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50 Maritime Reporter & Engineering News ? NOVEMBER 2013 FluidsNothing stirs the maritime pot like new regulation, and coming soon to you (in less than a month) is the new iteration of the Vessel General Permit (VGP). The VGP applies to vessels op- erating in a capacity as a means of trans-portation, that have discharges inciden- tal to their normal operations into waters subject to this permit, except recreational vessels. Unless otherwise excluded from coverage, the waters subject to this per- mit means ?territorial seas? of the U.S. The Clean Water Act (CWA) does not require NPDES permits for vessels or other ß oating craft operating as a means of transportation beyond the territorial seas, such as in the contiguous zone or ocean. The Environmental Protection Agency (EPA) is issuing a replacement VGP permit under its authority from the CWA. The new VGP provides ef ß uent limits for 27 speci Þ c discharge catego- ries. The types of vessels covered under the VGP include commercial Þ shing vessels, cruise ships, ferries, barges, mobile off- shore drilling units, oil tankers or petro-leum tankers, bulk carriers, cargo ships, container ships, other cargo freight- ers, refrigerant ships, research vessels, emergency response vessels, including Þ reÞ ghting and police vessels, and any other vessels operating in a capacity as a means of transportation. While all non-recreational vessels, which are not vessels of the armed forces, may seek coverage under this permit. The permit requirements are generally targeted to vessels that are at least 79 feet in length. The EPA estimates that the domestic vessel population subject to the VGP is approximately 60,000 vessels; it es-timates approximately 12,400 foreign ß agged vessels are subject to the VGP requirements. Lubricants Companies InvestAs with any new industry rule, those that stand to gain business from new re-quirements work well in advance to en-sure that its product and service line-up is well-positioned to prosper. This has been the case with VGP, particularly with lubricant and ß uids manufacturers that for years have been tasked to reÞ ne product that are more environmentally benign while maintaining performance standards.?To ensure ExxonMobil Marine Fu- els and Lubricants can help operators to meet the stringent requirements, we have developed a new comprehensive series of synthetic, environmentally accept-able lubricants, the Mobil SHC Aware range,? said Iain White, Global Field Marketing Manager, ExxonMobil Ma- rine Fuels & Lubricants. The new Mobil SHC Aware range has been formulated to not only help engineers comply with the new marine operating practices, but to enhance vessel reliability, minimize maintenance costs and reduce potential environmental impact. The Mobil SHC Aware range includes: ? Mobil SHC Aware H hydraulic ß uids ? Mobil SHC Aware ST stern tube lubricants ? Mobil SHC Aware Grease EP 2 multi-purpose grease ? Mobil SHC Aware Gear range of gear oils ?RSC Bio Solutions has a legacy of developing these kinds of products since 1996, and we have worked with OEMs and other industry stakeholders for quite some time to deliver technically sound, environmentally acceptable products with high performance,? said Mike Gug-genheimer, President & CEO, RSC Bio Solutions. ?In light of the recent changes to the VGP regulation, RSC Bio Solutions un- dertook a signiÞ cant process to repeat our documentation and testing studies on biodegradation, toxicity, bioaccu- mulation to ensure we would be able to unequivocally certify our products as compliant. RSC Bio Solutions has also extended our production and distribu-tion network as the market for EALs has grown on a global stage.Our EnviroLogic EALs (100 Series and 3000 Series) are suitable, proven and approved for a wide range of ap-plications, including controllable pitch propellers, thruster and hydraulic ß uids and other oil-to-sea interfaces including lubrication discharges from stern tubes, thruster bearings, stabilizers, rudder bearings, azimuth thrusters, propulsion pod lubrication, wire rope and mechani-cal equipment subject to immersion. Ap- plications for our SAFECARE cleaners include deck and equipment washing, general purpose cleaning, degreasing, parts cleaning and oil stain removal,? Guggenheimer concluded.In a discussion on the show ß oor in New Orleans last month, Panolin main-tains that it was already well-ahead of the VGP game as it has nearly 30 years experience producing environmentally-considerate lubricants. Panolin offers its VGP-compliant Greenmarine prod- ucts to help owners and operators meet the imminent EPA requirements. Pa- nolin Greenmarine lubricants use fully saturated synthetic esters and specially developed additives to achieve 100% VGP and sVGP compliance without sac- riÞ cing performance. The range includes hydraulic ß uids, gear oil and production line control ß uids, as well as lubricants for stern tubes, gear boxes, cables and sliding parts. These products have prov- en themselves through harsh continued use in dredging, offshore, subsea, ma- rine and hydropower applications with customers around the world. These syn- thetic lubricants are designed to separate from water easily and quickly due to their fully saturated ester compound, and possess self-drying characteristics when heated. Their higher af Þ nity to water and moisture content allows for water sepa-ration and removal, providing long-term product stability and durability. By also decreasing the frequency of oil changes and enhancing operating efÞ ciency, these products effectively reduce CO2 emissions. Castrol Marine believes in developing an entire range of marine grade lubri-cants based on an unfolding legislative program, and at the same time securing OEM approvals ahead of time. But it also believes its coordinated efforts to share regulatory knowledge with customers will not be sufÞ cient; only by working with customers to forecast the size and location centers of demand for its EAL compliant range can it claim to offer a truly market responsive approach. Castrol BioStat and BioBar ranges are registered under OSPAR (Conven- tion for the Protection of the Marine Environment of the North-East Atlantic) and therefore meet the criteria for be-ing EALs under the VGP. Owners will also need to be assured that the products they select meet acceptable standards in terms of performance. Here, Susannah Linington, Castrol Marine Environmen-tal Specialist, explains that Castrol Ma-rine has spent the four years since the revised VGP was Þ rst raised securing OEM approvals for BioRange products in the marine context. As important as performance is that the product is documented to meet the new requirements, ultimately the vessel owner is responsible. ?Claims for ?en-vironmentally responsible? products are made widely but can sometimes be mis-leading,? said Linington. ?It is a great step forward having deÞ ned criteria for determining the environmental perfor- mance of marine lubricants. This means that environmental claims can be backed up by relevant scientiÞ c testing.? According to Linington, Castrol?s Þ rst principle for BioRange was to of- fer drop-in replacements for lubricants based on conventional mineral oils. Finally, Vickers said its HYDROX BIO, ECOSURE HSE and BIOGREASE EP2 ranges of Environmentally Accept- able Lubricants (EALs) meet the detailed ecological deÞ nitions and requirements laid down in the 2013 Vessel General Permit (VGP). Vickers Oils has approv- als for its EALs from many of the rel-evant equipment manufacturers. Stocks are carried in ports around the world.EPA?s Vessel General Permit (VGP) & You What?s it Going to Cost? It wouldn?t be a new rule if it didn?t hit your bottom line. The table below pro- vides the EPA?s projected low end and high end estimates concerning the Gen- eral Inspection and Paperwork costs associated with compliance across the board for the VGP. Vessel Class Low End Estimate High End Estimate Vessel Class Low End Estimate High End Estimate Commercial Fishing $34,496 $254,545Freight Barges $193,893 $193,893 Freight Ships $20,593 $20,593Passenger Vessels $15,322 $15,322 Tank Barges $34,839 $34,839Tank Ships $8,661 $8,661 Utility Vessels $102,182 $102,182 Total $409,986 $630,036Total $409,986 $630,036MR #11 (50-57).indd 50MR #11 (50-57).indd 5011/13/2013 9:12:44 AM11/13/2013 9:12:44 AM