WASTE OIL REDUCTION FOR DIESEL ENGINES
                        by
                    Todd Sigaty
                     Carl Reller
                  Daniel Middaugh
                Alaska Health Project
              Anchorage, Alaska  99517
           Contract Number CR-817011-01-0
                   Project Officer

                    Paul Randall
            Sustainable Technology Division
      National Risk Management Research Laboratory
               Cincinnati, Ohio 45268
NATIONAL RISK MANAGEMENT RESEARCH LABORATORY
      OFFICE OF RESEARCH AND DEVELOPMENT
     U.S. ENVIRONMENTAL PROTECTION AGENCY
              CINCINNATI, OHIO 45268

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                                          NOTICE
       This material has been funded wholly or in part by the U.S. Environmental Protection Agency
(EPA) under Contract No. CR-817011-01-0 to Alaska Health Project. It has been subjected to the
Agency's peer and administrative review, and it has been approved'for publication as an EPA
document.  Approval does not signify that the contents necessarily reflect the views and policies of the
U.S. Environmental Protection Agency or the Alaska Health Project.  Mention of trade names or
commercial products does not constitute endorsement or recommendation for use.

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                                          FOREWORD
                                             I
       The U.S. Environmental Protection Agency is charged by Congress with protecting the Nation's
land, air, and water resources. Under a mandate of national environmental laws, the Agency strives to
formulate and implement actions leading to a compatible balance between human activities and the ability
of natural systems to support and nurture life. To meet this mandate, EPA's research program is providing
data and technical support for solving environmental problems today and building a science knowledge
base necessary to manage our ecological resources wisely, understand how pollutants affect our health,
and prevent or reduce environmental risks in the future.

       The National  Risk Management Research Laboratory is the Agency's center for investigation of
technological and management approaches for reducing risks from threats to human health and the
environment. The focus of the Laboratory's research program is on methods for the prevention and control
of pollution to air, land, water and subsurface resources, protection of water quality in public water systems,
remediation of contaminated sites and groundwate'r, and prevention and control of indoor air pollution.  The
goal of this research effort is to catalyze development and implementation of innovative, cost-effective
environmental technologies, develop scientific and;engineering information needed by EPA to support
regulatory and policy decisions; and provide technical support and information transfer to ensure effective
implementation of environmental regulations and strategies.
                                             i
       This publication has been produced as part of the Laboratory's strategic long-term research plan.
It is published and made available by EPA's Office jof Research and Development to assist the user
community and to link researchers with their clients.
                                         E. Timothy Oppelt, Director
                                         National Risk Management Research Laboratory
                                               m

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                                          ABSTRACT
                                             i
       This project reduced waste oil from diesel engines at remote sites in Alaska by extending oil
change intervals using by-pass filters and a closed-loop reblending process in connection with portable
field monitors and laboratory analysis.  Incidents of normal and abnormal oil degradation were recorded
and correlated between field and laboratory tests. I A quality assurace program evaluated data precision
and accuracy.                                ;

       Waste oil from diesel engines represents an environmental problem in Alaska especially in
remote areas where disposal/recycling are non-existent.  Results of this project showed that small,
isolated communities can reduce the amount of waste oil generated at the source with techniques that
are easy to implement and inexpensive.  However, they depend primarily on operator interest in closely
monitoring the engine because degradation levels need to be determined individually for each engine
and oil type by establishing  baseline data.      Frpm the worker safety view, this project reduced or
eliminated waste oil in several engines without the! added risk of worker contamination by polynuclear
aromatic  hydrocarbons. One engine eliminated waste oil altogether by using reblending technology.

       This report was submitted in fulfillment of Cooperative Agreement No. CR-817011-01-0 by
Alaska Health  Project under the partial sponsorship of the U.S.  Environmental Protection Agency. This
report covers a period of time from  August 1990 to June 1994  and the work was completed as of June
1994.

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TABLE OF CONTENTS
•Notice i
Foreword i
Abstract ;
List of Tables • • i
List of Figures «
List of Appendices . |
Acknowledgments i
!
SECTION 1 - INTRODUCTION I
Project Description j
Description of Sites :
Summary of Methods i
SECTION 2 - BACKGROUND INFORMATION • .
Past Studies :
Lubricating Oil :
Sources of Lubricating Oil >
Lubricating Oil Life Expectancy
Used Lubrication Oil
Oil Analysis ',
Oil Quality i
Oil Performance Standards i
Quality Assurance :
• Engine Warranties . ;
Oil Certification ;
Interested Parties i
Oil Manufacturers !
Engine Manufacturers i
Engine Operators
Internal Lubricant Manufacturers !
ii
iii
iv
viii
viii
ix
X
1
2
3
4
7
7
9
9
10
11
12
13
14
15
16
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17
18
18

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Consumers i 18
Government '
Health Effects of PAHS Due To Burning Waste Oil
SECTION 3 - MATERIALS AND METHODS i
Site Selection and Demography '<
Selection
Description ;
Unalaska i
Yakutat !
Hoonah . •
Kiana !
Seward ;
Bethel i
Snettisham ':
Tooksook Bav !
General Obstacles to Site Participation
Technical Equipment
Comparative Dielectric Analyzer (CDA)
Engines '•
Filters !
Analytical Methods
Experimental Design i
Diagnostic Screening ;
Phase l-Baseline
Phase Il-Methods
Phase Ill-Blending :
Field Testing CDA ;
Laboratory Analysis - i
i
Maintenance
Technology ' !
Extension of Oil Drain Interval
By-Pass Filters 1
Closed-Loop Process [
Data Evaluation i
i
SECTION 4 - RESULTS
18
19
20
20
20
22
22
22
22
22
23
23
23
23
23
24
24
25
25
27
27
27
27
27
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28
28
29
29
29
29
32
32
33
VI

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SECTION 5 -DISCUSSION	;	   50
       Field Data Compared to Laboratory Data: Abnormal Engine Wear	   51
       NormalOil Degradation	j	   51
       Abnormal Engine Wear	|	   52
       Economic Evaluation    	;	   56
             Costs	^	;	   58
             Economic Analysis	.	   58
             Recommended Calculation	\	   58
             Oil Cost Ratio	;	~	   59
             Oil Consumption Costs	,      59
             Oil Disposal Costs_	   .50
             Filter Costs	    :	   QQ
             Testing Costs	!  .	   60

SECTION 6 - QUALITY ASSURANCE.	J	   61
       Site Testing	,	!	    -      61
       Laboratory Testing	:	   61
       Total Base Number	;	   70
       Data Input	    !	.      72
       Limitations and Qualifications	'_	   72
       Data Reduction	i_	   .     	     . .   .  .    72

SECTION 7 - CONCLUSIONS	:	j	.	     :      75

SECTION 8 - RECOMMENDATIONS	[	   75
       Opportunities	:	;	    76
       Obstacles	;	   77
                                         i
                                         f                 '               '
REFERENCES	|	    79
                                         i
BIBLIOGRAPHY__	j	'	    83
                                         VII

