EPA VESSEL GENERAL PERMIT COMPLIANCE OF PROPULSION EQUIPMENT

Transcription

1 EPA VESSEL GENERAL PERMIT COMPLIANCE OF PROPULSION EQUIPMENT INTERNATIONAL WORKBOAT SHOW NEW ORLEANS Wärtsilä

2 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 2 Wärtsilä

3 THIS IS WA RTSILA WӒRTSILӒ This is Wartsila ENERGY SOLUTIONS (Power Plants) MARINE SOLUTIONS 3 Wärtsilä SERVICES

4 THIS IS WӒRTSILӒ OFFSHORE MERCHANT CRUISE & FERRY NAVY SPECIAL VESSELS OIL & GAS 4 Wärtsilä SHIPPING

5 THIS IS WӒRTSILӒ The most complete marine offering on earth 5 Wärtsilä

6 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. 6 Wärtsilä

7 THIS IS WӒRTSILӒ MEUR Order intake Operating result % of net sales , PROFESSIONALS COUNTRIES LOCATIONS 7 Wärtsilä

8 VGP Background Clean Water Act (CWA), originally enacted in 1948 and revised in 1972, as the Federal law governing surface waters in the USA.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 (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 9 th Circuit 8 Wärtsilä

9 VGP Background 2008, EPA preliminary version of Vessel General Permit (VGP) becomes effective. For commercial, nonmilitary 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 VGP Wärtsilä

10 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 10 Wärtsilä

11 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. 11 Wärtsilä

12 3. Oil-to-Sea Interfaces All vessels must use an EAL in all oil to sea interfaces, unless technically infeasible. - Technically Infeasible must be reported annually to USCG. 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 STERN TUBE RUDDER BEARINGS TRANSVERSE THRUSTERS 12 Wärtsilä STEERABLE THRUSTERS CPP HUBS

13 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. 13 Wärtsilä

14 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 14 Wärtsilä

15 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 15 Wärtsilä

16 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 Hoses Gears/ bearings/ wet clutch Dynamic seals Propeller shaft Steering seals Breathers/ breather-fillers Coatings Static and semistatic seals O-rings Quad-rings Gaskets 16 Wärtsilä

17 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 17 Wärtsilä

18 Elastomer testing (2) Test matrix for elastomeric materials with EALs for general (semi-) static operating conditions Conditionally approved EAL list Supplier 1 Supplier 2 Supplier 3 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 % EAL 95% EAL + 5% water 95% EAL + 5% seawater 100% EAL 95% EAL + 5% water 95% EAL + 5% seawater 100% EAL 95% EAL + 5% water 95% EAL + 5% seawater 100% EAL 95% EAL + 5% water 95% EAL + 5% seawater 100% EAL 95% EAL + 5% water 95% EAL + 5% seawater 100% EAL 95% EAL + 5% water 95% EAL + 5% seawater 100% EAL 95% EAL + 5% water 95% EAL + 5% seawater Volume change Supplier 1 Elastomer type X Hardness change Tensile strength change Ultimate elongation change Volume change Supplier 2 Elastomer type Y Hardness change Tensile strength change Ultimate elongation change Volume change Supplier 3 Elastomer type Z Hardness change Tensile strength change Ultimate elongation change 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 18 Wärtsilä

19 Water Separation For initial installations, a water separator is mandatory. However work is underway to reevaluate 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 60 o C, cold air then flows through the oil and absorbs water present later to be condensed out. 19 Wärtsilä

20 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. 20 Wärtsilä

21 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) SEAL SHAFT 21 Wärtsilä Aft BEARING Fwd BEARING

22 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 3 rd 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 The product details have been reviewed to establish whether in normal operation the seal presents an oil to sea interface. 22 Wärtsilä

23 Eliminate Oil-to-Water Interfaces (Barrier) Air space Sea Water Bar Air Space 0 Bar Oil 0.2 Bar Sea Water Constant flow of air Oil Sealing Lip FACE TYPE Standby Lip Seal Oil Sealing Lip LIP TYPE Standby Lip Seal 23 Wärtsilä

24 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 24 Wärtsilä

25 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. $ K 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? 25 Wärtsilä

26 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 26 Wärtsilä

27 Thank You Brian Fariello Business Sales Propulsion 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 27 Wärtsilä

28 References RSCBio - Envirologic, American Chemical Technologies - Neptune, Panolin GreenMarine Line (Stella Maris, EP, etc) Castrol - Biostat, 28 Wärtsilä