Beyond VGP: Choosing the Best EAL for Your Application Needs. Workboat December 1, 2015

Transcription

1 Beyond VGP: Choosing the Best EAL for Your Application Needs Workboat December 1, 2015

2 Panel Participants Jack Faulk, Team Leader, EPA Mark Miller, Senior Vice President of Global Partnerships and Strategic Initiatives, RSC Bio Solutions Ben Bryant, Marine Market Manager, Klüber Lubrication John Sherman, Technical Service and Development Manager, Marine Division, American Chemical Technologies Alex Dubrowski, Technical Director- Automotive and Industry Marketing and Services, Total Lubricants Erica Nemser, CEO, Compact Membrane Systems

3 Today s Discussion Why the focus on EALs? What is the new regulation? What are the different types of EALs? How best can you choose and use an EAL? Audience questions What are you most curious about?

4 Regulatory History Clean Water Act (CWA) 1972 September 2006 US District Court December 2008 First VGP December 2013 Second VGP Established the Order interpreting National Pollutant the CWA as Discharge requiring NPDES Elimination System permits for (NPDES) permit program incidental discharges from Any point source, discharge of a vessels pollutant to waters of the U.S. Established National requirements for 27 types of discharges All vessels must use an EAL in all oil to sea interfaces, unless technically infeasible. EAL defined as: biodegradable, minimally toxic and not bioaccumulative 4

5 2013 Final VGP Overview Jurisdiction of the permit: Inland waters, territorial sea up to 3 nautical miles (nm) Vessels covered: Non-recreational and non-military vessels 79 feet or longer Other vessels with ballast water discharges EPA estimates 61,000 US and 8,000 foreign flagged vessels covered under the permit. 5

6 Key Requirement VGP Section 2.2.9: As of December 19, 2013, all vessels covered under the VGP must use EALs in all oil-to-sea interfaces, unless technically infeasible Oil-to-sea interfaces include: Controllable Pitch Propeller Thrusters Paddle Wheel Propulsion Stern Tubes Thruster Bearings Stabilizers Rudder Bearings Azimuth Thrusters Propulsion Pod Lubrication Wire Rope Other mechanical equipment subject to immersion (e.g., dredges, grabs, etc) Unless technically infeasible No EALs approved that meet OEM spec Products which come prelubricated (e.g., wire ropes) have no available alternatives manufactured with EALs EAL products that meet OEM spec but are not available within any port in which the vessel regularly calls Change over to an EAL must wait until the vessel s next drydocking

7 Documentation and Reporting Requirements Document EAL Use Information from any labeling program MSDSs or other technical data sheets. Document rationale if technically infeasible Can be basic and straightforward (e.g., a general statement from seal maker). Report EAL Use Annually (by February 28) Type of EAL used for each oil-to-sea interface Rationale for not using EALs and next steps

8 What defines an EAL? Commercial options Criteria: Biodegradable Not bioaccumulative Minimally toxic HEES 1 (Synthetic Esters) HEPG 1 (Poly alkylene glycols) HEPR 1 (Poly alphaolefins) 1 Categories arise from ISO

9 All EAL chemistries meet major EAL requirements EALs Property Mineral Oil HETG Veg. Oil HEPG Poly alkylene glycol (PAG) HEES Synthetic Ester HEPR Poly alpha olefin (PAO) Nonbioaccumulative No Yes Yes Yes Yes Readily Biodegradable No Yes Yes Yes Yes Aquatic Toxicity Low to Moderate Low Low Low Low Note 1. Water soluble PAG base stocks used.

10 And all EALs have distinct advantages over mineral oil hydraulic fluids Lubricant Properties HETG Veg. Oil HEPG Poly alkylene glycol (PAG) HEES Synthetic Ester HEPR Poly alpha olefin (PAO) General Lubrication Viscosity Index Oxidative Stability Low Temp. Viscosity Fluid Life

11 But different EALs have different properties and therefore uses Property HETG Veg. Oil HEPG Poly alkylene glycol (PAG) HEES Synthetic Ester HEPR Poly alpha olefin (PAO) Mineral Oil Soluble Yes No Yes Yes Freshwater or Saltwater Soluble No Yes No No Density versus Fresh or Saltwater Less Dense More Dense Less Dense Less Dense Choosing an EAL requires understanding your application and requirements Note 1. Water soluble PAG base stocks used.

12 EALs require regular maintenance Participate in a in-service oil analysis program Check fluid levels at least twice a year Follow equipment manufacturers maintenance recommendations Removal of water through a dehydration method Establish regular fluid change out intervals All lubricants require maintenance.eals are no different!

13 Questions you should be asking in choosing What is your application? an EAL What sort of maintenance are you prepared to do? What compatibility with elastomers and paints is required? How much resistance to hydrolysis and oxidation is needed? Expected consumption and/or change out intervals? Is this EAL approved by the OEM? Are there required OEM specifications or recommendations? Is lubricant miscible with previous lubricant used? What are changes in EAL appearance that vessel operators can observe to indicate a potential operational issue? Do you have references from other people who have used it? What viscosity grade is required? What is your system operating temperature and pressure? Is your equipment still under warranty? How will the EAL react with water and what are critical water content levels?

14 Questions? Experience Sourcing Common Concerns Seal compatibility Oil life??? Managing Water Ingression Regulation

15 Where you can learn more Ben Bryant Booth #4727 John Sherman ech.com Booth #3252 Mark Miller Booth #4755 Erica Nemser Booth #4812 (Shared with MSC Filtration) Alex Dubrowski Jack Faulk