There’s a big difference between the words “must” and “should.” That’s especially true when talking about the Environmental Protection Agency’s 2008 Vessel General Permit and its 2013 successor. Depending on the application, the difference for workboat operators can have financial implications. It can result in downtime for boats, plus logistical and maintenance issues.
Legally the Vessel General Permit, which affects all commercial boats 79' or greater, has to be renewed every five years — thus the 2013 edition, which took effect Dec. 19, 2013.
Congress mandated VGPs under the Clean Water Act. Both are concerned with overboard discharges “incidental to the normal operation of a vessel” that happen inside three nautical miles.
While much of the VGP’s focus is on ballast water, “They took a harder look at ballast water discharges,” said John Nagle with the EPA’s regional office in Boston. But it’s two pages of the 2013 VGP’s 194-page document that have especially caught the attention of many workboat operators.
Section 2.2.9 deals with discharges from oil-to-sea interfaces on a workboat that include controllable-pitch propellers, stern tubes, thruster bearings, rudder bearings, azimuth thrusters and towing-notch interfaces.
Part of that section reads, “All vessels must use an EAL [environmentally acceptable lubricant] in all oil-to-sea interfaces, unless technically infeasible.” The emphasis is on the word “must.”
As the 2008 Vessel General Permit was written, “Owners/operators should use an environmentally preferable lubricant.” The word “should” meant there wasn’t an immediate rush to use those lubricants in 2008. Adding “must” to the wording of the 2013 VGP has boat operators thinking more seriously about EALs.
If a boat doesn’t use an environmentally acceptable lubricant, meaning “biodegradable, minimally toxic and not bioaccumulative (absorbed by organisms),” the owner has to tell the EPA why it’s not being used.
Is there an increased demand for EALs? “We are starting to see it, yes, absolutely,” said Jared Mikacich, with Panolin America, a lubricant supplier based in Ventura, Calif.
Currently, he said, the demand related to the VGP has mostly to do with thrusters, hydraulic systems and some gears in the lower units of thrusters.
Requests for EALs for stern tubes are a bit slower, “primarily because they are using the drydocking clause to delay the process.” This refers to a section of the permit that says a change over to an EAL may wait until the boat’s next drydocking.
He added that the term “technically infeasible” is something “a lot of people are using lately.” That means boat operators are telling the EPA they aren’t using an EAL because none are available that meet manufacturer’s specifications for that equipment. However, Mikacich said, “For the most part, there are available lubricants out there somewhere for most of the equipment on the vessels.”
For the stern-bearing portion of the permit, the major impact will be on older boats, as new boats are now being built with water-lubricated versus petroleum-lubricated stern bearings. “They are all water lubricated. That’s pretty much throughout the industry,” said Hal Hockema of Hockema & Whalen Associates in Seattle.
Switching to a seawater-lubricated shaft bearing ensures a boat operator is in compliance with the VGP regulations.
On boats without seawater-lubricated bearings, there are two ways a shaft bearing leaks oil into the water: operational where the oil leaks a small amount as part of the normal operation and when the shaft seal is damaged. “Thordon Bearings offers a system where you can replace the oil-lubricated bearing and put a non-polluting water system in,” Hockema said.
COSTLY CHANGE
How do you measure the need to spend the money on a new non-polluting lubrication system? By showing that a fair amount of oil is going into the water. That’s what the EPA seems to have done in its economic and benefits analysis of the final 2013 VGP released last year that claims the “average daily stern tube lubricant consumption rate across vessel types is reported as 2.6 liters per day, but ranges from less than 1 liter to 20 liters per day.”
Barge operations consume the most while utility boats such as patrol boats are at the lower end of the scale. (Due to the way barges carry cargo, the VGP imposes additional measures in order to prevent and minimize the discharge of pollutants from barges.)
What does it cost to use environmentally acceptable lubricants? On average, the EPA found that EALs are 38 percent more expensive than conventional lubricants. The EPA assumes that the incremental cost to vessel owners ranges between $4 a gallon and $8, though prices will differ depending on the region of the country.
However, Crowley Maritime has found that the increased costs may end up being much higher.
Bill Metcalf, Crowley’s vice president of engineering, said the “average cost of EAL oil is $1,200 per 100 liters [26.4 gals.]. The average cost of non-EAL oil is $350 per 100 liters.” That’s a difference of about $32 a gallon.
“At Crowley we have identified approximately 87 vessels, 12 separate manufacturer interfaces and 10 different oil-grade replacements required to meet the EPA, VGP oil-to-sea interface requirement.”
When those vessels come in for their next drydock all the existing oils will be removed, the systems will be flushed, new seals will be installed in oil-to-sea interfaces and EPA-approved oils will replace the old lubricants “at a considerable cost to the corporation,” Metcalf said.
New biodegradable lubricants
Clarion Lubricants introduced two new products in February in response to the new Vessel General Permit. Both products are hydraulic fluids. One is a vegetable-based natural ester, and the other is a synthetic ester.
The synthetic ester has “extremely low temperature properties,” said Clarion’s Ben Briseno. He characterizes the natural ester as having good wear performance but not as stable as the synthetic ester. “They meet the biodegradable qualities of the vessel permit.”
Within the year, Clarion plans to come out with “a readily biodegradable grease, as well as stern-tube lubricants and gear lubricants,” he said. “The good thing about the VGP is that it’s very specific about what defines an EAL. Before you had a lot of marketing terms out there. Environmentally acceptable might mean different things.”
Clarion Lubricants is part of Citgo Petroleum, Houston.
Tyler Kuchta at Terrasolve, an Ohio company that makes environmentally safe lubricants, said a test called OECD 301B measures biodegradability over a 28-day period. “To pass the test, you have to be at least 60 percent degraded in 28 days.” As the lubricant breaks down, it turns to carbon dioxide and water.
Kuchta said that Terrasolve lubricants break down entirely in 40 to 60 days.
