recognizing the benefits of environmentally
acceptable lubricant fluids (EAL). Using
these lubricants can potentially save an
operator thousands of dollars in terms of
fines, cleanup costs and downtime. The
U.S. Environmental Protection Agency
(EPA) defines an “EAL” as a “lubricant that
is biodegradable, exhibits low toxicity to
aquatic organisms and has a low potential
for bioaccumulation.” (EPA 800-R-11-002,
Publication U.S. Environmental Protection
Agency, November 2011).
For those not already using readily
biodegradable lubricants, there is mounting
pressure from the U.S. federal government
to utilize these environmentally preferable
products. For example, the EPA under the
2013 Vessel General Permit (VGP) now
requires that all vessels over 79 feet use
an EAL in oil to water interfaces, unless
technically infeasible. The 2013 VGP revision
also requires any above water line hull
cleaning or deck wash-downs resulting in
discharge to be conducted with “minimallytoxic”
and “phosphate free” cleaners and
detergents as defined in Appendix A of
the permit. The permit further requires
cleaners and detergents to be non-caustic
and biodegradable. It is expected that most
vessels seeking coverage under this permit
will be greater than 79 feet in length;
however, commercial fishing vessels and
other non-recreational vessels less than 79
feet are also eligible for coverage under this
permit or those vessels may seek coverage
under EPA’s small Vessel General Permit
(sVGP), as available and appropriate.
Additional regulation for pile driving
contractors includes the Clean Water Act
M. Pellinni/Shutterstock
feature
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