EPA VESSEL GENERAL PERMIT COMPLIANCE OF … · • These rules can be very port and biocide specific – “Copper Impaired Ports” can restrict usage of copper, Los Angeles/Long

EPA VESSEL GENERAL PERMIT COMPLIANCE OF PROPULSION

EQUIPMENT INTERNATIONAL WORKBOAT SHOW

NEW ORLEANS 2015

15 December 2015 Presentation name / Author 1 © Wärtsilä

Agenda

• Wartsila and our propulsion history

• VGP Background

• VGP areas of focus for propulsion equipment

• Types of EAL oils on the market

• Propulsor Changes for required for compliance

• Propulsion Equipment Test Methods

• Alternate technologies, ie water lube, barrier seals

• Life Expectancies of EAL’s

• Partnerships and Fleet Size of VGP Compliant Vessels


This is Wartsila


ENERGY SOLUTIONS (Power Plants)

MARINE SOLUTIONS

SERVICES

THIS IS WARTSILA

THIS IS WӒRTSILӒ

THIS IS WӒRTSILӒ


MERCHANT CRUISE & FERRY NAVY SPECIAL VESSELS OFFSHORE

SHIPPING OIL & GAS

THIS IS WӒRTSILӒ


The most complete marine

offering on earth

THIS IS WӒRTSILӒ


• Wartsila’s propulsion group came through acquisition of

LIPS in the Netherlands in 2002

• LIPS’ experience dates back to 1882 with many industry

records and firsts

• Propulsion product lines include

– Fixed and Controllable Propellers,

– Steerable and Tunnel Thrusters,

– Waterjets

– Gearboxes

– Propulsion Controls

• References include tunnel thrusters on many premier

cruise lines, waterjets for US Navy, DP capable thrusters

for Harvey Gulf LNG PSV’s, Gears and CPP’s for Seacor

and Crowley ATB’s etc.

THIS IS WӒRTSILӒ


MEUR 2014 20132 20123 2011 2010

Order intake 5 084 4 821 4 940 4 516 4 005

Operating result 1 569 557 517 469 487

% of net sales 1 11.9 12.1 10.9 11.1 10.7

17,700 70 200

PROFESSIONALS COUNTRIES LOCATIONS

VGP Background • Clean Water Act (CWA), originally enacted in 1948 and revised in 1972, as the Federal law

governing surface waters in the USA. The CWA has 5 key sections:

1. a system of minimum national effluent standards for each industry;

2. water quality standards;

3. a discharge permit program that translates these standards into enforceable limits;

4. provisions for special problems such as toxic chemicals and oil spills ; and,

5. a revolving construction loan program (formerly a grant program) for publicly-owned treatment works (POTWs).

• 1973, EPA enacts regulation exempting several categories of vessel discharges from National

Pollutant Discharge Elimination System (NPDES ) permitting requirements (section 402 of CWA)

– 40 C.F.R. §122.3(a), exempts “any discharge of sewage from vessels, effluent from properly functioning marine engines,

laundry, shower, and galley sink wastes from vessels, or any other discharge incidental to the normal operation of a vessel”

from the permitting requirements of the NPDES program.

• 2005, Northwest Environmental Advocates, the Ocean Conservancy, and San Francisco

Baykeeper (collectively NWEA) brought suit and won in federal district court against the US EPA,

alleging that such regulation exempting was beyond the scope of the Clean Water Act (CWA).

• 2008, On appeal the EPA again lost in the 9th Circuit


VGP Background

• 2008, EPA preliminary version of Vessel General Permit (VGP) becomes effective. For commercial, non-

military vessels over 79 feet operating in US waters. Compliance was not mandatory.

• 2013, EPA enacts current version of VGP. Covers 27 effluent vessel discharges. EPA estimates this affects

61,000 US flagged vessels and 8,000 foreign. For propulsion equipment this effects:

1. Coatings

2. Anodes

3. Oil-to-Sea Interfaces

• 2014, EPA sVGP for non-recreation, non-military vessels below 79 feet. Was to go into effect December

2014 however its full implementation has been delayed 2 years (only Ballast Water rules in effect for vessels

other than fishing). This will affect up to 138,000 vessels with similar requirements as the VGP.

– These smaller vessels may potentially be permanently exempted per pending Vessel Incidental Discharge Act (VIDA).

