EPA-HQ-OAR-2008-0708-DRAFT-0305[1] To: Melanie King/RTP/USEPA/US@EPA From: "Matt Todd" <ToddM@api.org>

Date: 02/05/2010 04:49PM Subject: RE: Re: Diesel RICE Management Practices and Oil Change Analysis Program
Melanie,

Oxidation products in lube oil may lead to increased viscosity (causing or contributing to oil thickening problems), acidity (causing or contributing to corrosion), and formation of sludge and varnish (leading to filter plugging, fouling of critical oil clearances and undesired valve friction). If oxidation becomes a problem it will be evident in viscosity degradation and changes in acidity (TBN). Changes to viscosity and TBN are more important as primary indicators of oil failure that may indicate oxidation is the cause, but other causes such as soot or water could also negatively impact viscosity and TBN.

TBN (total base number) measures the amount of buffering capacity remaining in a sample of oil. By comparing the TBN of used oil to the TBN of the same oil in virgin condition, the analysis can be used to determine the remaining reserve capacity of the oil to neutralize acids. The TBN as well as the other parameters that API recommended can be checked in the field with a portable kit without a requiring a more expensive laboratory analysis.

Viscosity is a primary oil condition parameter for determining changes to the oil’s lubricating properties and the accumulation of undesirable contaminants in the oil. Viscosity is defined as resistance to flow. It is referred to as an oil's thickness at a given temperature. Changes to viscosity can result from contamination of the oil. Moisture, fuel, and antifreeze can cause the viscosity to increase or decrease, depending on the contaminant and how long it has been present in the oil. The consensus parameters and condemning limits proposed by API are based in large part on ASTM D6224 - Standard Practice for In-Service Monitoring of Lubricating Oil for Auxiliary Power Plant Equipment. This method provides useful guidance however; it may not always be appropriate for certain engine applications amongst the large diverse population of diesel engines. Per the stated method limitation, “This practice does not necessarily reference all of the current oil testing technologies and is not meant to preclude the use of alternative instrumentation or test methods which provide meaningful or trendable test data, or both.” The proposed API parameters and condemning ranges are thought to encompass the key oil change parameters recommended by ASTM for proper asset management. Though recommended by EMA, oxidation is not an ASTM recommended parameter to check for diesel engines.

A lthough this active method covers auxiliary equipment including diesel engines, this test method is being revised [Work Item: ASTM WK13579 - Revision of D6224-02 Standard Practice for In-Service Monitoring of Lubricating Oil for Auxiliary Power Plant Equipment] to address other types of synthetic lubricants that are frequently used and updated analytical parameters as part of oil condition monitoring standards.

A ny final oil condition analysis needs to also allow the flexibility for more comprehensive OCA programs to continue and should also avoid jeopardizing proprietary information. Because of the wide range of engine types, engine duties, and industries affected by this rule, API believes that EPA should provide procedures for approval of an alternative program (see attached API memo dated November 30, 2009).

Feel free to contact me with any additional questions.

Thanks,

Matt

From: King.Melanie@epamail.epa.gov [mailto:King.Melanie@epamail.epa.gov] Sent: Thursday, February 04, 2010 11:56 PM

To: Matt Todd Subject: Fw: Re: Diesel RICE Management Practices and Oil Change Analysis Program

Page 1EPA-HQ-OAR-2008-0708-DRAFT-0305[1] Hi Matt, got your message, COB tomorrow is fine.

Melanie King Energy Strategies Group Sector Policies and Programs Division Office of Air Quality Planning and Standards U.S. Environmental Protection Agency

Mail Code D243-01 RTP, NC 27711

Phone: (919) 541-2469 Fax: (919) 541-5450 king.melanie@epa.gov

-----Forwarded by Melanie King/RTP/USEPA/US on 02/04/2010 11:55PM ----- To: "Matt Todd" <ToddM@api.org> From: Melanie King/RTP/USEPA/US

Date: 02/04/2010 10:30AM cc: Meadows@api.org Subject: Re: Diesel RICE Management Practices and Oil Change Analysis Program

Hi Matt, We're still working on the concept of including an oil analysis program in the rule. We had asked other folks to provide input about parameters that would be appropriate. The Engine Manufacturers

A ssociation concurred that viscosity and water content were important parameters. They suggested an oxidation test rather than total base number. Thoughts? Is oxidation a parameter that you would look at as part of an oil analysis?

A lso, are there specific methods (ASTM methods for example) that you follow when measuring the parameters that you recommended?

Melanie King Energy Strategies Group Sector Policies and Programs Division Office of Air Quality Planning and Standards U.S. Environmental Protection Agency

Mail Code D243-01 RTP, NC 27711

Phone: (919) 541-2469 Fax: (919) 541-5450 king.melanie@epa.gov

"Matt Todd" ---11/30/2009 04:19:29 PM---Melanie,

From:

"Matt Todd" <ToddM@api.org>

To:

Melanie King/RTP/USEPA/US@EPA

Cc: Page 2EPA-HQ-OAR-2008-0708-DRAFT-0305[1]

"Stephanie Meadows" <Meadows@api.org>, RobertJ Wayland/RTP/USEPA/US@EPA

Date:

11/30/2009 04:19 PM

Subject

:

Diesel RICE Management Practices and Oil Change Analysis Program

Melanie,

A PI is pleased to submit the attached supplemental information regarding management practices for diesel RICE along with information to support an oil change analysis program option.

Please feel free to contact me with any additional questions.

Thanks,

Matt

Matthew Todd

A PI

1220 L Street NW Washington DC 20005

202.682.8319 www.api.org [attachment "2009-11-30_diesel_management_practices.pdf" deleted by Melanie King/RTP/USEPA/US]

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