Forward-thinking vessel owners and operators in the marine and offshore industries have been substituting mineral-based solutions for readily biodegradable alternatives to minimize business risk. With proposed changes to U.S. vessel discharge regulations by the Environmental Protection Agency (EPA), vessel operators who have yet to adopt less hazardous chemicals into their operations must reexamine their lubricating, cleaning and degreasing practices.
The Vessel General Permit (VGP) is a Clean Water Act National Pollutant Discharge Elimination System (NPDES) permit from the EPA that authorizes, on a nationwide basis, discharges incidental to the normal operation of non-military and non-recreational vessels. The 2013 VGP will take the place of the current 2008 Vessel General Permit, which expires in December, and will contain several new provisions aimed at reducing pollutant loadings incidental to vessel operation, in part by minimizing the introduction of pollutants in the vessel effluents (e.g., use of environmentally preferred cleaners or lubricants).
It will require vessel owners and operators — from small commercial shipping lines to major offshore drilling companies — to adopt environmentally acceptable products into their operations to reduce their environmental impact.
The EPA estimates that 58,602 domestic flag and 12,429 foreign flag vessels will be covered under the VGP, the bulk of which are freight barges.
Navigating the EALs market
Despite the costs of spill remediation, the majority of marine vessel operators use petroleum-based lubricants and cleaners across their fleets, as these products can offer slightly more competitive prices up-front.
The deadline for VGP-compliance is December 19. Delaying the switch to environmentally acceptable lubricants (EALs) will increase operational risk for vessel owners.
Currently, four categories of EALs are available to choose from:
• polyalkylene glycols (PAGs),
• synthetic esters, and
Vegetable-based EALs, like triglycerides, often demonstrate lower performance metrics and usable life cycles when compared to synthetic alternatives. Their upper temperature threshold is 180° F, and they tend to break down when mixed with water. Their expected change-out time is 1000-2000 hr.
Biopolyolefin synthetics, like RSC Bio Solutions’ Envirologic series lubricants, have an upper temperature threshold of 400° F, are water-resistant, and last 10,000-15,000 hr or more. Even though synthetic products can cost up to four times more than vegetable-based products, they can last up to ten times longer, while performing at the same level as mineral-based lubricants. PAGs, according to the EPA, are generally biodegradable and do not bioaccumulate. However, some polyalkylene glycol-based lubricants are more toxic due to their solubility.
Costs and benefits simplified
The EPA estimates a small average annual increase of $555 to $1111 per vessel when switching to EALs. For example, Nordic American Tankers announced net voyage revenue per vessel per day of $16,200 in its second quarter 2012 report. Using the “high-end estimate” from the EPA of the annual costs of phasing in EALs, it would take slightly more than one hour of voyage time per vessel to recoup these costs. Substantial evidence also exists that readily biodegradable products begin to pay for themselves almost immediately after a spill or leak occurs. The savings on remediation costs provide a compelling case for investing in EALs.
Continuing to use mineral-based products will not only perpetuate an environmentally harmful practice, but also bring serious operational risk to vessel operators. The threat of financial and potentially legal penalties makes compliance a necessity.
The VGP law will also apply to cleaners and detergents as well as adsorbents. Read the full language of the Draft 2013 Vessel General Permit here.