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 LIST OF TABLES
TABLE 1
TABLE 2 ...
TABLE; 3
TABLE 4
TABLE 5
Sites, Engines and Total Number of Samples
Engine Information for Unalaska ;
Lab Selection Process i
Abnormal Lab Results due to a Low TEN
from Unalaska Engines
Precision Data for Total Base Number
21
26
30
57
71
LIST OF FIGURES
FIGURE 1
FIGURE 2
FIGURE 3
FIGURE 4
FIGURE 5
FIGURE 6
FIGURE 7
FIGURE 8
FIGURE 9
FIGURE 10
FIGURE 11
FIGURE 12
FIGURE 13
FIGURE 14
FIGURE 15
FIGURE 16
FIGURE 17
FIGURE 18
FIGURE 19
Site Location I
Trends In Oil Change Intervals '
Bypass Filter vs. Control Samples CAT3512, Engine No. 4
Average Oil Life for Different Settings 105 g Oil Sump
Bypass Filter vs. Control Samples1 CAT 3512, Engine No. 5
Bypass Filter vs. Control Samples CAT 3512, Engine No. 5
With Confidence Level
Average Oil Life for Different Oil Change Interval (OCI)
Settings CAT 3516, Engine No. 6
Control Sample Variation with Time CAT 3516, Engine No. 6
Control Sample Variation with Time CAT 3516, Engine No. 6
Bypass Filter vs. Control Samples1 CAT 3516, Engine No. 6
Bypass Filter vs. Control Samples' CAT 3516, Engine No. 6
With Data :
Bypass Filter vs. Control SamplesiCAT 3516, Engine No. 8
Bypass Filter vs. Control Samples' CAT 3516, Engine No. 8 .
With Data ;
Control Samples Engine, Volvo MD11C
1.5% Oil: Fuel Blend Engine, Volvo MD1 1C
1.5% Oil: Fuel Blend Engine, Volvo MD11C
Control Extended to Zero TBN Engine, Volvo MD1 1 C
Total Base Numbers and CDA Response Compared to
Hours on Oil :
Quality Control Samples for Total Base Number
5
8
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
53
54
     iviii

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FIGURE 20
FIGURE 21
FIGURE 22
FIGURE 23
FIGURE 24
FIGURE 25
FIGURE 26
FIGURE 27
APPENDIX A
APPENDIX B
Quality Control Samples for Blank
Quality Control Samples for Visco
Precision for Quality Control Spita
Accuracy for Quality Control Spike
Precision for Quality Control Spite
Accuracy for Quality Control Spikt
Calibration Curve for Comparative
Quality Control Samples for Total
LIST OF i
Engine Warranty Discussi
Oil Certification and Oil Dr
s
sity
5s of 9 ppm
53 of 9 ppm
3S of 90 ppm
}s of 90 ppm
Dielectric Analyzers
Base Number
APPENDICES
on
ain Interval History
55
63
64
65
66
67
68
69
86
91

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                                  ACKNOWLEDGMENTS
       We acknowledge the Department of the Army tank-automotive command  and Allied Signal Inc.
for their valuable comments on our draft report.  We acknowledge those engine operators without
whom this study and report could not have been accomplished.  The villages and towns of; Kiana,
Nunapitchuk, Pilot Station, Tooksook Bay, St. Mary's,  Bethel, Seward; Tatitlek, Yakutat, Hoonah,
Snettisham, and Unalaska.                   ;

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                                          SECTION 1

                                        INTRODUCTION

        Over one billion gallons of waste oil are generated each year in the U.S. (4).  An Alaskan oil
company spent over $10 million to clean up roads contaminated with waste oil in the Kenai National
Wildlife Refuge (5).  The U.S. government spent over $32 million to buy all the homes and seal off the
town of Times Beach, a town whose roads were contaminated with waste oil (6). A gas pipeline
company is paying over $400 million to clean up pits contaminated  with waste oil (7). No one knows
the total cost from these damages, but we do know that displacing entire communities shreds the fabric
which binds societies together.                 ;
        Although it was not the oil that caused these problems, the ease with which toxic substances
are introduced into oil, due to inadequate controls (5), continues to cause millions of dollars of
damages.  Even a careful generator of waste oil may not be able to prove that oil dumped years ago is
not the source of newly discovered contamination;
        The Environmental Protection Agency (EPA) designates source reduction as the preferred
method of environmental management. Source reduction means any practice which reduces the
amount of a pollutant prior to recycling, treatment; or disposal. Source reduction methods include
equipment and procedure modifications in maintenance and training (1).
        The generation of energy is critical to remote villages, marine vessels, and military bases
throughout Alaska. The process of generating that energy with diesel generators produces large
quantities of used oil.  If not properly managed, used oil can be a health hazard, an environmental
danger, and a costly expense.  Engine operators change the  oil at  a rate recommended by the engine
manufacturer.
        Oil change intervals (OCIs) are recommended by manufacturers based on  industry standard
conditions. Most equipment operators change lubricating oil based on time without regard to  engine
use, such as  once a month or every 500 hours. OCIs are time-based because of the simplicity in
record keeping. Although time is a variable in oil degradation, fuel and lube oil consumption rates,
sulfur content, and environmental conditions are the causative agents in oil degradation (2).  Flexible
OCIs based on analyses are not permitted for the general consumer, in part because consumer
warranty damage claims related to engine failure would be difficult to refute without knowledge of
engine operating conditions regarding potential contributions from extended OCIs (3).  It would not be
unreasonabteofor engine manufacturers to authon'ze OCIs based on analyses instead of time for
professional fleet mechanics and large (>2,000 hp.) diesel engine operators who are able, and willing,
to keep  records to maintain warranty continuity.  !
        Extending OCIs requires oil analyses and 'feedback from the  laboratory; however, a  remote site

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 engines could log several thousand hours before sample results get back to the operator. Real-time oil
 monitoring permits OCIs adjusted to actual operating conditions. Sensitive on-site oil monitoring may
 detect abnormal wear in time to avoid catastrophic failure.
        Every extra oil change increases the risk,of a spill. Every extra barrel of waste oil increases the
 chance of leaks, contamination, or improper disposal. Every hour spent changing oil means an hour of
 down time. Until recently, the benefits associated!with frequent oil changes outweighed the risks* of
 engine wear. In the past, waste oil volumes depended on engine design and recommended oil change
 intervals. Early engines lost 10% of the oil every,;hour, along with an equivalent amount of the
 contamination.  Because oil was cheap and disposal was free, oil changes were based on
 manufacturers' recommendations or seasons, regardless of oil condition.  Now, engines are 100 times
 more oil efficient, meaning, much less contamination is lost in escaping oil (8) and disposal can be
 expensive. Increased OCIs allows decreased purchasing, handling, shipment, and storage costs.

