US calls time on low-level pollution, mandates enviro-lubricants
The US EPA is bringing in a revised Vessel General Permit this month, mandating the use of environmentally acceptable lubricants for certain shipboard applications while in US waters; David Tinsley explains.
Lubricants have now been brought within the widening sweep of US environmental legislation, adding to all the regulatory considerations facing owners and operators with vessels sailing in US waters. The revised Vessel General Permit (VGP) entering force on 19 December this year ushers in a stipulation that accredited, Environmentally Acceptable Lubricants (EALs) have to be used instead of mineral oils in all oil-to-sea interfaces.
Predicated on the cumulative pollution produced by leakage of lubricants from ships’ underwater components, the EAL requirements are a step change for the industry and have enormous implications, being applicable to commercial vessels over 79ft (24m) in length, irrespective of place and date of construction. It is estimated that some 10%-20% of world tonnage trades to US shores.
The impending mandatory requirements for oil-to-sea interfaces encompass the oils in key components including stern tubes, thruster bearings, controllable pitch propellers, rudder bearings, podded propulsion systems and fin stabilisers. Moreover, any equipment subject to immersion and ensuing oil wash down, such as deck gear and wire rope, should in principle be taken into account under the new VGP, which supersedes the 2008-introduced permit.
The expanded VGP will have a five-year validity and will be brought to bear on all shipping navigating within three miles of US shores and on the Great Lakes. While the US Coast Guard will carry out spot checks of vessels to verify compliance, the EPA is relying on operators to self-report EAL usage. As might be expected with US legislation, violations ultimately run the risk of heavy penalties. However, the provisions of the legislation do offer opportunities for the implementation of requirements to be deferred under certain circumstances.
The VGP also requires that close attention be paid to the suitability and integrity of protective seals to guard against the leakage of hydraulic oils or lubricants.
EALs are defined by the EPA as lubricants that are “biodegradable“, “minimally toxic” and “not bioaccumulative”. The definition includes products endorsed under labelling programmes such as Blue Angel, European Ecolabel, Nordic Swan, the Convention for the Protection of the Marine Environment of the North East Atlantic(OSPAR), the Swedish standards SS155434 and 155470, and the EPA’s own Design for Environment (DfE) scheme. The various labels have set environmental criteria not only for the main constituent of the lubricant, but also for the additives.
Products that do not carry these labels can undergo independent testing and qualify as an EAL so long as EPA standards governing biodegradation, bioaccumulation, and toxicity are met.
EALs are mandatory unless their use is “technically infeasible,” the term employed by the EPA. Although interpretations seem to vary, the official meaning of the term for the purposes of the VGP is as follows:
- Where no EAL products are approved for use in a given application that meet manufacturer’s specifications for the equipment involved;
- Where products which come pre-lubricated (such as wire ropes) have no available alternatives;
- Where EALs meeting the manufacturers’ specifications for their equipment are not available in any port at which the vessel calls;
- Where changeover and use of an EAL must wait until the vessel’s next planned drydocking.
If an owner or operator finds it “technically infeasible” to use an EAL, the reasons must be documented.
The provisos indicate a pragmatic approach on the part of the EPA, especially if it allows the uptake of the requirements to be in line with scheduled drydockings. Our understanding is that if a drydocking is necessary to substitute the mineral oils with EALs, a vessel may operate in US waters until its next drydocking, when the changeover would take place.
Furthermore, the fact that the technical feasibility of EALs encompasses equipment manufacturers’ approvals as well as biodegradability, minimal toxicity and non-bioaccumulative properties is widely regarded in the industry as prudent. However, with the roll-out of the EAL mandate in line with drydocking and product development, it could be some years before the full effect of the new VGP is felt.
Total Lubmarine recently launched its online virtual vessel, a user-friendly and visual way to illustrate the various areas of a ship that require lubricants. Several main areas, such as propeller shafts and stern tubes, regularly suffer from leakages that can remain undetected for long periods of time. The animated graphic also facilitates matching each element with a corresponding lubricant, and provides a useful tool to assist shipowners and operators in identifying suitable products to ensure vessels are VGP-compliant.
