Thursday, 1 July 2010

Trafigura: Amsterdam 2 Busch Response

Dr Busch has responded by email to my 2nd post in the series about the Probo Koala’s waste and Amsterdam.  If you haven’t read that  post you probably should so that Busch’s response and my reply to that makes a tad more sense.

Again I make no apology for publicising Dr Busch’s emailed response.

He said,

“This babble about COD is a red herring. Didn't the sudden drop from 500,000 mg/l to 21,000 mg/l in tests on the same materials without any explanation by APS not raise any doubts about their competence in testing for COD levels?

COD measures the organic compounds in a mixture which, when digested by aerobic or anaerobic bacteria will remove oxygen from the surrounding water. A high COD is evidence that the wastes should be processed before being released into the community water systems. That is why Trafigura contracted with APS to process the slops in the first place.  It is a quicker test than the BOD and can be used to extrapolate BOD readings.

I can agree that if APS didn't treat the slops and poured the wastes into the Dutch water system it would have had the capacity to affect the water supply. That is why MARPOL insists on procedures being put in place for registered Marpol sites to deal with these pollutants properly.

What you are highlighting is why the slops were there in the first place.

For your guidance I attach a background on COD.

If you are interested, check out the COD for hand soap, fresh milk or cream and get excited about their high COD numbers.”

He also appended a paper on Chemical Oxygen Demand (COD).

Some, even many of you, may wonder why I continue to question Dr Busch’s statements.

I think it is always worthwhile to have one’s views challenged but, more importantly, this gives the reader more information on which to form his/her own views.

It is important that you do not simply accept Dr Busch’s views, my views, Trafigura’s, Greenpeace’s or whoever’s as THE truth.  You need to discriminate.  That is what I attempt to do.

At one level I agree with Dr Busch that the issue of COD is a red herring BUT not in the way he supposes nor in a way which supports his case.  I’ll come to this in a later post.

BUT, in the context of my post, COD is far from being a babble and is far from being a red herring …. as Dr Busch knows well or should.

Dr Busch’s argument is so specious it does him – an educated man - no favours.

His argument is summarised by this sentence,

“What you are highlighting is why the slops were there in the first place.

No!”, Gary, “a thousand times no!”

THE COD test was carried out because the slops were there but not only because they were there.  The APS quote contained this condition.


The quotation was based on Trafigura’s product – the waste – meeting this specification.  Trafigura accepted the quote and its terms. Failure to meet this specification and the quote would fall and Trafigura’s product failed spectacularly – by a factor of 10 on COD and of 50 on TOCl (total organic chlorine).

We must assume that the APS condition inserted in their quote was a standard term for the product they expected to receive.  Therefore the conditions  - including COD - were important to APS. 

Why the exact levels in the terms are important I don’t know but I assume they are a trigger point above which the process changes and the costs increase.  If Dr Busch knows then he is keeping silent.

BUT don’t just accept my word or APS’ on the importance of COD and these conditions, in general.  Don’t just accept Dr Busch’s word on the irrelevance of COD. Listen to Trafigura.

Trafigura knew their importance.

Read this extract of an email from Trafigura sent a few days prior to the Probo Koala arriving in Abidjan.

Doc7 p1

Read that carefully.

Because the COD is larger than 2000mg/l the wastes are to be treated as Chemical Slops and not Marpol Slops. 

Trafigura knew there was a trigger point in treatment. 

APS were right, COD was important!

COD is not the red herring Dr Busch would have us believe. 

You were right to “not just accept” his word.

1 comment:

  1. While I appreciate the time you take to read my missives and your attempt to be fair I should only like to point out that the message from Trafigura referring to the COD means that the slops were Annex 2 (Chemical slops) as opposed to Annex 1 (oily slops) which may be what APS were expecting. This difference was commented on by the Dutch Enviromental Police who examined the APS evidence and cleared the wastes to be reloaded on the Probo Koala. The Trafigura message was badly phrased because it seems to differentiate between Marpol and chemical wastes but this was shorthand for Annex 1 and Annex 2 Marpol slops. It's no great mystery.