EPA-HQ-OAR-2008-0708-DRAFT-0308[1] From: Suchecki, Joe [JSuchecki@ngelaw.com] Sent: Monday, December 14, 2009 2:12 PM To: Tanya Parise Subject: RE: oil analysis program

Tanya,

Here is the EMA response to your question regarding an oil analysis program. Our assumption is that you are interested in compression ignition/diesel engines at this time since the stationary diesel engine regulation needs to come out soon. The following response is relevant to compression ignition engines. Spark-ignited, gaseous fueled engines have different characteristics and we will work on getting you a specific answer for them shortly.

Joe

The following applies to compression ignition engines

As EMA has mentioned in previous comments, the maintenance and oil change intervals for a specific engine depend on the characteristics, size, and operating cycle of the engine and there is no standard acceptable, maintenance schedules that fit all engine or operating conditions. For all but the largest stationary diesel engines, the best and most cost-efficient practice is to follow the recommended oil change interval recommended by the engine manufacturer.

For some large compression ignition engines, it may be cost effective to run an oil analysis program. Such programs can be used to adjust the recommended oil change interval as needed to minimize costs and ensure that the oil continues to meet any required specifications. For larger engines, say above 500 hp, or where the cost incurred by implementing an oil-analysis program can be balanced against savings from potentially longer oil change intervals. As an example, for a 100 hp diesel engine, the cost of collecting and analyzing the in-use oil is most likely greater than any savings that might result from a slightly longer oil change interval.

Given the above, however, EMA does not believe that EPA should mandate an oil analysis program for any size engines. Rather, in terms of required maintenance, EMA believes that EPA should allow owners and operators the option to perform oil analysis as a way to demonstrate the feasibility of adjusting or extending the manufacturer's recommended maintenance interval if they would like to do so.

Joe Suchecki Director, Public Affairs Engine Manufacturers Association Two North LaSalle Street, Suite 1700 Chicago, IL 60602

Tel: 312-827-8734

Fax: 312-827-8737 j suchecki@emamail.org www.enginemanufacturers.org

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From: Tanya Parise [mailto:parise.tanya@ecrweb.com] Sent: Tuesday, December 08, 2009 1:27 PM To: Suchecki, Joe Subject: oil analysis program
Joe,

Melanie wanted me to ask you one additional thing. I know EMA has previously helped out with the issue regarding maintenance practices and I understand that it’s EMA’s position that there aren’t any maintenance practices that would be suitable to all engine types. However, we’d really appreciate your thoughts on a potential oil analysis program. I know Waukesha specifically recommends that oil changes be through such a program if feasible. What is EMA’s position regarding maintenance based on an oil analysis program? Is this something EMA would be in favor of?

Tanya

Tanya Parise EC/R Incorporated 501 Eastowne Drive, Suite 250 Chapel Hill, NC 27514 (919) 484-0417

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