There is growing concern over the environmental impact and associated costs of lost petroleum-based fluids. The US National Oceanic and Atmospheric Administration (NOAA) estimates over 700 million gallons of petroleum enter the environment each year, over half of which is due to irresponsible and illegal disposal. It is estimated that up to 80 percent of hydraulic fluids leave systems through leaks, spills, line breakage, and fitting failure.

Petroleum is persistent and toxic. It damages living organisms, including plants, animals, and marine life, for many years. In addition, the US Coast Guard, Environmental Protection Agency (EPA), and local governments are increasing the range of responsibility of lubricant releases, including significant fines and clean-up costs.

There are many different contributors to oil released into the ocean, including oil spills, routine maintenance, and natural seeps. As demands on lubricant systems increase, the likelihood of accidental fluid release increases. Increased operating temperatures, pressures, and working cycles shorten the life of circuit components.

The single best approach to protecting the environment, the equipment, and the operation is to prevent leaks and spills through good routine maintenance. A good preventative maintenance program will:

• increase productivity since equipment is utilized more,
• better utilize in-shop maintenance due to less emergency work,
• improve control of spare part inventory and reduce parts usage,
• reduce equipment down time,
• reduce safety hazards,
• increase equipment life,
• reduce fines and clean-up costs due to environmental release, and
• reduce down time related to environmental release.

Myth 1: The Coast Guard Approves Non-Sheening Oils
There are increasing regulatory pressures from the EPA, Coast Guard and other organizations. While small releases will not result in a Resource Conservation and Recovery Act (RCRA) clean-up, large spills will. All petroleum hydraulic fluid spills are "reportable events." These events involve a great deal of clean-up cost, administrative procedures, and punitive fines ranging from tens of thousands to hundreds of thousands of dollars.

While spilling large quantities of biodegradable hydraulic fluid is still considered under RCRA to be a reportable event, agencies are required to evaluate "bio-based oils" differently than petroleum-based oils. As awareness of biodegradable fluids increases, state and federal agencies become more lenient regarding fines and clean-up costs. In fact, there are many case studies of equipment releasing several hundred gallons of vegetable-based hydraulic fluid into environmentally sensitive areas with no fines and minimal clean-up expense. In most instances, the operator was able to continue working during clean-up efforts. Since the fluids were biodegradable and non-toxic, there was no long-term negative effect to the ecosystem.

There is a common misperception that the Coast Guard approves oils based on the oil not leaving a sheen. This is not true. The Coast Guard does not approve, recommend, nor endorse any fluids. Furthermore, the Coast Guard does not approve nor recommend any test procedures, but rather, follows United States statute laws. The oil sheen that is frequently referenced is inferred from the Clean Water Act as defining "any substance that leaves a sheen, emulsification, or discoloration, as a pollutant and be subject to appropriate fines and regulations governing pollutants." The Coast Guard also relies on the guidelines as outlined by equipment manufacturers and highly favors the use of bio-based and biodegradable fluids.

Myth 2: "Inherently Biodegradable" Products are Environmentally Safe
There is no single definition of biodegradability. Throughout the United States and internationally there is a wide range of environmentally preferable definitions. The ASTM has defined biodegradable as a function of degree of degradation, time, and test methodology.

Despite these definitions, there are two widely used designations for biodegradability, readily and inherently. Readily biodegradable is defined as degrading 80 percent within 21 days as measured by the decrease of a test sample. This degradation is preferable because, in most cases, the fluid will degrade long before environmental damage has occurred. Thus, they require little in terms of long-term bio-remediation. Vegetable-based lubricants and some synthetic ester-based products exhibit ready biodegradation.

There are several petroleum-based lubricants that claim "inherent biodegradability," defined as having the propensity to biodegrade, with no indication of timing or degree. These products can persist in the environment for years, continuing to cause substantial damage. They require long-term remediation due to the environmental persistence. Typically, these products are petroleum-based, like conventional lubricants. It is easy for the EPA and Coast Guard to see the difference between a readily biodegradable product and an inherently biodegradable one, and they utilize this differentiation when evaluating an oil release.

Myth 3: Food-Grade Products are Environmentally Safe
Another measurement to determine environmental effect of a lubricant is "eco-toxicity." Historically, tests for eco-toxicity have concentrated on the aquatic environment with a number of standard test procedures. Most typically, the tests are for "acute toxicity" - the concentration required to kill various organisms over a short period of time (24-96 hours).