 PROJEECT DESCRIPTION                     i
                                              |
        This  study is intended to bridge the gap between reports which identify waste oil as a problem
 and research on oil life extension and remote site; recycling. The  questions asked by this study are
 listed below:                                   i
                                              I                       '
        1.  Based on field and laboratory measurements of crankcase oil, can manufacturer
 recommended oil drain intervals be  increased?   ;
        2.  Do by-pass filters increase the life expectancy of lubricating oil?  If so, how long can drain
 intervals be extended without increased engine vikar? Which filters are efficient, effective, and
 economical?  Can a closed-loop process eliminate waste oil?  If so, how much?  Is the closed-loop
 process efficient, effective, and affordable?       !
        3. Can small, isolated communities recycle waste oil safely and economically using simple
 filtration technology and field tests?  Does extending lubricating oil life increase  the concentration of
 polynuciear aromatic hydrocarbons and place used oil handlers at an increased health risk? Filtration is
 defined for the purpose of this project to mean physical  separation of liquids  and solids. For example,
 present day technology uses screens, belts, drums, presses, flocculation, gravity sedimentation,
 freezing, centrifuges, and media filters to separate solids and liquids (9).  The last two types are
 commonly used  in by-pass filters.               i
        Using several remote sites in Alaska,  a study of  the extension of Oil Change Intervals was
 carried out over a period of three years.  The  sites selected for this study included stationary electric
 generation facilities, one marine vessel, and one federal hydroelectric facility. The initial portion  of the
 study was to  extend OCI's  by using analysis alone. Phase two of this study utilized by-pass filtration
that is effective in the removal of water, unburned fuel, acids, and small metal contaminants below
20um. Phase three utilized a closed-loop process that blends oil removed from the engine at pre set
                                              ! 2                                 ;

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 rates to be burnt with the fuel to eliminate waste oil altogether.  This process has the advantage of
 actually increasing the quality of the fuel, while using the oil at a rate equal to an oil change every 150
 hr. to 300 hr. .dependent on initial analysis.

 DESCRIPTION OF SITES                     !

       The site locations are shown on Figure 1.:

       Kiana is a village located on the North bank of the Kobuk River above the Arctic Circle.  It is
 57 air miles from Kotzebue.  Kiana is located in the transitional climate zone which is characterized by
                                             !                                      '
 long cold winters and cool summers. The mean Rummer temperature is 60 F while the mean winter
 temperature is 22 F.  The annual precipitation is 16 inches.
       Pilot Station is a village located on the Northwest bank of the Yukon river, 11 miles east of Sit.
 Mary's in the Yukon-Kuskokwim Delta area.  The |climate of Pilot Station is more maritime that
 continental.  The mean summer temperature is 56 F while the mean winter temperature is 20  F. The
 annual precipitation is 60 inches.                [
       Nunapitchuk is a village located on the right  bank of the Johnson River, 26 miles Northwest of
 Bethel in the Yukon-Kuskokwim Delta area.  The climate of Nunapitchuk is more maritime than
 continental.  The mean summer temperature is 56 F, while the mean winter temperature is 20 F.  The
 annual precipitation is 60 inches.                >
       St. Mary's is a village located on the North bank of the Andreafsky River in the Yukon-
                                             i
 Kuskokwim Delta area.  The climate of St. Mary's is both maritime and continental with greater
 maritime influence. The mean summer temperature  is 56 F while the mean winter temperature is 25 F.
The annual precipitation is 60 inches.            i
       Tooksook Bay is a village located on Nelson Island in Southwestern Alaska.  It is 506 air mails
from Anchorage and 200 hundred miles to the west of  Bethel.  The climate of Tooksook  Bay is
 maritime. The mean summer temperature is 48 F,; while the mean winter temperature is 14 F. The
annual precipitation is 25 inches.
       Bethel is a village 90 miles from the mouth of  the Kuskokwim River in -Southwestern Alaska.
The climate of Bethel is more maritime than continental with modifying daily temperatures during most
of the year.  The mean summer temperature is 53 F, while the mean winter temperature is 11  F.  The
annual precipitation is 18 inches.
       Unalaska is a village located on Unalaska
the community of Dutch Harbor. By air it is 4 hours from Anchorage. The climate of Unalaska is
maritime.  The mean summer temperature is 48 F
, while the mean winter temperature is 30 F.  The
annual precipitation is 58 inches.
       Seward is a community located on Resurrection Bay on the Kenai Peninsula, in the Prince
 Island in the Aleutian chain across Iliuliuk Bay from

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William Sound area of South Central Alaska. The city is 128 highway miles south from  Anchorage.
The climate of Seward is  more maritime than continental. The mean summer temperature is 56 F,
while the mean winter temperature is 25 F. The 'annual precipitation is 65 inches.
       Tatitlek is a community located in  Prince William Sound of South Central Alaska , just south of
Valdez on the Northeast shore of the Tatitlek Narrows. The climate of Tatitlek is more maritime than
                                            \
continental.  The mean summer temperature is 55 F, while the mean winter temperature is 26 F: The
annual precipitation is 167 inches.              '
       Yakutat is an isolated coastal community; situated in the lowlands along the Gulf of Alaska.  The
maritime climate of Yakutat is characterized by relatively mild but often rainy weather. The mean
summer temperature is 51 F, while the mean winter temperature is 28 F. The annual precipitation is
132 inches.                                  ;
       Hoonah is a village located on the Northeast shore of  Chichagof Island, about 40 miles
Northwest of Juneau in the Southeast Alaska Panhandle.  The maritime climate of Hoona is
characterized by cool summers and mild wintersJ The mean summer temperature is  57  F, while the
mean winter temperature  is 33 F. The  annual precipitation is 54 inches.
       Snettisham is a village located on the mainland about 50 miles Southeast of Juneau in the
Southeast Alaska Panhandle. The maritime climate of Snettisham is characterized by cool summers
and mild winters.  The mean summer temperature is 57 F, while the mean winter temperature is 33 F.
The annual precipitation is 50 inches.          ;

SUMMARY OF METHODS
                                            i

       A Quality Assurance Plan (GAP), prepared at the beginning of this study (AHP 1991) describes
the detailed approach and scientific  rationale used to extend oil life.
       The experimental  design of this study had three phases. A baseline was established to verify
the condition of the engine for liability purposes and assessment of data  reproductivity and
representativeness.  Upon completion of the baseline data, by-pass filters and a closed-loop
re-blending process were run to monitor their effect on used oil.
       Initially, a diagnostic screening was used to determine if the potential candidate had any
problems which would complicate the study such; as a coolant leak or excessive engine wear.
                                            I  '.                    .     ' '
Approximately twice as many engines as needed were screened to assure enough were available for
the study.                                    ;
       Phase I, baseline, selected engines and determined the baseline trend of oil degradation during
the cycle of a normal oil change interval.  This phase judged if the oil change interval could be
extended based on analysis alone.
       Phase II, methods, used oil analysis to monitor the effects of several by-pass filters on oil
degradation.  Both the laboratory and project manager recommended an increase or  decrease of oil

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FIGURE 1 -  Site Locations
                                                                       0
                                                                       0
                                                                        o
                                                                     0
                                                                    0
                                                                  D
                                                                  o

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change intervals based on information available f|rom engine manufacturers and literature, but the
actual decision was made by the operator. Regardless of the decision, the quality assurance plan
guaranteed thatthe data collected was of a known quality and useful in the statistical analysis.
        Phase III consisted of recycling used oil and blending it with unused diesel fuel.  Based on cost
and effectiveness, a closed-loop filter was selected to improve the quality of oil removed from engines.
The filtered oil was blended for use in the diesel engine or as heating fuel.
        Used oil samples were taken from the diesel engines as often as every two days. Each sample
by a Lubrisensor field monitor was tested for deviations in the dielectric constant. This test was
conducted by the engine operator on-site as well; as at the AHP office by the Project Manager.  Next,
the sample was sent to the lab for analysis of the physical and chemical properties of the oil. The lab
results were sent to AHP for review and then forwarded to the engine operator. A quality control
sample was sent to the lab with every fifth used oil sample.

