Part One: by James Burton
The commercial marine industry in the United States has very recently come under the microscope by the U.S. EPA as new, strict environmental guidelines have been put in place that will have a major effect on all vessel operations, design, and maintenance practices. Along with reducing engine exhaust emissions and subsequent air pollution from the use of cleaner fuels, scrubbers, and more efficient engine and hull designs, the other category that the U.S. EPA is trying to greatly reduce or eliminate is the approximately 100,000,000+ liters of “free oil” that is discharged worldwide from commercial vessels and ships annually. This “free oil” is basically the various oils used to lubricate and transmit power in such applications as stern tubes, stabilizers, azipods, bow thrusters, hydraulic steering systems, as well as deck machinery, such as cranes, winches, and drum reels. Through normal wear and tear, oil can leak directly into the water caused by worn and leaky seals on steering and propulsion systems, or could enter the water as a result of blown hydraulic hoses from hydraulic equipment used onboard the vessel.
Currently, the U.S. EPA controls all operations of commercial vessels over 80 feet in length under the heading known as “Vessel General Permits” (VGPs), including all liquid discharges from commercial vessels from sewage, bilge, and ballast water, as well as discharges of oil and petroleum products.
This year, the U.S. EPA drafted and finalized the newest edition of the Vessel General Permits and has included a second category for all commercial vessels 79 feet in length and under called the “small Vessel General Permit” (sVGP). These new regulations come into effect as of December 2013 and one major category being introduced is the mandatory use of U.S. EPA-approved “Environmentally Acceptable Lubricants” or “EALs” as they are being referred to in the new regulations.
Under the new regulations or the “white paper,” vessel operators must implement the use of an approved EAL or be required to maintain extensive, accurate daily records and inspections on all affected equipment and fluid levels to monitor any leaking or discharges of oil or other hazardous substances in order to be in compliance with both the U.S. EPA and the U.S. Coast Guard. These products include the lubricating oils that are directly used in applications referred to as “oil-to-sea interfaces,” where the only thing holding the oil from entering the water, and the water entering the machinery, is a simple seal or gasket, such as a stern tube seal. These lubricants would include stern-tube lubricants as well as various types of gear and hydraulic fluids used in applications such the propulsion and steering mechanisms. Engine oils and heat exchange coolants are not included in this category, as the vessel’s hull acts as a “catch basin” for any leaks or accidental discharges, so accidental discharges are highly unlikely.
The U.S. EPA has set out the criteria for what is required to classify or be considered a U.S. EPA-approved Environmentally Acceptable Lubricant, or EAL:
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The first is that the product has to have a biodegradability rating of 60% or more in 28 days (the minimum criteria to also be classified as “readily biodegradable”) in order to be considered an EAL. Products marketed as “inherently biodegradable” or “environmentally considerate” mineral oils or white oils offered by many major oil companies are not included in this category. These products are generally hydraulic oils with the zinc/phosphorous (ZDDP) anti-wear additives removed to eliminate heavy metals and reduce aquatic toxicity but fall short of the required 60% biodegradability in 28 days, and they are still refined petroleum products. They also possess reduced anti-wear capabilities since the main anti-wear additives have been removed and will not meet the warranty standard of some component manufacturers and equipment OEMs.
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The second is that the product has to meet or exceed very low aquatic toxicity criteria in order to have the lightest possible impact to the marine environment.
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The third is that it must not be bio-accumulative to any organism or any part of the food chain.
The U.S. EPA has determined that four major types of lubricants meet all the necessary required criteria to be classified as an “approved EAL.” They are as follows:
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Vegetable Oils (such as canola or soy oil-based)
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Synthetic Esters (esters derived from bio-based sources)
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Polyalkykene Glycols (can be either water-soluble or water-insoluble)
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Water (referring to water-lubricated and cooled stern tubes)
Each type of fluid has been dissected and scrutinized in various papers and articles for their advantages and disadvantages regarding the performance, fluid life span, component compatibility, conversion techniques, and overall fluid cost. There seems to be some bias toward certain types of lubricants that are compatible with other oils, but there are a variety of other factors and facts that are either passed over or seldom if ever mentioned about the features and benefits, as well as the disadvantages of other alternative EAL products. In fact, there is a fair amount of ignorance, along with some outright false statements, often made in regards to certain types of EALs, as well as a lot of assumptions of both performance and environmental issues concerning the use and implementation of various EAL products. This article will examine the real issues regarding the use, advantages and disadvantages, environmental impact, as well as environmental compliance regulations regarding these products that often go unmentioned.
Environmental Concerns Regarding EALs
The EPA is mandating the use of these approved EALs in an attempt to greatly reduce or eliminate the long-term environmental damage caused by current “free oil” discharges. Most approved EAL products are still oils of some type, with the one exception being what is referred to as water-soluble Polyalkylene Glycols. While readily biodegradable “oils” may biodegrade rapidly and are considered not bio-accumulative and very low in toxicity, they are nevertheless “oil” and will float, causing a slick or sheen on the surface of the water in the event of a spill or discharge.
