s future image.

Why ?????Why ?????Why do senior engineers and Why do senior engineers and other crew members deliberately other crew members deliberately risk their liberty, career and risk their liberty, career and companycompany’’s image?s image?Why does a convicted company Why does a convicted company continue to commit crimes while continue to commit crimes while on probation?on probation?Why does a company under Why does a company under investigation continue to commit investigation continue to commit crimes?crimes?Why have senior engineers Why have senior engineers deliberately tricked newly installed deliberately tricked newly installed antianti--tricking equipment?tricking equipment?

Why ??? Why ??? ContinuedContinued……..

Why do Port Engineers, Class, ISM Auditors and Flag Why do Port Engineers, Class, ISM Auditors and Flag States not find and/or not report evidence of States not find and/or not report evidence of bypassing to the owner/operator or to port state bypassing to the owner/operator or to port state authorities? authorities? Why do flag administrations not take any action Why do flag administrations not take any action against ship, owner, operator or crew members who against ship, owner, operator or crew members who have been convicted of intentional MARPOL have been convicted of intentional MARPOL violations and deliberate falsification of records?violations and deliberate falsification of records?Why have ISM auditors not recorded major nonWhy have ISM auditors not recorded major non--conformities against ship, owner, or operator after a conformities against ship, owner, or operator after a criminal conviction? criminal conviction? Why do Insurance Clubs pay criminal costs?Why do Insurance Clubs pay criminal costs?

Vessel Pollution & SolutionsVessel Pollution & Solutions

Richard A. Udell *Senior Trial AttorneyEnvironmental Crimes SectionU.S. Department of Justice601 D Street, NW - #2008Washington, D.C. 20004202-305-0361Richard.Udell@usdoj.gov

INTERTANKOMarch 30, 2006

Singapore

* The views expressed herein are those of the author.