New US EPA Regulations:
Environmentally Acceptable Lubricants
Proposed Vessel General Permit - VGP
Proposed Small Vessel General Permit – sVGP
Presented by:
James Kovanda
Vice President
American Chemical Technologies, Inc.
MarineLink.com
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House Addresses Great Lakes Dredging Crisis
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Great Lakes Maritime Task Force - Monday, April 23, 2012
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The end of the Great Lakes dredging crisis took a
step closer to reality last week when the U.S. House
of Representatives passed H.R. 4348 and included a
provision that could lead to substantially increased
Great Lakes dredging funding. The amendment
directs that all funding collected in the Harbor
Maintenance Trust Fund be spent on dredging each
year.
A move towards alternative lubricants-WHY?
Deepwater Horizon - catastrophe
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The National Oceanic and Atmospheric Administration
(NOAA) estimates that more than 700 million gallons of
petroleum enter the environment each year, more than half of
which is through irresponsible and illegal disposal.
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Oil leakage from stern tubes (let alone CPP’s and propulsion
systems in general), once considered a part of normal
“operational consumption” of oil, has become an issue of
concern and is now considered as oil pollution.
Spills/Discharges – Some Facts
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A 2010 study estimated that of 4,708 ports/harbors worldwide,
stern tube leakage amount to 1.2 to 7.5 M gallons per year –
from 1.7M port visits (Etkin, 2010)
In addition, 8.5M leaked of oil from other operational discharges
Total – 9.7 to 16.1 Million Gallons into Marine Port Waters
Annually
 – the equivalent of about one and a half Exxon Valdez-sized spills
US EPA – White Paper
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EPA contracted an independent lab to conduct a battery of
tests with the purpose of drafting a White Paper - Draft
The purpose of this document was to describe the range of
environmentally preferable lubricants that may be used as a
best management practice (BMP) by operators of vessels
covered under the Vessel General Permit for Discharges
Incidental to the Normal Operation of Vessels (VGP / sVGP)
The document defines what they are calling
“Environmentally Acceptable Lubricants” – EAL’s
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Differentiating them from “Environmentally Friendly Lubricants”
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White Oils now fit into the EFL category
US EPA - “Environmentally Acceptable Lubricants”
Goal: Provide Reduced Environmental Impact Compared to
Conventional Lubricants – 3 Categories Tested
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Biodegradation
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(Aquatic) Toxicity
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Process of chemical breakdown of oil caused by
organisms or their enzymes into carbon dioxide and
water
Concentration in ppm or milligrams per liter that kills a
given % of the species being tested
Bioaccumulation
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The build-up of chemicals within the tissues of an
organism over time.
US EPA – White Paper Test Protocol
•
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“Readily” Biodegradable
 “> 60 % biodegraded on OECD 301 A-F”
“Low (Aquatic) Toxicity”
 OECD 201 – 212
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•
Food chain - Algae / Daphnia / Fish
“Non-Bioaccumulative”
 OECD 107 & 117
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Partition Coefficients of Log Kow < 3.0
White Paper - Conclusions
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Because the majority of a lubricant is
composed of the base oil, (3) types that are
biodegradable were identified as EAL’s:
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Vegetable Oil
Synthetic Ester
Polyalkylene Glycol (PAG)
Vegetable Oil
PRO’s
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Least Costly EAL
Renewable Content
Compatible with Petroleum
base oils
Good Lubricity
High Flash Point
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CON’s
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Poor Performance at both
low and high Temperature
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Poor Oxidation Stability
Hydrolytically Unstable
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Reacts with water
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Some are FM Approved
Unsaturated molecule
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Reacts with catalysts to form
sludge/varnish as
decomposition products
Short Life Cycle
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Produces Acid as byproduct
12-18 months
Produce Sheen
Synthetic Ester
PRO’s
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High Viscosity Index
Good Oxidation Stability
Good Lubricity
Compatible with Petroleum
base oil
Long Life Cycle
CON’s
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Highest Price EAL
Hydrolytically Unstable
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Reacts with Water
Paint Compatibility
Seal Compatibility
Produce Sheen
Polyalkylene Glycol - PAG
PRO’s
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Best High/Low Temperature
Properties
Inert to Water
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Good Lubricity
Chemically incapable of
producing varnish
Only Non-Sheening EAL
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Limits - 1.5% salt 2.5% fresh
Heavier than water
Water Soluble
Non-bioaccumulative
Factory Mutual Approved
CON’s
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Paint Compatibility
Seal Compatibility
3-4 times price of
conventional petroleum oil
“Sheen” Performance Comparison
- 40 CFR 435 Static Sheen Test
“Lastly, any discharge of oil, including oily materials, from any of these oil-tosea interfaces may not result in a discharge that may be harmful as defined by
