### Technical Memorandum

Date: November 30 , 200 9

To: Melanie King, EPA OAQPS

From: Stephanie Meadows / Matt Todd, API

Cc: API RICE NESHAP Compression Ignition Management Practices Workgroup

Subject : Diesel RICE Management Practice s and Oil Change A nalysis Program

API appreciates you taking the time to discuss our submittal of information on November 2 nd , including

the MACT Floor Determination for 50 HP to 500 HP Diesel Engines (CI RICE). During the call, you requested additional information on ind ustry ma intenance practices for maintenance and our Oil Change Analysis (OCA) programs. As the “best management practice”, API continues to support written operating and maintenance (O&M) plans developed by the operator. This allow s the operator flexibil ity to optimize the time interval between maintenance activities based on performance metrics unique to each company and engine application/service. Over the past decades, c ompanies have developed maintenance procedures specific to each engine type and/or model to protect the substantial investment in RICE necessary to keep our operations in motion. API believes requiring these procedures to be in a written plan

, along with the provisions of 40CFR63.6(e)(1)(i)

, w ill enable EPA to enforce the “management practice” for RICE without catalyst and ensure good combustion practices to minimiz e the e missions of HAPs

.

API plans on providing additional information for spark ignition (SI) RICE in the coming months due to the six month delay to finalize regulations for these units. Since API had insufficient time to develop analogous information for compression ignition (CI, or diesel fueled) RICE, API would like to offer the supplemental comments on the fixed oil change frequency maintenance practice as proposed. Additionally, we are provid ing further clarification on an OCA program that would serve as an alternative compliance option for diesel engines . We believe both options fulfill EPA’s desire to have

standards that are clearly defined and enforc e able

.

Fixe d Oil Change Frequency Management Practice

A. EPA proposed that oil must be changed in all engines <50 hp every 200 hours. API believes that

this short of interval is unsupportable

, burdensome and unnecessarily generates excess waste

. T he oil change frequen cy should be the same as larger engines of a similar category and no less than every 500 operating hours.

B. EPA proposed that oil must be changed every 500 hours on emergency CI engines from 50 hp to 500 hp. API believes that this frequency is appropriate f or all emergency and limited use CI engines of any size.

C. EPA proposed that oil must be changed every 500 hours on non

- emergency CI engines from 50 hp to 300 hp. API recommends an oil change frequency no less than 1440 hours.D. API recommends that all oil ch ange intervals specified in the final rule be expressed as ± 10% of the

number of hours between oil changes. This gives operators some flexibility to schedule maintenance

but

, most importantly

, the critical abil i ty to finish any operating use of an engine during an emergency situation

.

Oil C hange Analysis Program

- Parameters

Many o perators analyze the condition of the oil instead of assuming the oil needs to be changed or they use analyses to determine the normal oil change frequency . These OCA pro grams vary substantially based on type of engine, type of oil and the rigor desired by the company. A detailed laboratory OCA can test many different parameters, and o il change condemning limits of some of these parameters may be proprietary information o f the lube oil manufacturer for competitive advantage reasons

. However,

many OCA programs ha ve the following three basic parameters in common :

1. T B N 1

- Total Base Number (TB N) measures alkalinity of the lube oil. It is measured in milligrams of potassium hydroxide per gram (mg KOH/g). The higher the TBN, the more effective it is in suspending wear

- causing contaminants and reducing the corrosive effects of acids over an extended period of time. Over time, the TBN can decrease from its original new oil va lue as it neutralizes acid build up.

2. Viscosity

– Viscosity , a measure of flow, can change from new oil measurements and is a primary

indicat or of oil life degradation

. In CI engines

, contamination from soot can increas e viscosity or oil

contaminants

, such as fuel oil

, can decreas e viscosity.

3. Water (% content by volume )

- % water content (by volume) is the primary indicator of water

contamination in the oil.

These three tests can be completed in the field using a field analysis kit available from several different

vendors , or oil samples can be sent to a lube oil specialty lab for analysis.

Specific warning levels used to indicate that the oil should be changed can vary by engine design, oil specification s and company experience. In the table below, t h e warning levels (also known as “condemning limits”) for TBN and viscosity are relative to the new oil specification

. This provides greater flexibility to account for the differences in new oil properties.

Diesel RICE Oil Warning Levels

Oil Parameter Warning Level Oil Degradation Indicated by

Parameter

T B N (mg KOH/g) < 3 0% of new

o il TBN pH indicator

Vis @ 100 o C, (cSt)

- 20%/+30% change from

new oil Oil viscosity

Water (%) > 0.5 Water contaminant indicator

1 Note that TBN is used for diesel e ngines as the appropriate indicator for pH in OCA programs. SI engines typically use total acid number (TAN) as an indicator of pH in OCA programs.If an OCA is used, the operator would be required to change the oil within 14 days of receiving OCA

results exceeding the warning level. Utilizing OCA programs have proven to reduce waste generation, while maintaining the operating integrity of the engine.

O il C hange A nalysis Program

- Fre quency

Initially, an OCA program should inspect oil at the same frequency as oil changes are required for the engine category and size (i.e.

, 1440 operating hours). However, after several oil test/change cycles have been completed for specific oil and eng ine type, OCA programs may allow extended period s before the oil is tested or changed. A regulatory precedent for this type of extended period is current ly found in the leak detection and repair regulat ions such as NSPS Subpart VV (40 C.F.R. §6 0.483

- 2 a )

. S kip period oil testing/changing could prove effective in dealing with premium oils and engine designs that are capable of utilizing extended monitoring i ntervals. EPA sh ould consider a form of skip or extended period monitoring that would allow for an a ffected facility to skip a required interval or extend the intervals

based u pon successful checks of the previous two intervals. For example, if a parameter w arning l evel

w as not exceeded after two inspection periods, then inspection periods could be incr ementally extended by 1,440 hours after the next oil change. If further testing/change cycles still indicate an even longer period is supportable, an additional skip period should be allowed. This would also reduce the amount of alternative monitoring re quests submitted to the agency due to the use of premium oils and improved engine design s.

API requ ests that operators have the option to change the oil within the specified frequency of the final

rule or analyze the oil as part of an enforceable OCA pr ogram that contains

, at a minimum

, the three parameters above (for diesel engines)

. However, any final OCA rule language needs to also allow the flexibility for more comprehensive OCA programs to continue and also avoid jeopardiz ing proprietary

information

.

Administrator A pproved Alternative Programs

Because of the wide range of engine types, engine duties, and industries affected by this rule, the default “fixed frequency oil change” and OCA programs described above will not be suitable for all operat ors. The operator always has the alternative to apply for an alternative emission standard (i.e.

, work practice) under the provisions of 40CFR63.6620. However, API believes that EPA should provide stre amlined procedures for approval of the alternative. For example, the operator should apply for the petition as required in 40CFR63.6620, but should be able to utilize the proposed alternative, unless the operator hears otherwise from the Administrator within 60 days.