Industry must take note of upcoming vessel general permit

With increasing concerns about the impact that exploration and production is having on the environment, the offshore industry must work with the authorities in different regions of the world to develop and implement measures to reduce its footprint.

With increasing concerns about the impact that exploration and production is having on the environment, the offshore industry must work with the authorities in different regions of the world to develop and implement measures to reduce its footprint.

To give an example, the marine ecosystem has the potential to be disrupted by discharges of lubricants from offshore vessels. It is the responsibility of the authorities, operators, and lubricants suppliers to work together to find solutions that will limit the impact on the environment. R&D efforts have long focused on finding alternatives to using mineral oils in applications where lubricants enter the sea. The challenge has been to develop lubricant products that reduce the environmental impact of operations without compromising performance.

In recent years, the need for greater clarity on what is environmentally acceptable has become more apparent. In the North East Atlantic, the Oslo and Paris Convention (OSPAR) is the mechanism by which governments cooperate to protect the marine and offshore environment. The OSPAR guidelines use three primary criteria to determine the level of impact of chemicals and hazardous substances in the marine environment. Plus, there is detailed guidance in place to establish whether individual components used in a product are acceptable or substitutable. This is not the case in other areas of the world and – in a global industry – the resulting uncertainty has led to calls for similar guidance to be implemented elsewhere.

In the US, the Environmental Protection Agency (EPA) recently published a new version of the Vessel General Permit (VGP), with effect from Dec. 19, 2013. This mandates the use of "Environmentally Acceptable Lubricants" (EALs) by any "vessel" calling in waters within 3 mi (4.8 km) of the US coast. The aim is to reduce the environmental impact of lubricant discharges across all applications.

The VGP ensures that the industry has clear guidance on the procedures that need to be followed in order to limit the environmental impact of operations. The EPA defines an EAL as a lubricant that is biodegradable (can break down naturally in the sea), minimally toxic (reducing the risk of harming marine life), and not bioaccumulative (to ensure that a chemical does not enter the food chain by accumulating in the fatty tissues of organisms).

The culmination of work that has been ongoing for a number of years, this month's deadline marks an important milestone. Yet levels of awareness in the industry are relatively low. The reasons why are unclear, but operators must work with a lubricant supplier that is knowledgeable about the changing environmental requirements to understand the steps that need to be taken to ensure that relevant vessels meet the requirements, and that the necessary OEM approvals are in place ahead of the Dec. 19 deadline.

The first step for operators is to establish if a vessel is affected by the legislation. Within the offshore industry, the VGP applies to mobile offshore drilling units such as semisubmersible drilling rigs and drillships. The vessels covered include the majority of commercial marine vessels of any age or origin of construction, which are longer than 79 ft (24 m). In certain circumstances, mobile drilling rigs or vessels under construction must also adhere to the guidelines. Recreational vessels or vessels belonging to the Armed Forces are exempt. Vessels shorter than 79 ft are exempt from the VGP, but will be subject to the requirements of the small VGP, which is currently under revision.

If a vessel is covered by the VGP and is due to call in US waters, EALs must be used in all oil-to-sea interfaces – including, but not limited to, lubrication discharges from thruster bearings, azimuth thrusters, wire ropes, and mechanical equipment subject to immersion. In order to comply with the new VGP legislation, vessel owners and operators must self-report EAL usage and keep records of material safety data sheets onboard for the EALs used, including a statements of the products' compliance with the VGP. In addition, operators are required to document whether the EALs are registered under a labeling program.

For vessel operators who find it technically infeasible to use an EAL, the reasoning must be explained in record-keeping documentation, and the use of a non-environmentally acceptable lubricant declared in the vessel's annual report. The EPA will accept that it is technically infeasible to use an EAL when products come pre-lubricated and there are no available alternatives manufactured with EALs, or when there are no EALs approved for use in the given application.

Due to the current lack of awareness surrounding the new legislation, and the fact that the EPA is relying on vessel operators to self-report EAL usage, it will be interesting to see how successful the EPA is in ensuring the VGP mandates are followed. Clearly, the availability of EALs that ensure performance is critical. The industry cannot afford to compromise on performance, component life, and system reliability.

Susannah Linington
Environmental Specialist
Castrol Offshore

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