EPA Releases New Vessel General Permit Guidelines

The second issuance of the EPA’s Vessel General Permit (VGP) took effect December 19 2013 replacing the first one issued in 2008. The permit affects commercial vessels greater than 79 feet in U.S. waters to monitor incidental discharges in normal operations as defined in the Clean Water Act.

Section 2.2.9 of the VGP pertains to dredging operations as follows: the protective seals on oil-to-sea interfaces must be maintained in good working order; after applying lubrication to wire rope and mechanical equipment subject to immersion equipment must be thoroughly wiped down to remove excess lubricants; and most important all vessels must use Environmentally Acceptable Lubricants (EALs) in all oil-tosea interfaces.

All commercial vessels including dredges are required to comply with these standards as of December 19 2013 except where “technically infeasible” which in reality gives dredges some time to comply with the new standards. Realistically they can wait until their next dry dock.

Michael Dunbar president of Ryzhka International recommends changes to dredge lubricants sooner rather than later. His company started in May 2011 supplies lubricants to the dredging industry and others mainly to the Corps of Engineers to operate its dredges.

Although it will probably take a year or so before the industry sees more changeover Dunbar said environmental standards can easily become issues for political and environmental groups that target the dredging industry. “Show them you’re part of the solution not the problem” Dunbar said.

These guidelines should have been no surprise in their final form. EPA worked to inform the oil and lubricant manufacturers about the pending changes Dunbar said.

Additionally European markets have long been more attentive to environmental issues for oils and lubricants than the U.S. Jared Mikacich sales and marketing manager for Panolin said. The Switzerland-based company has been producing environmentally sensitive lubricants for 30 years in business much longer and is fairly new to the U.S. dredging market. Panolin is primarily predominant internationally and its lubricants have long complied with European standards like Blue Angel Swedish Standard and European Ecolabel.

Panolin has produced land-based lubricants internationally for 60 years and had to meet the European standards which have a stringent environmental approval process that doesn’t exist in the U.S. for EALs. Mikacich said that while there’s no approved list of products for the U.S. no one has astronomical costs for environmental approvals either. However Mikacich did say the lubricant industry is lobbying for such a list of approved EALs with the hope that it will standardize the market. To meet the EPA standards manufacturers must present their test results to customers to prove compliance.

“Some people are seeing the VGP as superseding a lot of Eco labels in Europe” Mikacich said though he noted it also depends on many factors like the availability of renewable sources and the location of vessel operations.

Advantages of EALs

One of the upshots of EALs Dunbar said is that because the products are synthetic in nature they last longer than mineral-based oils. While there is an upfront cost increase (synthetics cost three to four times more) they also last three to four times as long. Synthetics can be used longer and the cost savings comes in the long term.

“In the past lubricants were almost a disposable product” Mikacich said. “Now they’re a higher dollar commitment initially but easy to justify when you have less down time and more efficiently running equipment.”

EALs are defined by the EPA standard as biodegradable minimally toxic are non-bioaccummulative meaning they do not build up chemicals within aquatic organism tissue and will not produce a sheen.

Mikacich said the 2013 VGP identified lubricants more correctly as minimally toxic rather than wholly non-toxic because everything is toxic at some level.

As an alternative to mineral-based oils EALs are being made from synthetic materials like polyalkylene (PAGs) or Polblycol (PGs) synthetic ester and vegetable oil. More traditional mineral-based products (PAOs) could become environmentally friendly with additives but so much would be needed it reduces the performance of the oil Mikacich said.

Vegetable-based oils can be extremely environmentally friendly but not necessarily equipment friendly. There may be issues with gumming and sludge; vegetable oil-based products often don’t tolerate heat variations or moisture well. See the chart on this page for some of the pros and cons in different EAL base synthetic materials.

While the EPA standard for EALs designated that they should not produce a sheen Mikacich argues that this is secondary to the other requirements. “When people see a sheen they have a dramatic response” Mikacich said. However a lot of fluids sink in water and don’t create sheen but do cause problems on the seafloor.

Dunbar would argue that a sheen might be necessary for detecting a spill should one occur. With clear lubricants and no sheen products that sink to the seafloor could unknowingly build up.

In any operation the use of lubricants EALs or otherwise should be monitored properly and documented.

All new builds after December 19 must comply with the lubricant regulations and older dredges that are unable to use EALs for the time being must document the reasons why and report the use of any non-EALs.

Dredge Compliance

Dredges may need EAL lubricants and oils for engines and gears deck grease and moving parts like winches. The biggest player in EAL lubricants for dredges is for hydraulic systems Mikacich said.

Panolin calls its lubricants ECLs (Environmentally Considerate Lubricants) but they are made of synthetic ester and meet all the EAL standards in the EPA’s VGP. Mikacich makes a distinction between fully saturated and unsaturated synthetic ester compounds likening unsaturated to a chain dipped completely in a protective coating while partially saturated is only partially protected and not as robust. Panolin uses fully saturated synthetic ester.

In terms of the VGP guidelines the biggest concern for dredges are lubricants for hydraulic systems. Panolin’s main lubricant for dredge hydraulic systems would be HLP Synth which meets all the EAL standards.

As the VGP guidelines have just become effective and dredges have some leeway they are mostly researching different lubricants and checking compatibility with their hoses and seals Mikacich said. “Then it comes down to availability and price” he said. “Normally those would be at the front end not the tail end. Now people want to know about compatibility and choose a base oil technology that they like.”

To learn more about EPAs VGP guidelines visit http://www.epa.gov/npdes/pubs/vgp_permit2013.pdf.