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Det Norske Veritas asNO-1322 Høvik, Norway
Tel: +47 67 57 99 00www.dnv.com
DNV serViNg THe mariTime iNDusTrytechnical eNewsletter 12 June 2013
New US requirements as to biodegradable lubricant oilsin march 2013, the us environmental Protection agency (ePa) issued a final Vessel general Permit (VgP) regu-lating discharges from commercial vessels in order to protect the nation’s water from ship-borne pollutants and reduce invasive species in us waters. The VgP will enter into force on 19 December 2013 and replace the current VgP (2008 VgP).
more newsletters from DNV:www.dnv.com/newsletters DNV disclaimer of liability
This newsletter addresses the new EPA requirements in the revised VGP for Environmentally Acceptable Lubricants (EALs), also known as biodegradable oils (although EAL requirements comprise more than just biodegradability). The VGP requires ships sailing in US waters to use EALs in all oil-to-sea interfaces “unless technically infeasible”. See the EPA web page, where the Final 2013 VGP can be found and EALs are addressed in part 2.2.9 (page 47).
The most relevant components are the stern tube, rudder bearings, CP propellers, thrusters and fin stabilisers. However, any ship components that can potentially cause the leakage of lubricants into the sea are in principle to be considered according to the VGP.
The challenge for each shipowner trad-ing in US waters will be to consider which lubricants on board its vessels shall be changed to EALs and when, or alternative-ly to decide not to do so as this is deemed technically infeasible.
Oil companies and some other suppli-ers of lubricants are now in the process
of introducing products compliant with the EAL requirements to the market. Although environmentally preferable, EALs may have some major disadvantages. The most important one is that many con-ventional rubber (seal) materials are not compatible with the new EALs. The EALs will also absorb more water than mineral oils, so water control (i.e. sticking to the recommendation of the EAL supplier) becomes important to maintain lubrication capacity and keep the risk of corrosion and bacteria growth under control.
As a market response to these issues, the seal manufacturers have, each accord-ing to their own testing principles, tested combinations of seals and EALs. The tests have been done brand by brand, resulting in lists of compatible oils and seals, usu-ally with target lives of 2.5 years. Taking into account the vessel’s docking intervals, EALs that are compatible with the seals installed should be sought for all oil-to-sea interfaces.
techNically iNfeasibleThe understanding of the term “unless technically infeasible” is at present uncer-tain, but the following guidelines can be
assumed to be acceptable under the VGP:
1. If the ship has seals that are not compat-ible with any EALs, it can continue to use mineral oil until the next planned docking, when the seals are to be replaced.
2. If the original equipment manufacturer (OEM) has no recommended seal-EAL combination for its product, the use of EALs can be considered “technically infeasible”.
3. For new ships or when replacing equip-ment, the use of EALs is “technically infeasible” only if no manufacturer can deliver an EAL-lubricated product that is suitable for the purpose.
4. If the use of an EAL in an oil-to-sea interface is claimed to be “technically infeasible”, the ship must carry docu-mentation to that effect. Such a docu-ment/statement written by the manufac-turer or owner shall be not more than one year old and confirm the factual situation.
Det Norske Veritas asNO-1322 Høvik, Norway
Tel: +47 67 57 99 00www.dnv.com
DNV serViNg THe mariTime iNDusTrytechnical eNewsletter 12 June 2013
more newsletters from DNV:www.dnv.com/newsletters DNV disclaimer of liability
CONTACT INFODNV approval ship and Offshoreenvironmental [email protected]
coNclusioNs■■ For ships sailing in US waters after 19 December 2013, EALs must be used in all oil-to-sea interfaces if technically feasible. If it is not feasible, this must be documented.
■■ For the stern tube, this is not technically feasible if the seal installed is not listed in the manufacturer’s lists of compatibil-ity with an EAL.
■■ For all other oil-to-sea interface com-ponents, it is not feasible to use EALs unless such a manufacturer-recommend-ed solution exists.
■■ When a component which includes an oil-to-sea interface is replaced, a brand/model for which a recommended EAL solution exists shall be preferred when-ever technically possible.
DNV’s CLEAN DESIGN class notation has defined the following requirements for the oil/water interface in the stern tube:
If a “biodegradable” oil is used, an arrangement shall be in place to keep the water content of the oil under control and it shall be ensured that seal materials are compatible with the “biode-gradable” oil. If conventional lube oil is used, an effective, monitored double barrier seal system shall be in place to safeguard against oil leaks to the sea.
The DNV requirement under CLEAN DESIGN is leaner than the VGP require-ment and has so far offered the monitored double barrier system with conventional lubricants as an option. A revision of CLEAN DESIGN is planned in order to implement some requirements similar to the VGP.
Final 2013 VGP
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
The protective seals on controllable pitch propellers, azimuth thrusters, propulsion pods, rudder bearings, or any other oil-to-sea interfaces must be maintained in good operating order to minimize the leaking of hydraulic oil or other oils. The vessel owner/operator must not discharge oil in quantities that may be harmful as defined in 40 CFR Part 110 from any oil-to-sea interface. If possible, maintenance activities on controllable pitch propellers, thrusters, and other oil-to-sea interfaces should be conducted when a vessel is in drydock.
Minimize maintenance activities on stern tube seals when a vessel is outside of drydock. If maintenance or emergency repair must occur on stern tubes or other oil-to-sea interfaces which have a potential to release oil in quantities that may be harmful as defined in 40 CFR Part 110, appropriate spill response equipment (e.g., oil booms) must be used to contain any oil leakage. Operators of the vessel must have ready access to spill response resources to clean up any oil spills.
After applying lubrication to wire rope and mechanical equipment subject to immersion, wire ropes, and other equipment must be thoroughly wiped down to remove excess lubricant unless doing so is deemed unsafe by the Master of the vessel.
All vessels must use an EAL in all oil to sea interfaces, unless technically infeasible. “Environmentally acceptable lubricants” means lubricants that are “biodegradable” and “minimally-toxic” and are “not bioaccumulative” as defined in Appendix A of this permit. For purposes of requirements related to EALs, technically infeasible means that no EAL products are approved for use in a given application that meet manufacturer specifications for that equipment, products which come pre- lubricated (e.g., wire ropes) have no available alternatives manufactured with EALs, products meeting a manufacturers specifications are not available within any port in which the vessel calls, or change over and use of an EAL must wait until the vessel’s next drydocking.
If a vessel is unable to use an EAL, you must document in your recordkeeping documentation consistent with Part 4.2 why you are unable to do so, and must report the use of a non-environmentally acceptable lubricant to EPA in your Annual Report. Use of an environmentally acceptable lubricant does not authorize the discharge of any lubricant in a quantity that may be harmful as defined in 40 CFR Part 110.
EPA recommends that all new build vessel operators endeavor to use seawater-based systems for their stern tube lubrication to eliminate the discharge of oil from these interfaces to the aquatic environment.
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