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                                           SECTION 2
                                  BACKGROUND INFORMATION
 PAST STUDIES
        Past studies have evaluated lubricating oil life and the potential to extend oil drain intervals by
 using filtration units and improved maintenance. In 1973, it was known that engine manufacturers'
 warranty recommendations were very conservative and that marketed oils were capable of extended oil
 drain intervals if good maintenance was followed.  Today there still remains a need to extend OCIs in
 order to reduce equipment downtime, waste oil, and maintenance costs (10) (See Figure 1).
        Since 1973, studies have evaluated the ability of by-pass filters to extend oil life and reduce
 wear.  It has been shown that by-pass filters have improved filtration compared to full-flow filters. This
 reduces engine wear while allowing oil  drain interval extensions up to 25,000 miles (11).  Controlling
 the abrasive contaminants in the range of 2 to  22: microns in the lube oil is necessary for controlling
 engine wear (12).  By improving filtration and reducing engine wear,  by-pass filters can also provide
 the lowest total cost to the engine operator (13).  Full-flow filters do not screen particles smaller than
 20 microns, whereas most by-pass filters can screen particles below 5 microns.  Compared to a 40
 micron filter, a 30 micron filter was found to reduce wear 50%.  Likewise, wear was reduced 70% with
 15% micron filtration (12).                      :
        A study which used half full-flow filters arid half by-pass filters on engines concluded that the
 combination resulted in extension of engine wear !life up to two or three times the wear life obtainable
 with only good full-flow filtration (14). Previous studies indicate that by-pass filters can decrease
 engine wear by 50% in truck fleets as well (15). Trucking fleets have conducted tests using by-pass
filters to reduce engine wear and to extend the life of lubricating oil (16,17).  In each case, the filters
were found to reduce engine wear, but  rarely does a trucking fleet extend  the OCI with or without the
by-pass filters in fear of voiding their engine warranties. Therefore, it is difficult to quantify the ability of
the by-pass filter to extend oil life beyond the ability of the oil itself to sustain longer oil change
 intervals.
        The military has found that by-pass filters' can reduce engine wear and reduce the generation
of waste oil in remote sites in Alaska in an economically feasible fashion, but they did  not study the
extension  of OCI without the aid of filters as baseline data (18). A.survey  of 137 users of by-pass
filters in Austria concluded that by-pass filters carj significantly increase oil changing intervals and thus
reduce the need and cost for fresh oil while reducing waste (19).
        An extended oil drain  interval study conducted on 56 subjects (three types  of diesel engines,
both with and without by-pass filters) using four types of oil, found only relatively small differences
based on engine inspections after 100,000 miles (10). Recent tests have shown that use of a high

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                   FIGURE 2 - Trends in Oil Change Intervals
•g §.
•3 «

I-
       o

         -
CC d E CO
               O
               o
               o
O
O
O
CD
O
O
O
to
O
o
o
o
o
o
CO
o
o
o
CM
o
o
o

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 performance by-pass filter combined with a low-soot dispersancy oil could raise the soot trapping
 efficiency at the filter 85% and extend the diesel engine oil drain interval more than twice the
 recommended miles by engine manufacturers (20).
        In 1976, certain engine manufacturers recommended oil change intervals every 7,500 miles,
 triple the levels of the 1940's, due mainly to superior lubricants and additives.  7,500 miles was
 believed to be the maximum OCI recommendatidn and any further increase would  require development
 of new technology. Technical limitations for extension of OCI remain to be control  of engine wear,
 engine deposits, and resistance to lubricant thickening (21).
        Regular filters have been shown to begin to plug when oil  drain intervals exceed 18,000 miles.
 Good maintenance, not larger filters, is the key to successfully extending oil drain intervals (22).
 Extended drains with taxi fleet show that API SE ;oils did not control engine wear (12).
        Periodical lubricating oil analysis is essential because, if the concentrations of bearing
 elements increases, then the engine can be stopped for thorough checking, thus avoiding disastrous
 damage (23).                                  ;

•LUBRICATING OIL                            '

        Motor oil is used to lubricate engines and prevent component wear.'Motor oil is composed of a
 base stock and additives.  The base stock lubricates the internal moving parts, removes heat,  and seals
 pistons.  The functions of the additives include anti-wear,  anti-foam, corrosion protection, acid
 neutralization, maintenance of viscosity,  detergency, and dispersancy.  The quality of additive systems
varies throughout the lubrication industry, ranging! from a bare minimum to high quality.
       The four primary purposes of engine oil are: cooling of the engine, controlling contamination
and corrosion, sealing piston rings, and lubricating the moving internal parts to minimize friction and
wear.                                         ;

Sources of Lubricating Oil

       Lubricating oils are derived from crude oil. About 0.9% of crude oil production is diverted into
lubricating oils and greases (24).  When  boiled under a vacuum, crude  oil yields a base oil with a 700
to 900 degree Fahrenheit true boiling point (25).  Several base oils may contribute to a blended lube
stock.  A lube stock may be further treated to remove undesirable components such as volatile
hydrocarbons, asphalt, wax, and unstable compounds. Steam strips out volatile compounds.
       Propane extracts asphalt under high pressures.  Methyl ethyl ketone dissolves wax which can
be cooled, crystallized, then filtered out.  Hydrofinishing with heat and hydrogen slightly changes the
molecular structure and produces  a more thermally stable, lighter colored oil (26). These technologies
are examples of those commonly used for producing lubricants from crude oil.
                                              ; 9

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        Annual consumption of synthetic lubricants is about 45 to 50 million gallons per year at a cost
 of 3 to 30-times greater than crude oil lubricants (27).  Synthetic lubricating oils are more thermally
 stable and resistant to changes in viscosity due to temperature effect. Oils decompose near the top of
 the piston ring leaving deposits which accumulate, increasing friction, and eventually causing failure if
 left unchecked.  Deposits are half carbon and half metal ash 1rom additives (28). Synthetic oils leave
 less ash and are more stable. The most common synthetics used in motor oils are synthesized
 hydrocarbons, organic or phosphate esters, and polyglycols (29). The raw materials for synthetic
 lubricants are usually petroleum derived. In spite of the improved properties of synthetics, these oils
 still require many of the same additives as petroleum oils.

