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.
Although 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.  
Any 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

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 
Association 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? 
 
Also, 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:
 
"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, 
  
API 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 
API 
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] 