40 CFR Part 110 or result in the production of a visible sheen”.
- Proposed 2013 VGP Fact Sheet, Page 136
VGP – Language Pertaining to EAL’s
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VGP - Vessels 80’ and longer
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2.2.9 Controllable Pitch Propeller and Thruster Hydraulic
Fluid and Other Oil-to-Sea Interfaces Including Lubrication
Discharges from Paddle Wheel Propulsion, Stern Tubes,
Thruster Bearings, Stabilizers, Rudder Bearings, Azimuth
Thrusters, Propulsion Pod Lubrication, and Wire Rope and
Mechanical Equipment Subject to Immersion
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All vessels…… must use an environmentally acceptable lubricant
in all oil-to-sea interfaces. “Environmentally acceptable
lubricants” means lubricants that are “biodegradable” and “nontoxic” and are not “bioaccumulative” as defined in Appendix A of
this permit.
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Page 43
sVGP – Language Pertaining to EAL’s
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Vessels 79’ and shorter
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2.3 ENGINE AND OIL CONTROL
(h) Unless technically infeasible, you must use
environmentally acceptable lubricants (as defined
in Part 6 of this permit) in all machinery and
equipment, including but not limited to stern
tubes, wires, and two-stroke engines, where
discharges of oil to surrounding waters are likely
to occur.
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Page 4
Applications that put Vessel Operators at
risk in the event of leaks
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A “vessel is its own
containment”
Applications that pose
risk
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Propulsion Systems
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CPP’s, Thrusters, etc.
Deck Machinery
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Hydraulically operated
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Cranes
Winches
Hatches
Dredges
Seal Testing – USACE Wheeler Dredge - CPP
Industry standard is change in volume and
change in hardness at 1000 hours of less
than +/- 12% when exposed to fluids that
are ≤ ISO viscosity grade 46 and +/- 10%
when exposed to fluids that are ISO
viscosity grade > 46.
1000 hrs.
DUROMETER ASTM D 2240-05(10):
Shore A Durometer Point
Confidence (+/-)
86
1
FLUID IMMERSION PROPERTIES, ASTM D 471-10
Elastomers immersed @ 65ºC in UCON™ Trident™ AW-68 lot 31095.
Durometer,
points change
-0
Volume
Change %
+3%
Weight
Change %
+6%
Time Frames – VGP/sVGP
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“All Vessels constructed on or after December 19, 2013 must
use an environmentally acceptable lubricant (EAL) in all
oil-to-sea interfaces”.
“For all vessels built before December 19, 2013, unless
technically infeasible, owner/operators must use an EAL in all
oil-to sea interfaces”.
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“Technically Infeasible”
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Equipment must be “retrofitted” to accept EAL
If EAL significantly degrades performance
NOTE: If deemed Technically Infeasible, owner/operator must document why they
cannot use EAL, and must note the use of a non-EAL in the vessel’s Annual Report.
Note: Dispersants, detergents, emulsifiers, chemicals or other
substances that remove the appearance of a visible sheen may not
be added to the bilge.
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sVGP – Section 2.3 ENGINE OIL CONTROL, (j)
Do EAL’s Provide Vessel Operators Value?
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Do EAL’s = Net Expense?
If selected properly, EAL’s will drive value
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Yielding Long Life and Extended Drain Intervals
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Lasting up to 4-5 times longer than conventional oil
Added Bonus – In the event of a leak into a
sensitive waterway:
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EPA and US Coast Guard should be satisfied with
your conscious use of EAL lubricants
If PAG is in use, there will be no sheen, and no
need for remediation
THANK YOU