Houston Explains Effects of EPA Regulation Mandating Environmentally Acceptable Lubricants in Dredges
Matt Houston market manager for marine construction for RSC Bio Solutions discussed the 2013 vessel general permit and Environmentally Acceptable Lubricants at PIANC’s Dredging 2015. His presentation was entitled “New EPA Regulations for Environmentally Acceptable Lubricants and their Effect on the Dredging Industry.”
The conference was held at the Savannah Hyatt Regency Hotel Savannah Georgia on October 19 through 22.
The 2013 Vessel General Permit (VGP) enacts discharge regulations for vessels operating in U.S. waters to keep them in compliance with the Clean Water Act. It requires all vessels including dredges longer than 79 feet to replace traditional petroleum lubricants with “Environmentally Acceptable Lubricants” (EALs) in all oil-to-sea interfaces unless technically infeasible. The permit is applicable to all vessels operating within three nautical miles of the U.S. coastline in the Great Lakes and in the inland rivers and waterways of the U.S.
RSC Bio Solutions formulates readily biodegradable products for land and marine applications including hydraulic gear and grease lubricants as well as cleaners that comply with the requirements of the 2013 VGP and sVGP (regulating small vessels).
The VGP addresses the fact Houston said that lubricant discharges from marine vessels can add up to seven to 16 million gallons per year in U.S. waters.
The dredging industry faces unique challenges operating heavy equipment in sensitive areas he said. Projects are contained by regulatory constraints attention to environmental impacts and public perceptions as well as the consequences of spills and leaks balanced by profit pressure that places a premium on equipment uptime and longevity. Large spills attract the most attention but small spills can be even more damaging because they are more likely he said.
“The dredging industry is under constant scrutiny by the EPA Coast Guard Army Corps of Engineers local government and the general public to protect the environment. Spills leaks and discharges from petroleum are costly with fines downtime and cleanup. EALs and cleaners are viable alternatives offering both safety and performance benefits that minimize the risk” Houston continued.
STANDARDS FOR COMPLYING
RSC Bio Solutions has developed EALs to enable dredging shipping and barge and towing companies to comply with the new VGP. Compliant fluids are defined by the EPA according to three standards: 1. Rate of biodegradation – fluids must be readily biodegradable and completely biodegrade to CO2 water and mineral salts within a given time frame – 60 percent or more in 28 days; 2. aquatic toxicity – minimum toxicity to aquatic organisms such as daphnia algae and fish is determined by careful additive selection and level; and 3. bioaccumulation or build-up of chemicals within tissue of organism must be very low potential.
Houston cautioned vessel operators to be sure to ask for the supporting detail of the certification before using it in their vessels. Compliance is demonstrated through independent laboratory testing of these characteristics or through one of five accepted EU labeling programs he said. These certifications are acquired by the fluid manufacturers who ensure that their customers are in compliance with the permit. Houston noted that EU labeling programs advocate bio-based content which have a far shorter fluid life.
Biodegradation is a commonly misused term Houston said and the misleading terms “environmentally safe” and “environmentally friendly” are used to cover up the fact that the products cannot claim more than 60 percent degradation in less than 28 days.
He described the characteristics of compliant environmental oils which are manufactured for specific purposes with varying durability viscosity oxidative and hydrolytic stability seal compatibility temperature range and mineral oil compatibility.
There are four classes of EALs recognized in the VGP and sVGP Houston explained. They are Hydraulic Environmental Triglycerides (HETG); Hydraulic Environmental Polyalkylene Glycols (HEPG); Hydraulic Environmental Synthetic Esters (HEES); and Hydraulic Environmental PAO (polyalphaolefins) and related products (HEPR).
“Understanding the requirements and limitations of the application allows us to recommend the best EAL” Houston said. “For example while we offer HETG fluids for land applications we more often recommend HEPR for marine applications.”
“Sources of spills would be in seal failures or hose ruptures in thruster bearings and ladder pumps. In vessels and tugs the sources would be seal/hose failure in oil-lubricated stern tubes controllable pitch propellers (CPPs) azimuth thrusters and runoffs from the deck equipment of cranes winches and wire rope” Houston said.
The heavy demands on dredging equipment especially on cutting tools and drives make leakages more likely.
“For Great Lakes Dredge & Dock our environmentally safe lubricants are working in the gear drives that turn the cutter on the 30-inch cutterhead dredge Texas. Often there are seal failures from pressure of dredging rocky materials on the seafloor” Houston said.
Other dredge components subject to leakage into the water are dragheads hydraulic doors gearbox drives ladder pumps and hydraulic and lubricating systems on excavators cranes barges and workboats.
Manufacturers have developed a range of EALs certified to bring a vessel into compliance with the VGP and sVGP. For marine applications RSC Bio Solutions offers three versions of its EnviroLogic® Readily Biodegradable Hydraulic Fluid in addition to readily biodegradable gear and thruster oils rope and chain oil grease and two cleaner concentrates. (The 2013 VGP revision requires any above-waterline hull or deck cleaning to be conducted with “minimally toxic phosphate free biodegradable” cleaners.)
The cost of changing to and using the moreexpensive EALs is a real concern among vessel operators. Houston related the experience of a drilling rig customer who looked at the effects of converting to RSC Bio Solutions’ EnviroLogic 3046 hydraulic fluid who compared it with a traditional petroleum product in terms of four expense categories: regulatory fines; maintenance repair and operations (MRO) costs; fluid top-up costs post-initial fill; and fluid cost at initial fill.
The customer ascertained that because the Product and Proformance News EAL ensures regulatory compliance meets or exceeds the performance of the petroleumbased product and runs the equipment with less downtime and better operational efficiency the benefits more than compensate for the initial fluid cost.
Additionally the life of the synthetic EALs can be as long as eight years compared to a much shorter replacement time for petroleumbased fluids.
Vessel owners were required to submit new permit applications on March 19 2013 and a Notice of Intent (NOI) to comply with the new regulation on December 12 2013. All vessel general permits expired as of December 19 2013. The first annual report detailing the vessel’s compliance with the permit was due on February 28 2015.
The 2013 permits expire at midnight December 19 2018.
SMALL VESSEL PERMITS (SVGP)
A moratorium was placed on the small vessel (less than 79 feet) permit requirements in 2014 as a result of a view held by policy makers that discharges from small vessels under the control of the EPA permit are not a significant environmental problem though this view is not universally shared.
Also included in that legislation was a moratorium on compliance with a regulation concerning ballast water control because there was no consensus over whether compliance was possible given existing technology.