beyond vgp: choosing the best eal for your application needs€¦ · technologies alex dubrowski,...
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Beyond VGP: Choosing the Best EAL for Your
Application Needs Workboat
December 1, 2015
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
Panel Participants
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?
Regulatory History
4
Clean Water Act (CWA)
1972
September 2006
US District Court
December 2008
First VGP
December 2013
Second VGP
Established the National Pollutant Discharge Elimination System (NPDES) permit program
Any “point” source”, “discharge of a pollutant” to “waters of the U.S.”
Order interpreting
the CWA as
requiring NPDES
permits for
incidental
discharges from
vessels
All vessels must use
an EAL in all oil to
sea interfaces,
unless technically
infeasible. EAL
defined as:
biodegradable,
minimally toxic and
not bioaccumulative
Established
National
requirements for
27 types of
discharges
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
61000
8000
Key Requirement
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 pre- lubricated (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
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
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
What defines an EAL?
Criteria:
• Biodegradable
• Not bioaccumulative
• Minimally toxic
Commercial options
HEES1 (Synthetic Esters)
HEPG1 (Poly alkylene glycols)
HEPR1 (Poly alphaolefins)
1Categories arise from ISO 6743-4
All EAL chemistries meet major EAL requirements…
Property
Mineral
Oil HETG Veg. Oil
HEPG Poly alkylene
glycol (PAG)
HEES Synthetic
Ester
HEPR Poly alpha
olefin (PAO)
Non-
bioaccumulative
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.
EALs
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
…And all EALs have distinct advantages over mineral oil hydraulic fluids…
…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
Note 1. Water soluble PAG base stocks used.
Choosing an EAL requires understanding your application and requirements
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!
Questions you should be asking in choosing an EAL
• What is your application?
• 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?
Questions?
Experience
Common Concerns
Regulation Managing
Water Ingression
Sourcing
• Seal compatibility
• Oil life • ???
Where you can learn more
• Erica Nemser
Booth #4812 (Shared with MSC Filtration)
• Ben Bryant
Booth #4727
• John Sherman
Booth #3252
• Mark Miller
Booth #4755
• Alex Dubrowski
• Jack Faulk