The owners of a crude gathering / distribution facility were experiencing significant monetary losses due to the misrepresentation of “free water” volumes loaded on barges for their trade partners. The ACA MTS Loss Control team was engaged to investigate the issue, determining that the paraffinic nature of the crude was causing an inability of the third-party Inspection services to accurately quantify the correct volume of water loaded. Our MTS Team produced a detailed, written procedure to amend the on-site inspection and testing process for the facility owners, and initiated an oversight program, resulting in an approximate savings of $1.5 million per month for the next 3 years.