 Lubricating Oil Life Expectancy                 ;
                                              f                        '
        Lubricating oil is a petroleum product consisting of oil and additives used for lubrication in
 engines.  The lubricating oil itself does not wear but,  but it must be replaced to effectively protect the
 engine against wear, corrosion and deterioration.: An oil filter only removes the large particles, so the
 oil must be drained at a frequent interval or the oil will become contaminated from condensation, acids,
 and fuel dilution.  The life expectancy of the oil is determined by  the recommended oil drain interval.
 The method of operation, the driving conditions, and the quality of the oil  are all factors in this process.
 If the engine operator neglects to follow the recommended oil drain interval, then any damage to the
 engine due to this neglect may not be covered by the engine warranty.
       Oil change intervals are recommended by individual engine manufacturers. Some
 manufacturers publish rigid intervals and openly state "they will never publish wear limits based on oil
 analysis." Other manufacturers allow substantial Changes of intervals if regular testing indicates the oil
 is within limits of acceptability. In addition to manufacturers' recommendations, individual  owners make
 independent decisions based on additional criteria, such as service needs, current operating costs,
 life-cycle/overhaul ratio, and dependability requirements.  Some authorities claim engine tests at this
 time cannot predict lubricant suitability for extended oil change intervals (21). Laboratory analyses
 used to determine oil degradation are discussed  in Summary of Methods.
       Lubricating oil failure can originate from normal oil degradation, environmental conditions, and
 engine malfunction. For the purposes of this study, engine  malfunctions are considered an aberrant
cause of oil failure. • Examples of oil failure caused by faulty engines are inadequate air filtration, leaky
fuel injectors, cracked blocks, and failed water pump seals.  Fuel and water leaks decrease oil
viscosity, plug filters, precipitate additives and can lead to catastrophic failure.  Engine operators in this
study were notified of engine problems as soon as they were discovered and their participation
suspended until the engine was repaired.
       The type of fuel used in an engine influences the mode of normal oil degradation. Oil in
gasoline powered engines most commonly degrades due to water contamination and oxidation (30,31).
                                              ; 10

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 Diesel powered engine oil degrades from soot particles which blow by the rings due to higher
 compression ratios and unbumed fuel. The aqueous phase of diesel exhaust can be as acid as pH 0.4
 from sulfur, but when combined with water, contamination synergistically affects the precipitation of  -
 additives. Another mode of oil degradation in diesel engines is through  higher operating temperatures
 which increase the rate of oxidation and varnish formation.
        How an engine is used also influences oil degradation. Engines run at low speeds or  -
 excessively idled may have low oil operating temperatures.  Consequently, water condenses and builds
 up causing precipitation of additives and loss of dispersancy. Additive precipitants plug filters.
 Dispersant failure can result in soot particle "dump out" (22), a term used to describe the condition
 when a filter capable of holding only a pound of contaminants is overloaded with the several pounds of
 soot typically dispersed in a 10 gallon capacity engine oil sump.
        Environmental conditions can cause similar failures. Ambient temperature,  humidity, and
 changing atmospheric conditions can cause condensation which would not occur in an identical engine
 under different climatic conditions.   Airborne particulates not trapped by air filters abrade bearings and
 cause a rise  in wear metals and plugging of filters.
        Lubricating oil is chemically resistant to breakdown. However, used oil becomes waste oil when
 metal particles exceed filtration capability, essential additives are exhausted, or fuel and water
 contaminate the system. The  lubricating oil effective life may be extended with ultra filtration, and
 monitoring for both engine wear and oil performance.  In fact, recyclers of used oil claim oil "doesn't
 wear out it only gets dirty" (33).
                                             i  .
 Used Lubrication Oil                          j
                                             !
        Used oil becomes waste oil when the physical or chemical properties exceed limits of
 condemnation for use in an engine. Some waste oil may still be suitable for service if the oil change
 intervals are more frequent than needed.  However, used oil, once removed from the engine, often gets
 contaminated with water, gasoline,  diesel, solvents, and paint, making the mixture unsuitable for almost
 any use. Waste oil which becomes contaminated is a regulated hazardous waste.
        Carefully managed, used oil retains economic value. If specifications can be met, such as flash
 point and lead concentration (34), used oil may be burned as a fuel for heat or in diesel powered
 engines. In Alaska, as elsewhere in the United States, ocean ports are required to accept waste oil
 generated aboard ships.  However, small coastal Communities and villages have neither the experience
 nor the knowledge to evaluate the condition of used oil or to determine a reasonable means of
 recycling.  Consequently, much of the accumulated used oil and oil contaminated with water is
transported many miles at substantial costs. Indiscriminate dumping is common. For example in
Nome, Alaska a small lake was used as the unpermitted city dump (CERCLA site No. AKD980722540)
and was observed to have over a foot of waste oil floating on the surface. A creek flowing through the

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 dump was contaminated with enough lead to nearly exceed the allowable limit for hazardous waste as
 tested by the EPA during a site inspection in June 1986.  Nome has a year round resident
 environmental inspector, but in more remote villages which are inspected infrequently at best, waste oil
 disposal is unrestricted and undocumented.  Current filtration technology may make possible the
 processing of used oil on site, providing a recycled oil which meets specifications for burning (35).
        Direct observations such as carbon and ash  build-up behind piston rings and cylinder varnish
 deposits require taking an engine apart. Furthermore, varnish formation is,  in part, a function of fuel
 type and engine operating conditions (36). Waste; oil which meets specification is commonly blended
 with either heating oil and burned in a boiler or with diesel fuel in a 5% ratio to power the engine
 source.  Both Cummins Engines and International'Harvester publish guidelines for recycling crankcase
 oil through engines.                             '

 OIL ANALYSIS                                 '.
                                               i
        The objectives of an effective oil analysis program are to measure  (in terms of engine
 condition) oil contamination, oil deterioration, and engine wear metals.  From this it should be possible
 to determine oil suitability for further use, protect the customer from costly premature engine overhauls,
 and thus provide an optimum balance between engine life and effective maintenance practices.  If the
 conditions of use are not too demanding, a simple; lube stock may not need additives. However, most
 applications require additives to stabilize the oil and protect the engine.  Lubricant additives affect both
 the physical and chemical properties of oil.  Some!additives enhance inherent  properties, others prevent
 undesirable changes.  Additives can also impart new lubricating properties to the oil.
        The most commonly used additives are viscosity improvers, dispensers, detergents, anti wear
 agents, antioxidants, corrosion inhibitors, friction modifiers, foam inhibitors, and pour point depressants
 (20).  Viscosity improvers alter the change of oil viscosity with temperature.  Viscosity changes can be
 stabilized when the oil  is doped with small quantities of polyisobutylenes  or polymethacrylates (37).
 The viscosity of an oil refers to the internal cohesiveness of the oil or its resistance to flow.  Viscosity
 Index Improvers are chemicals found in modern oil designed to extend the viscosity range.
        Dispersants hold contaminants in suspension, preventing varnish formation on engine parts.
 Dispersants are similar to detergents in structure: long and ashless. Alkeenylsuccinic esters and
 Mannich bases from high molecular weight alkylphfenols are two common dispersant additives.
        Usually it is not the oil going bad that necessitates an oil change-it is the depletion of additives.
Anti-wear additives protect the engine by bonding to metal surfaces and forming a protective layer
 between moving parts. This layer does not prevent their rubbing together, but minimizes the effects of
this contact.
        Detergents are metallo-organic compounds, such  as barium, calcium and magnesium salts of
sulfonic acids, phenols, salicylic acids, or thio-phosphonic acids, these compounds lift deposits from
                                               12