• Similar rules are expected to expand elsewhere. Eventually not just US waters.

• DNV Clean Notation requirements for stern tube lubrication are similar to VGP2013.


1. Coatings

• VGP’s focus on coatings is primarily on anti-foulants and general coating condition and

cleaning processes and generally not in the scope of propulsion suppliers

• These rules can be very port and biocide specific

– “Copper Impaired Ports” can restrict usage of copper, Los Angeles/Long Beach

– Tributyltin (TBT) banned

• Due to the nature of now required Environmentally Approved Lubricants (EAL’s), coatings are

generally limited to epoxy based products

– Typical of the industry already


2. Anodes

• Recommends, particularly for new vessels, the use of Impressed Current

Cathodic Protection (ICCP)

• Operators should note that magnesium is less toxic than aluminum and

aluminum is less toxic than zinc

• Anodes should be flush mounted or backfilled behind anode to hull

• Calls out cleaning procedures

• Freshwater vessel must document why the use of magnesium is not

appropriate if aluminum or zinc is selected

• Seawater vessels must document why aluminum is not appropriate if zinc is

selected.


3. Oil-to-Sea Interfaces


TRANSVERSE

THRUSTERS

“All vessels must use an EAL in all oil to sea interfaces, unless technically

infeasible.” - Technically Infeasible must be reported annually to USCG.

CPP HUBS

STERN TUBE

RUDDER

BEARINGS

STEERABLE

THRUSTERS

Technically infeasible means

1. No EAL’s approved for use

2. No alternatives with EAL’s

3. EAL’s not available in port of call

4. Need dry dock to convert

Main Types of EAL Lubricants


– Synthetic Esters (HEES):

• Fluid type of majority of EAL suppliers, where initial testing has focused

• Made from a weak non-vegetable based acid and alcohol combination

• Panolin GreenMarine Line (Stella Maris, EP etc), Castrol BioStat, ExxonMobile Aware,

Kluber KluberBio, Shell Naturelle, Vickers Biogear

– Polyalphaolefins (HEPR or PAOs):

• Chemically close to mineral oils with similar compatibilities

• Synthesized from crude oil

• RSCBio’s EnviroLogic

– Polyalkylene Glycols (HEPG or PAGs):

• Interest as these fluids have densities higher than water and are therefore non-sheening

• uses polyalkylene glycols (PAGS) as the base fluid which are synthesized from natural gas

• American Chemical Technologies' Neptune

– Vegetable Oil / Triglycerides (HETG):

• Author has no market knowledge of such EALS

• Not suitable for geared units, degrade too quickly

– Water

• Suitable for stern tubes only

• Recommended by the EPA per the VGP for stern tubes

Wärtsilä Propulsion intent is to ensure broad

compatibility with EAL’s.

What Makes EAL an EAL?


• 3 characteristics (per ASTM, ISO, CEC, OCED standards)

– Biodegradability - measure of the breakdown of a chemical by micro-organisms

– Aquatic Toxicity - low toxicity to aquatic organisms

– Bioaccumulation - build-up of chemicals within the organism’s tissues over time

• Who Certifies an EAL is Environmentally Approved?

– National Labeling Programs

• Blue Angel - German, developed in 1988, very stringent

• Swedish Standard - collaboration between industry and government

– International Labeling Programs

• Nordic Swan - Norway, Sweden, Finland, Iceland, and Denmark, higher

renewable content requirements

• European Eco-label – 2005 EU initiative, closest to an international

standard available

• OSPAR – 15 nations operating in the North East Atlantic offshore oil and

gas fields

– EPA’s Design for the Environment (DfE)

– Self Certification

• Supplier can contract with laboratories to follow the prescribed tests

What Makes EAL an EAL?


• In addition to these main types of EAL base stocks, additives are

included to modify the viscosity and other properties

• Fluids are approved for EAL use as previously noted, it is not the

propulsor OEM scope

• Fluids are also tested by the oil supplier for (16) characteristics.

These include:

– Shear Stability (permanent and temporary loss of viscosity)

– Lubricity, ability to build boundary layer

– Viscosity, VI

– Oxidation Stability

– Thermal Stability

– Varnish, Sludge and Foam Formation

– Hydrolytic Stability, how much water can be present

– etc

Propulsor Changes for EAL Use


• Material compatibility 80+ part #’s on a steerable thruster to evaluate; 30+ on a transverse thruster:

– Dynamic seals (propeller shaft seals), static and semi-static seals (O-rings,

quad-rings, gaskets) need to be Viton (FKM) with additives to ensure

compatibility and service life with EAL. Specific HNBR elastomers are also

allowed.