Depending on the tests and its end points, the toxicity of a fluid is described by a loading rate that has a 50 percent effect (EL50) or causes 50 percent mortality (LL50) after the stated time. That is, at what concentration of fluid one half of the sample organisms die.

Attempts have been made using "food-grade" lubricants to protect the environment. While food-grade oils seem like a good idea, it is highly impractical for underwater applications. First, food-grade products are designed for equipment in food processing plants. They are toxic. In fact, an entire batch of food must be discarded in the event of contact with the lubricant. Secondly, they are environmentally persistent (non-biodegradable), meaning they are toxic to marine life for long periods of time. Lastly, they are designed for very light duty usage and break down quickly under typical pile driving temperatures and pressures.

Myth 4: All Biodegradable Products Work the Same
There are a wide variety of performance levels among biodegradable products. Traditionally, a lubricant is compounded from base oil and a variety of performance chemistries. Early pioneers in the vegetable-based lubricant market used the same chemistry that was used for petroleum lubricants in vegetable based-oils.

It was a great idea, but it didn't work. The characteristics of vegetable oils are vastly different than those of petroleum oils. Vegetable oils had to be formulated for their individual strengths and limitations. Today, there are several vegetable-based products on the market. They offer good performance and a fair price. While all vegetable-based lubricants have temperature limitations, there are some that are better than others. One should check with their lubricant supplier to determine their maximum and minimum operating temperatures. While most vegetable-based lubricants have a maximum operating temperature of 140 degrees F, some offer protection as high a 220 degrees F. Similarly, most vegetable-based lubricants offer good performance to 30 degrees F, yet there are some that flow below -30 degrees F.

When an environmentally preferable product is required outside the common temperatures range, a biodegradable synthetic is usually required. While offering biodegradation, these products can operate in temperatures in excess of 400 degrees F and still offer long fluid life. As would be expected, these products are significantly more expensive.

Care must be taken in choosing the appropriate product for the specific application. Responsible environmentally preferable product (EPP) suppliers can clearly indicate their definition of "environmentally preferable." The Federal Trade Commission has been very specific in their requirements for environmental claims and state, "Look for claims that give some substance to the claim, the additional information that explains why the product is environmentally friendly." Many would-be EPP suppliers use misleading environmental claims such as "inherently biodegradable" or "food grade." Suppliers should be able to support performance claims with testing data. These data can include standard industry tests (ASTM), field-testing, and equipment manufacturer tests. Unless an EPP supplier specializes in environmentally preferable products, they are probably not expert in the field.

Myth 5: Using a Biodegradable Product Will Void Your Warranty
While biodegradable products are relatively new to the underwater industry, they have a long history of successful performance. Due to the obvious benefits in the marine construction area, many equipment manufacturers have evaluated and approved a biodegradable hydraulic fluid for use in their equipment. While only few manufacturers exclusively utilize biodegradable oils for initial and service fill in their equipment, most manufacturers will offer them as an option. In the rare case where the manufacturer has not approved a truly biodegradable product alternative, a reputable EPP supplier will guarantee their fluid.

Biodegradable fluids have been used in various other industries from many years. As such, even if an equipment manufacturer has not given their approval for biodegradable fluids, there is a good likelihood that a high-quality fluid will have multiple equipment component manufactures' approvals. Check with the lubricant supplier as to additional approvals.

Protect the Environment, Save Money
Growing concern over the cost and environmental impact of lubricant spills in the pile driving industry has lead to increased interest in environmentally safer fluids. These fluids can be biodegradable and non-toxic so that they will have no long-term negative impact in the environment in the event of an accidental discharge.

While underwater users are trying their best to adhere to the regulations, there is still much confusion regarding biodegradable oils and the regulations pertaining to them. In an attempt to clarify some of this confusion, here are some important points to remember:

1. The Coast Guard does not approve any oils
2. All petroleum products are pollutants per the Clean Water Act.
3. Inherently biodegradable products take a long time to degrade.
4. Food-grade products do not biodegrade, are toxic, and are designed for light-duty service.
5. Some biodegradable oils are better than others.
6. Most equipment manufacturers approve biodegradable oils.