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 critical surfaces such as the upper piston ring belt area (20). Anti wear agents resist scouring and
 scuffing that occurs under high pressure and temperatures. Under severe wear conditions, surfaces
 can temporarily-weld together. Mild wear agents are polar compounds like fatty oils, acids, and esters.
 Extreme wear agents ( either individually or in combination): contain chlorine, sulfur, phosphorous, and
 lead.  Antioxidants limit the degradation of oil due to oxygen exposure.  The rate of oxidation  increases
 exponentially with temperature and is affected by free radical chain reactions and metal catalysts. Zinc
 dithiophosphate is an antioxidant that both inactivates the chain reaction and forms a protective coat on
 metal surfaces. Corrosion inhibitors neutralize acids such as sulfuric acid, a corrosive product of diesel
 fuel combustion. Some detergents and antioxidants can also serve as corrosion inhibitors.  Friction
 modifiers labeled as "energy conserving" improve fuel economy and were developed as a result of the
 energy embargo two decades ago (20).  Some of these modifiers are  colloids of molybdenum, copper
 soaps, sulfurized fats, and esters. Foam inhibitors collapse air bubbles preventing frothy mixtures of air
 and oil. Silicone polymers at only a few hundred parts per million are widely used to defoam oil. Pour
 point depressants control wax formation and crystal growth at low temperatures.  Under cold conditions
 oil may solidify and resist pumping. Styrene-based polyesters and cross-linked alkyl phenols are two
 common depressants.                         ''
        Oxidation is the chemical breakdown of oil which occurs due to the extreme heat in an engine
 and can cause sludge or acidic gasses to develop which can cause corrosion or rust.  Corrosion is
 critical in  diesel engines due to the high sulfur content in diesel fuel.   To counteract the effects of
 acids, neutralizing additives are blended into oil.  JThis neutralizing capability is measured by an oil's
 TBN.  Oxidation rate is also affected by the type and amount of antioxidant and by the presence of fuel
 in the oil.                                     ;
        In 1947, engine oil contained 2.5% to 6.5% additives. Today about 15% of automotive oil
 consists of additives, although specialty formulations may range from 0.05% to 30% or more.  Finished
 oils are screened in bench tests before more expensive full-scale engine testing.  The final formulation
 of a lubricating oil relies heavily on experience and judgment.

 OIL QUALITY                                 i
                                              I                                        , "
        The quality of oil is related to its ability to lubricate and protect an engine from wear over time
 without losing its additives or becoming contaminated. The quality of lubricating oil is essential
 information to consumers as well as engine manufacturers in establishing oil change intervals.
        The American Petroleum Institute (API) administers the certification program, allowing engine
 manufacturers to place a label on each oil that has met the program's  requirements. This label, known
 as the "donut seal of approval," assures that the oil satisfies the minimum standard quality of oil. This
 level of quality assures that the oil will: 1) permit easy starting, 2)  lubricate and prevent wear, 3) reduce
friction, 4) protect against rust and erosion, 5) keep engine parts clean, 6) minimize combustion and

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 chamber deposits, 7) cool engine parts, 8) seal combustion pressures, 9) be non foaming, and 10) aid
 fuel economy. The API engine oil service classification symbol is a representation and warranty by the
 oil marketer to the purchaser that the product conforms to the applicable standards and speculations for
 engine oils established by the automotive and oil industries.  Oil manufacturers have the responsibility
 to assure that all performance standards have been met and then decide which class applies.

 Oil Performance Standards                    !
                                             I
        Oil performance standards are developed! as a minimum standard for engine oils that engine
 manufacturers deem necessary for maintaining equipment life and performance.  The oil marketers use
 the standard as a performance guide for oil.
        A minimum oil performance standard is defined by the American Automotive Manufacturers
                                             i
 Association (AAMA) based on technical and marketing input from technical societies, trade
, associations, the U.S. Army and individual consumers. A development fund supported by both the
 automotive and oil industries provides funding for new test development to modify the definition and
 .timeliness of a minimum oil performance standard which reflects changes in equipment design,
 customer usage, or fuels.                      i
        Most standards include  performance requirements and chemical/physical  properties of those
 engine oils that engine manufacturers deem necessary for satisfactory equipment life and performance.
 The Society of Automotive Engineers (SAE) Crankcase Oil Viscosity and API Engine Service are two
 necessary standards  to adequately define a motor oil's characteristics when deciding what oil an
 engine requires. The SAE Viscosity standard defines 11 grades of Viscosity; OW, 5W,(10W, 15W,
 20W, 25W, 20, 30, 40, 50, 60, (W= winter conditions). The API Engine Service standard classifies and
 describes crankcase oil by factors other than viscosity in order to aid in service requirements and
 communication between engine manufacturers, oil companies and the consumer.  API, SAE, and ASTM
 devised the Engine Service Classification System with SE, SF, SG, SH, CC, CD-II and CE suitable for
 today's cars.  S stands for Service and C stands for Commercial. The S categories are for use with
 gasoline engines, the C categories for diesel engines. The oil marketers use the  standard as a
 performance guide
 for oil.                                       :
        AAMA and JAMA jointly established the ILSAC standard.  It is composed  of five parts: 1) SAE
 viscosity classification, 2) API SG performance standard, 3) bench test requirements, 4) an informal
 standard that may be applicable in the future, and 5) engine sequence tests.   Performance standards
 often need to be revised to keep pace with changes in engine performance requirements and changes
 in formulation                                ;
 technology.                                  I
                                              14