Having an EAL that behaves in such as manner sounds quite simple and logical. Since all oil tends to float, it can be easily recovered if spilled into water. Or can it?
The reality of marine oil spill cleanup attempts and the amount of actual oil recovered generally represent a very small percentage of the oil spilled and even in near-perfect conditions, there is the time delay to identify and react to a spill and to deploy appropriate cleanup apparatus and procedures.
In the real world, it is not all that simple and straightforward to recover oil discharged into water as the ideal conditions seldom or never actually exist. Strong river and/or tidal currents, along with wind and wave action, very often combine to make the situation difficult or even dangerous to try to deal with. The excessive strain in hydraulic equipment in poor conditions and rough seas is where discharges are most likely to occur, creating dangerous or often futile spill recovery attempts.
Oils of any type, spilled into a river or moving in a body of water, are usually carried downstream by the current way before remedial action can be taken. Far too often, by the time the leaks or discharges are noticed, the slick has migrated far downstream and in the case of large navigable rivers, are generally impossible to recover.
So what’s the big deal if the readily biodegradable hydraulic oil is very low in aquatic toxicity and readily biodegradable? After all, won’t most of it disappear in a month or so? Yes, as it will not leave bio-accumulative toxins and will disappear much faster than petroleum oil, but it is the actual oil itself, regardless of the environmental profile, that does the majority of the damage to marine life. It is true that while a non-toxic vegetable is floating on the surface of the water, it has very little or no affect on fish, but the surface marine species, such as seabirds, otters, shorelines, estuaries, and marshes are greatly affected. When species such as marine mammals and birds are coated with any oil, the result is that they try to lick the oil off and get sick in the process, but the most serious threat is that when they are saturated in oil, their down layer is rendered useless and the animals die of hypothermia. Marsh and shoreline invertebrates and other species, such as amphibians, also smother in the oil.
A couple of major spills of non-toxic, food-grade canola oil in Vancouver, BC harbor in 1999 and 2000 resulted in over two thousand seabird fatalities and required the same cleanup and wildlife rescue effort as if the spill was from a petroleum oil. In Germany in 2006, another spill of rapeseed, or canola oil, produced similar results, leading many environmentalists and regulators to question the use of biodegradable “oils” as “environmentally friendly lubricants.” These factors and events prompted Transport Canada, who polices the “Canada Shipping Act,” to rethink the idea of “biodegradable oil” and what really are “environmentally friendly lubricants” in a marine application, since “biodegradable oil” was designed to biodegrade in soil rather than water.
Regulatory Compliance Regarding “Oil” Spills or Discharges to Water
The U.S. EPA “Clean Water Act of 1990” clearly prohibits the discharge of any oil, mineral, or vegetable, accidently or otherwise in any water of the contiguous USA.
The “non-sheening rule” or 40 CFR 435 states that any substance that makes a visible sheen on the water is a violation of the “Clean Water Act of 1990” and 40 CFR 435, as that is the basic determination of what is actually discharged “oil.” This also includes any U.S. EPA-approved EAL that has the classifications of oil and has been determined to be considered oil. In sort, the U.S. EPA is attempting to promote the use of these products to lessen environmental impacts. If the EAL is not oil, or a hazardous substance, it is exempt from the “Clean Water Act of 1990” and 40 CFR 435, as well as the USCG OPA 90 oil spill clean-up regulations. Spills that violate this act, negligent or non-negligent, can and will result in substantial fines and other financial liabilities, such as clean-up attempts and site remediation.
In Canada, the “Canada Shipping Act” Pollution Prevention section clearly states that petroleum hydrocarbons (oil) are clearly defined “pollutants” as are “any substance that can have detrimental effects on humans, animals, and plant life.” This includes any oil that can interfere with marine wildlife, including vegetable oil, even if they are non-toxic. In Canada, marine pollution offences are often met with heavy fines and cleanup costs.
The major problem here is that almost all U.S.-approved EALs are some form of oil, and any subsequent spills will usually be met with fines. This is a bit ironic in the sense that the idea of an EAL is to be environmentally compliant and to reduce or eliminate the environmental impacts and financial burdens associated with accidental spills, especially when working in, on, or near water. Why would a company invest large sums of money to convert hydraulic or other types of machinery to an approved EAL only to still receive substantial fines and bear the cost of spill cleanups in the event of that happening. It seems like an exercise in futility to go through the entire process of evaluating the product, spend substantial amounts of money to convert machinery to an EAL or biodegradable oil, only to have the end result provide little benefit or reduced environmental liability.
Check back in the January Insider Guide to read Part Two of this article.
For more information: James Burton has been involved in the lubricants and environmental compliance field for over 30 years. He is the technical representative for Coast Lubricants, a company covering the Pacific Northwest supplying biodegradable and other high-performance industrial lubricants. He can be reached at jamesburton@shaw.ca.
Acknowledgments:
(1): Daryl Beatty, Martin Greaves, Dow Chemical; “PAGs are rising to the top of the synthetic market”
(2): Bosch Rexroth Corp.
(3): Dow Chemical; UCON Lubricants
(4): American Chemical Technologies Inc.