Propulsion – Marine Services

Service letter Ref.: SL-UL-2013-005

Date: 30.09.2013
Page 1 of 1

RECOMMENDED ACTION

New VGP requirements in US waters

Background:
In March 2013, the US Environmental Protection Agency (EPA) issued a final Vessel General Permit (VGP) regulating
discharge from commercial vessels in order to protect the nation’s water from ship discharges and reduce invasive
species in US waters. The new VGP will be valid from the 19th of December 2013 and replace the current VGP (2008
VGP).

Thrusters and gears are affected by discharges from oil-to-sea

oil sea interfaces and cathodic protection under the new VGP.
Generally speaking, the affected components in thrusters & gears will be:
• Dynamic propeller shaft seals
• Dynamic propeller blade seals
• Dynamic steering column seals
• Other special-to-product
product static and dynamic seals
• Recommended lubrication oil (gear and hydraulic oil)
• Sacrificial anodes

The technical evaluation involves considerations of technical feasibility against the sailing fleet of units and against
new OEM-units to be delivered beyond the 19th of December 2013.
For the sailing fleet, a dry docking will be required to perform the upgrade.

Status:
There are currently no Environmentally
mentally Acceptable Lubricants (EAL’s) that are compatible with this seal material,
material and
hence there are no technically feasible solutions available.
available. Neither is it recommended by the manufacturer of these seals
to expose the material to bio-degradable
degradable oils or EAL’s.
Work is ongoing, both internally and externally with
with our suppliers to determine a solution to this issue. Necessary
information on the determined solutions will be distributed with reference to the specific equipment once it becomes
available
Work instructions which detail the requirements surrounding thethe integration of EAL’s into existing in-service
in equipment
currently using mineral oils, should be attained by way of consultation with the oil supplier.

Recommended action:
If the use of an EAL in an oil-to-sea
sea interface is claimed to be “technically infeasible”,
infeasible”, the ship must carry documentation
to that effect.. Such a document/statement written by Rolls-Royce
Rolls Royce Marine or owner shall be not more than one year old
and confirm the actual situation.
Rolls-Royce Marine AS Propulsion - Ulsteinvik, will provide such documentation by request.

Contact information:
For further information, please contact Rolls-Royce
Rolls Royce Marine through the contact information in the footer of this letter.

Rolls-Royce Marine AS, Marine Services, Propulsion – Ulsteinvik, Sjøgata 98, NO-6065 Ulsteinvik Norway Template id.: DMN300005271
24/7 Technical Support +31 20 700-6474
6474 / +1 31 2725 5727 / +65 68 185 665 * Rev.: B
E-mail: marine247support@rolls-royce.com Approved date: 23.09.2013
* Website: www.rolls-royce.com/marine247 Approved by: JOH