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 Quality Assurance

       Quality Assurance is the level of guarantee that the product is equal to the quality expressed on
 the label. A consumer who purchases a container of oil needs assurance that the quality of the oil
 meets the minimum performance standard expressed on the label. An assurance of oil quality may
 offer the consumer confidence, and allow engine manufacturers to add flexibility to recommended oil
 drain intervals further it may enable them to develop improved technology.
       Certification labels are placed on the outside of the oil container to inform the consumer of the
 quality and characteristics of the oil.  Recent studies by the  U.S. Army and the Society of Automotive
 Engineers (SAE) have concluded that many oils on the market are questionably labeled. In 1979, the
 Army tested the quality of 17 commercial oils and concluded that 11 products failed to meet one or
 more of the specification's physical/chemical requirements and six  of the products had insufficient
 additives (38).  All of the products were advertised to meet the API performance level. OLAP,
 established by the U.S. Army and SAE in 1987, in order to get reasonable assurance that marketed oil
 actually met industry standards, has shown as high as 16.5% of the oils sampled were questionably
 labeled.  80% of those oils that were questionably labeled had the  API certification label (39).
       The dangers of questionable labeling practices affect the entire spectrum of the oil market.
 Consumers may purchase low quality oil and have potential engine failure, engine manufacturers pay
 the cost of an increase in warranty claims and  must delay advances in engine technology, while oil
 marketers lose credibility. Oil drain intervals remain restricted due  to the low minimum standard and
 waste oil increases.  Questionable labeling practices can be limited by a number of ways: tougher
 certification process,  an increase in testing, a more stringent post-market program, and tougher
 enforcement actions which are addressed in the new engine oil certification system being jointly
 established by API and AAMA.                '
       In 1983, General  Motors research labs conducted a survey on 250 lubricating oils. Of 41 oils
 specified as SAE 10W-40 SF/CC, 40 were apparently mislabeled and unsuitable for diesel engine use
 Six 10W-40 oils had very low additive content  and two others had no additives at all. Also, 6 out of 36
 tested for performance according to their specifications of 10W-30  SF/CC were not properly formulated
 (40).   The new oil certification process will use the Multiple Test Acceptance Criteria as a pre-market
test to discover if a given  oil meets the minimumiperformance requirements. The old API approved
 process only required,a single pass for each oil. :This means an oil marketer could re-test the oil an
 unlimited number of times and if it passed once, it is certified, but under the new system, the mean
value of each parameter must be a pass. The oil marketer will also have to provide a product
traceability code when applying for a license in addition to random  engine testing.  Any violation could
 result in temporary or permanent suspension of the license and a recall of oils in the market (41).  The
 new quality assurance elements of the engine oil licensing system aim to tighten up the quality of oil,
 regain consumer confidence and answer needs of the engine manufacturers.  The new engine oil
                                            :  15

-------
license system will also include the Chemical Manufacturers Association (CMA) Product Approval Code
of Practice.  This, in addition to the license agreement and industry code of ethics, will increase the
assurance of quality of oils on the market as well as the ethical obligation of oil manufacturers.
ENGINE WARRANTIES                       \
        Due to the important role the oil industry and engine manufacturers have in the decision of an
engine operator to extend OCI's, AHP conducted extensive legal research to analyze the impact of
engine warranty claims on the opportunity to extend oil life. Conservative maintenance requirements
recommended in engine manufacturer warranties are one of the barriers in extending OCI's. Engine
manufaicturers claim that these strict requirements are necessary to protect themselves against:
        1)     The difficulty in defending a warranty claim made by an engine operator whose engine
may be damaged by low oil quality assurance, and
        2)     The inability for oil performance Standards and quality to keep pace with advances in
engine technology.
        In consideration for  buying an automobile or engine from a dealer, a consumer is given a
warranty.  The purpose of the warranty is to guarantee that the product is of good workmanship, has no
defects, and is similar to what was in the mind of the buyer.
        The standard warranty covers cost of all parts and labor needed to repair any item on a vehicle
that is defective in material,, workmanship or factory preparation noted during the expressed warranty
period.  Along with the warranty, each engine company recommends a maintenance schedule which
includes a recommended oil drain interval. This indicates how often the  engine operator should drain
the oil in order to comply with the warranty. Eachiconsumer must use reasonable and necessary
maintenance to comply with the warranty.
        Modifications made  to a vehicle such as extending the OCI or adding filtration units do not void
the warranty unless the  manufacturer can prove that the engine failure occurred as a result of such
modification or operator negligence. Since such negligence is difficult and expensive for the
manufacture to prove, maintenance requirements in a warranty are kept conservative. Another reason
engine manufacturers have  conservative maintenance requirements is the low assurance of oil quality
on the market. Studies performed by the SAE Oil Labeling Assessment  Program (OLAf), the military,
and engine manufacturers have concluded that there has been a 10% to 20% rate of low quality oil or
mislabeled oil on the market. Even API indicated that too often the API symbol is used to sell inferior
lubricant products. An Exxon lab technician was found guilty  of falsifying data in order to meet lubricant
requirements ^ (42).  Engine  manufacturers are concerned about oil which is placed on the market  that
does not meet certification requirements. The  low quality oil purchased by consumers for use in
vehicles may lead to engine failure. See Appendix A for a complete discussion and legal analysis  of the
implication of warranties and the Magnuson-Moss Act in the extension of oil life.
                                              16

-------
 OIL CERTIFICATION

        Certification labels are placed on the outside of the oil container to inform the consumer of the
 quality and characteristics of the oil. Along with performance categories, adequate test methods are
 established to verify performance of the oil. By certifying oil before it enters the marketplace, oil
 manufacturers can be assured that consumers will select oil based on performance characteristics and
 the type of service for which the oil is intended.
        In 1970, the Society of Automotive Engineers (SAE), American Petroleum Industry (API) and
 the American Society for Testing and Materials (ASTM) agreed to form the tripartite system and
 develop an engine oil performance and classification system that assured the minimum standard quality
 of oil.                                        ,
        The tripartite designed the API "donut seal of approval" which displayed the appropriate API
 service category, the SAE viscosity grade,  and, if Applicable, the energy conserving features of the oil.
        The API symbol is a representation by the oil marketer to the purchaser that the product
 conforms to the applicable standards and speculations for engine oils established by the automotive
 and oil industries.                             j     .......
         Improper blending or falsification of testing that results in low quality or mislabeled oil
 contribute to low consumer confidence, potential engine failure, additional costs to engine
 manufacturers in warranty claims, delay in  engine technology advances, a loss of credibility to oil
 manufacturers, and the waste disposal problem. For a complete discussion on the changes in oil
 certification, the newest developments, and the history of oil drain intervals, see Appendix B.

 INTERESTED PARTIES

        Oil quality and used oil disposal is a concern for many segments of society, specifically:

 Oil Manufacturers                             {
        The American Petroleum Institute (API) directs the certification program that licenses many of
the large oil  manufacturers, API's members, and helps set standards for oil quality.  Oil manufacturers
want to produce a product of high quality and assurance to remain competitive, but are concerned with
the expense that added testing requirements and Iregulations place on a product.

 Engine Manufacturers                         I
                                             !
       The membership  of the Society of Automotive Engineers (SAE) and the AAMA consists of the
major engine manufacturers in the United States.; This group, along with smaller engine manufacturers,
strongly encourage a high quality oil to be placed on the market in conjunction with strict certification
programs to assure that quality standards are met. Engine manufacturers are concerned with oil quality
                                             i
                                             ! 17

-------
 in establishing oil change interval recommendations and in the development of new engine technology.
 If oil quality is poor or the assurance of oil quality is low,
 then recommended oil change intervals are conservative so that the engine
 manufacturer can be assured of protection from engine failure claims. For years, engine manufacturers
 have tested the quality of lubricating oil and possible drain  intervals, but this information is in the private
 sector and difficult to find.                     ;

 Engine Operators                             '•
        Engine operators of diesel generators demand high quality oil to protect their investment in
 expensive engine equipment. Also conservative oil change intervals  require are costly to an engine
 operator due to increased oil purchase and disposal fees.  Engine operators are often wary to extend
 oil change intervals or add filtration equipment for fear of voiding the  engine warranty.