– Hoses

– Epoxy coatings are prescribed to avoid stripping; coatings containing free

zinc (not chemically bound) are not allowed.

• Water Separation

– Initially mandatory but potentially replaced with monitoring in the future

• Ambient water infiltration

– Desiccant caps on oil tank breathers

• No stationary oil volumes (dead heading); continuous oil flow throughout

propulsor

• Proper EAL selection for Application

– Stern tube, gear, hydraulic fluids are all required

– Different viscosity and friction properties of EAL need to be taken into

account

Static and semi-

static seals • O-rings

• Quad-rings

• Gaskets

Hoses

Coatings

Breathers/

breather-fillers

Gears/

bearings/

wet clutch

Dynamic seals • Propeller shaft

• Steering seals

Elastomer testing (1)

• Elastomer testing of

– Dynamic seals (propeller shaft, steering, blade foot seals)

– Static seals (O-rings, quad-rings, gaskets, other static seals)

• Compatibility tests are carried out for dynamic and/or static operating

conditions

– Multiple elastomer suppliers and elastomer types

– Multiple EAL suppliers and types (main focus: conditionally approved EAL list)

– Relevant conditions (clean EAL, 5% water, 5% seawater)

• Criteria (parameters affecting sealing capability)

– Volume change

– Hardness change

– Tensile strength change

– Elongation change


Elastomer testing (2)


Volume

change

Hardness

change

Tensile

strength

change

Ultimate

elongation

change

Volume

change

Hardness

change

Tensile

strength

change

Ultimate

elongation

change

Volume

change

Hardness

change

Tensile

strength

change

Ultimate

elongation

change

100% EAL

95% EAL + 5% water

95% EAL + 5% seawater

100% EAL

95% EAL + 5% water


100% EAL

95% EAL + 5% water


100% EAL

95% EAL + 5% water


100% EAL

95% EAL + 5% water


100% EAL

95% EAL + 5% water


100% EAL

95% EAL + 5% water


Supplier 3

Conditionally approved EAL list

EAL product X

Viscosity 150

EAL product X

Viscosity 100

EAL product Y

Viscosity 68

EAL product X

Viscosity 150

EAL product X

Viscosity 100

EAL product X

Viscosity 150

EAL product X

Viscosity 100

Supplier 1

Elastomer type Z

Supplier 2

Test matrix for elastomeric materials with EALs for general (semi-) static operating conditions

Supplier 1

Elastomer type X

Supplier 2

Elastomer type Y

Supplier 3

• Tests are being carried out by the suppliers in close

cooperation with Wärtsilä

• Considering f.e. 3 elastomer suppliers, 7 EAL types

(from 3 suppliers), 3 conditions and 4 criteria, >250

tests have to be carried out (21 x 12 matrix).

• Test program is progressing

• For all elastomer (seal) components a solution tested

with multiple EAL brands is now available

Water Separation


• For initial installations, a water separator is

mandatory. However work is underway to re-

evaluate this approach.

• If separation is eventually deemed not mandatory

as knowledge base increases, then continuous

water content monitoring will be required with

potential corrective action possibly a separator.

• Significant R&D work on-going for water removal

technologies. The state of art is the Jensen CJC

D10 filter. This is not a standard CJC filter system.

• The D10 is a “desorber” and not affected by

viscosity or additives.

• Oil is pre-heated to 60o C, cold air then flows

through the oil and absorbs water present later to

be condensed out.

Thruster Test Rig


• Full scale testing on the Propulsion

Test Center in Tuusula, Finland in

cooperation with VTT Tech Research

Center

• fully loading a thruster, including

overloads

• reproducing relevant temperature /

cooling conditions

• reproducing propeller loads, including

eccentricity, & structural loads

• measure torque, rpm, temperature,

vibration, displacement etc.