A range of biodegradable, non-toxic and non-bioaccumulative EALs for use in oil to sea interfaces has been developed by Total Lubmarine. These are largely ester-based, thereby offering higher durability and lower toxicity than mineral lubricants. For example, Bioneptan, a biodegradable stern tube lubricant manufactured with synthetic ester base oils, is claimed to offer increased thermal and oxidation stability, enabling almost four-fifths of the oil to return to its original carbon and water state within 28 days.
Following rigorous independent testing, and European Ecolabel certification, Bioneptan meets EAL criteria and therefore VGP requirements.
“As regulatory and commercial pressures persist, lubricant suppliers such as Total Lubmarine are developing products that directly support shipowners and operators in achieving both financial and environmental objectives,” stated the company. “Close collaboration with OEMs and customers will ensure that solutions are continuously developed to ensure regulatory compliance while at the same time enhancing performance and minimising financial loss.”
Specialist supplier Vickers Oils confirmed that its bio lubricant ranges Hydrox Bio (for use in stern tubes and stabilisers), Ecosure HSE (for controllable pitch propellers, stabilisers and deck gear) and Biogrease EP2 (for chains, ropes and rudder gear), qualify as EALs, meeting the detailed ecological definitions and requirements laid out under VGP 2013. Biogear XP (for thrusters) is also expected to comply. Castrol said that its BioStat and BioBar product ranges are registered under OSPAR, and therefore meet the EAL criteria.
In response to VGP legislation, ExxonMobil has developed a range of synthetic marine lubricant products that are not only VGP-compliant, but offer additional performance benefits. “While EALs are new to many equipment manufacturers, we are working closely with them to raise awareness of the VGP requirements and gain any new endorsements that may be required, so shipowners can comply without compromising their operating efficiency,” said the company.
New lubricant formulations meeting the demands of the US legislators will inevitably impose higher product purchase prices for the shipping industry. But a key technical issue with bio oils in general is that they are often aggressive towards the types of sealing ring material currently used in lip seals. Although certain seal manufacturers report that they have tested a number of bio oils and identified those which they approve for a five-year docking cycle with new sealing developments, it appears that quite a number of the oils have yet to be endorsed to the required EAL standards.
Wärtsilä claimed an industry breakthrough in October when it unveiled a seal conforming with the latest EPA legislation and designed to work with EALs over a lifetime of at least five years in stern tube applications with fixed pitch propeller systems. The new Bio Seal Ring, developed for use with ester-based biodegradable oils, allows customers to upgrade from conventional seal rings, which should be changed at two and a half year intervals when subject to biodegradable lubricants.
All international waters are legislatively protected against accidental spills of oil and chemicals under IMO’s Marpol regulations. The US EPA’s initiative on EALs is the first enactment of its kind to address the impact of low-level and day-to-day chemical discharges. The concept of using environmentally compatible lubricants is also a facet of IMO’s Polar Code, currently in draft form.
According to the EPA, several million litres of mineral oil-based lubricants are discharged into commercial harbours each year through stern tube leakage alone. Once accepted as part of normal operational consumption, this has become an oil pollution issue, because it is now acknowledged as being a significant source of lubricant oil input to the aquatic environment.
Additionally, millions of litres more are estimated to enter the water from other oil-to-sea interfaces and from deck equipment and gear. Hydraulic oil can leak from CPPs if the protective seals are worn, defective or unsuitable, while lubrication oil can be lost from the propeller shaft and its supporting bearings due to seal deficiency or damage.
Frequent low-volume operational discharges and leaks of lubricants do not result in the type of response generally applied in major oil spills. But the aggregate amount and effects of this type of pollution has now spurred the US into taking all possible measures to ensure that the harmful effects of leaks are neutralised, given the fact that the risk of leaks and spills is impossible to eliminate. At the same time, there have been significant advances in engineering designs for stern tubes that reduce or eliminate the use of lubricating oil, such as seawater-lubricated propeller shaft bearings.
With its much broader remit than the 2008 VGP regarding discharges incidental to the normal operation of commercial vessels, the updated permit covers bilge water, ballast water, hull antifouling, cathodic protection, ‘grey’ water and exhaust gas scrubber waste water as well as lubricating oils and other fluids.
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