Eliminate Oil-to Water Interfaces (Water)


• Water lubricated stern tubes

– Generally these are open stern tubes whereby seawater is pumped in from the sea chest and flushes out the aft

– Utilize rubber or composite bearings instead of white metal

– Eliminate the aft seal, and utilizes a fwd seal only where the stern tube penetrates the hull

– Stern tube designed for corrosion protection, to ensure water flow for cooling etc

– Propeller shaft to be stainless, stainless clad or fiberglass wrapped for corrosion

– New build or retrofits too

– Need to consider bearing and journal wear as well as shaft survey requirements (especially CPP)

SHAFT

Aft

BEARING

Fwd

BEARING

SEAL

Eliminate Oil-to-Water Interfaces (Barrier)


• Barrier seals

– Essentially separate the lubrication oil from the seawater with a void space or air chamber that is monitored and

discharges to the engine room without the possibility of discharge to sea.

– These seal types have been around for decades and are very reliable

– Allow continued use of mineral oil

– However should a mineral oil result in a spill, the USCG/EPA can issue significant fines and clean up fees

– Originally these were not acknowledged by the EPA but with 3rd party verification they are an acceptable way to

meet the intent of the EPA VGP.

• For example LR, Design Appraisal Document

“This is to record that the undernoted products have been subject to desktop review in respect of meeting the

requirements of United States Environmental Protection Agency Vessel General Permit 2013. The product

details have been reviewed to establish whether in normal operation the seal presents an “oil to sea”

interface.”

Eliminate Oil-to-Water Interfaces (Barrier)


Standby

Lip Seal Oil Sealing

Lip

Oil 0.2 Bar Air Space

0 Bar Sea Water

0.3 – 2.0 Bar

FACE TYPE LIP TYPE

Sea Water

Air space

Standby

Lip Seal

Oil Sealing

Lip

Constant flow

of air

Life Expectancies


• While these EALs have been in use for many years

already, the use of EAL fluids in propulsors is still in the

learning phase.

• The difference in marine systems is the incidental water

that potentially enters the system that can break the EAL

down and how effective water polishers can remove it.

• All manufacturers are stating that their fluids will have a

lifetime of at least 5 years, dry dock to dry dock. In some

cases extended life over traditional mineral oil.

• Most also state that with filtering, the fluids can be likely

be re-used

Operator, Oil Supplier, OEM Partnership


• VGP compliance is not a scare tactic

• Mineral oils had decades of legacy work already

built in, since the 1920’s

• Lab testing of each new oil is costly and time

consuming.

• $200-300K

• 3 to 6 months

• Limited test rig availability

• Can the stakeholders share some risk for field

trials if a chosen oil has not been tested yet for a

given application?

Operator, Oil Supplier, OEM Partnership


• Wartsila has made a pubic statement May 2015 that all our

new build propulsion equipment can be made EPA VGP

compliant.

• In-Serv vessels are taken on a case by case basis

• We accomplish this with a combination of

• EAL lubricants,

• barrier seals

• Barrier EAL’s

• water lubricated stern tubes

• To date we have on order or delivered

• 30+ Vessels with CPP systems

• 50+ Vessels with Tunnel Thruster

• 5,000+ Vessels with FPP systems

• Several EAL’s OK’d

Thank You


IS VGP COMPLIANCE ON YOUR HORIZON?

Special Thank you to the following:

• Jeanne Grasso at Blank Rome LLP

• Tyler Kutcha and Mark Miller at RSC Bio

• Scott Kovanda at American Chemical Technologies

• Phil Cumberlidge at Panolin

• Wartsila’s Joost van Eijnatten, Elias Boletis

Brian Fariello

Business Sales Propulsion

+1 954 465 8267

[email protected]

References


http://elawreview.org/news/northwest-environmental-advocates-v-u-s-environmental-protection-agency

http://www.bdlaw.com/news-litigation-459.html

http://www2.epa.gov/national-pollutant-discharge-elimination-system-npdes/vessels-incidental-

discharge-permitting-5

RSCBio - Envirologic, http://rscbio.com

American Chemical Technologies - Neptune, http://americanchemtech.com/

Panolin – GreenMarine Line (Stella Maris, EP, etc) http://panolin.com

Castrol - Biostat, http://www.castrol.com/

http://elawreview.org/news/northwest-environmental-advocates-v-u-s-environmental-protection-agency/

Documents

EPA VESSEL GENERAL PERMIT COMPLIANCE OF … · • These rules can be very port and biocide specific – “Copper Impaired Ports” can restrict usage of copper, Los Angeles/Long