 International Lubricant Manufacturers Association (ILMA)
        ILMA represents small oil manufacturers who are concerned that increased testing  and other oil
 certification  requirements to improve oil quality may be unfair to them since larger oil manufacturers
 could absorb the expenses more easily.         :

 Consumers
        The average automobile owner is a major reason to attempt to improve oil quality and reduce
 waste oil. Do-it-your-selfers dispose of the majority of waste oil in the United States.  Automobile
 owners desire quality oil to protect their automobile, but cost is often the largest factor in oil selection.
 Increased consumer awareness of oil quality, certification, and engine warranty implications is
 necessary.  Consumers can extend their oil change intervals without engine wear, but the fear of break
 down, and voiding  of warranties has prevented this  effort.

 Government                                 •
        The Environmental Protection Agency (EPA) is concerned about the amount of waste oil that is
 improperly disposed of each year. It is an environmental threat and costly to remediate.  They are also
 concerned with oil quality as it relates to reducing dirty emissions from automobiles.  Since  the U.S.
 military purchases oil in  large amounts, they are very concerned with  oil quality. The military operates
 expensive and important equipment under harsh conditions, therefore, the need for high quality oil is a
 priority. For years they have been behind a push for strict performance standards and testing of
 marketed oil. The  U.S. military helped to fund the now defunct OLAP program in an attempt to identify
 and correct questionably labeled oil on the market.  The military wants to protect its investment in
 equipment and demands that the quality of the oil on the market is  equal to what is stated on the label
API's willingness to make improvements  in the new certification  program was motivated by concerns

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 expressed by the AMMA.  Due to the tremendous amount of oil disposed of by the military, they remain
 interested in new technology that can reduce the.amount of waste oil.
                                             I
                                             i
 HEALTH EFFECTS OF PAHS DUE TO BURNING WASTE OIL

        Waste oil contains toxic constituents at levels ranging from one hundred to ten million times
 greater than any health based standard (43). Consequently, when only a small amount of waste oil
 escapes into the environment, a substantial risk to human health and the environment is possible.
        Some of the toxic constituents found in waste oil are intentionally introduced such as
 tetrachloroethylene and 1,1,1-trichloroethane. Other toxins such as polynuclear aromatic hydrocarbons
 (PAHs) are always present. The PAH concentration in waste oils averages from less than 5 to over
 one hundred parts per million. PAHs are composed of carbon and hydrogen atoms forming clusters of
 six-membered aromatic rings. Waste oil contains a higher concentration of PAHs than most heating
 fuels, with the exception of No. 6 fuel which contains similar concentrations.
        Lab tests were conducted by Analytical Resources  on a new oil sample and used oil samples
•at 10 hours, 55 hours,  183.7 hours, 227 hours, and 208.5 hours to evaluate the potential health effects
                                             i
 from PAHs.  PAHs are a by-product created by improperly burning used oil or extending oil change
 intervals.
        Test methods used were EPA-SW 846 and included testing for Napthalene,
 2-Methylnaphthalene, Acenaphthylene, Acenaphthene, Dibenzofuran, Fluorine,  Phenanthrene,
 Anthracene, Fluoranthene, Pyrene,  Benzo(a)Anthracene, Chrysene, Benzo(b)Pyrene,
 lndeno(1,2,3-cd)Pyrene, Dibenz(a,H)Anthracene,;Benzo(ghi)Peryiene with a detection limit of 20,000
 g/Kg.  Results of each sample for each test werejbelow detection levels except for Phenanthrene.  At
 308.5 hours Phenanthrene was detected at 23,000 g/Kg and at 10 hours Phenanthrene was detected
 at 21,000 g/Kg.  These tests show no significant health hazard from PAHs  in  the used oil sampled
 resulting from oil exchange intervals or burning used oil.
                                             i 19

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                                           SECTIONS

                                   MATERIALS AND METHODS

 SITE SELECTION AND DEMOGRAPHY        '
                                             !
                                             [
        This project began with twenty diesel engines at thirteen sites throughout Alaska. Some sites
 have been successful participants while others have failed to participate in each phase of the project:
        In Phase I, extension of oil change intervals using only analysis was conducted on twenty
 diesel engines ranging from 23 to 3,000 horsepower at thirteen sites over an eleven month period. All
 engines were at remote sites. The majority of engines were stationary electric generating power plants
 in rural  locations from the Arctic through the Aleutian Islands to Southeast Alaska. In addition, an
 isolated federal hydroelectric facility volunteered road equipment. One offshore marine vessel
 participated. Participants were asked to gradually extend OCI based on laboratory data  and a field oil
 analyzer.                                     >
        In Phase II, by-pass filters were used on nine different diesel engines at four different sites.
 Data was compiled from four diesel engines at Unalaska, two diesel engines at Yakutat, two diesel
 engines at  Kiana, and one diesel engine at Hoonah.
        In Phase III, a closed-loop process was used on two engines at different sites.  Data was
 compiled from one stationary diesel engine at Unalaska and one marine diesel engine at Seward. Each
 site was informed, visited, trained, and given information about the potential benefits of the project.
 Each site was offered technical assistance, supplies, and follow up contact.
        The Alaska Health Project (AHP) was the central location for the project. All used oil samples
 were sent to AHP from the remote sites where thfey were tested by a comparative dielectric analyzer
 (CDA) before being sent to the laboratory for further testing.  All information and data was kept at AHP.
        The sites, engines, and total number of samples for each phase is described in Table 1.
                              «*,
 Selection                                     ;

        The following criteria was used in  selecting sites for this project: suitable equipment, good
 record keeping, waste oil generation, willingness to cooperate, representative engine loads, adequate
 maintenance practices, sufficient hour/mileage accumulation, engine type, cumulative hours, oil
consumption rate, oil drain interval and filter change history, periodic maintenance record, and major
 repairs.
                                              20

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TABLE 1 - Sites, Engines and Total Number of Samples
SITE

Unalaska

Yakutat

Hoonah

Kiana

Seward
(Mobile)
St. Mary's
Pilot Station
Nuaapitchuk
Tatitiek
Tooksook Bay
Bethel
Snst:isham


ENGINE

CAT 35 12-4 !
CAT 3512-5 !
CAT 3516-6 i
CAT 3516-8 :
CAT 34 12
CAT 35 12
CAT 3508 ;
CAT 35 12 'i
CAT 3406 (summery
Cummins KTA1150
(winter- only) i
Volvo MD 11C ;,

CAT3503D1 i
Cummins KTA19G2;
CAT 3412
CAT '330 4.PL '
Cummins KTA19G2'
CAT 3412 '
Deere 4239T ,
CAT 3204
CAT 3406 .
SAMPLES

• 20
20
• 24
20
16
23
8
3
9
2V

5i

10
9
4
1
0
0
0


EXTENDED

8
8
7
5
6
. 7
8
0
7
19

35










FILTERS | CLOSED

12
'12
,6
15
10
16
0
3
S

0





:




LOOP

11






16











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 Description

        Phase II and III of the project were conducted on ten diesel engines at five different sites.  Data
 was compiled from four diesel engines at Unalaska, one marine diesel engine at Seward, two diesel
 engines at Yakutat, two diesel engines at Kiana, and  one diesel engine at Hoonah.
        The following is a summary of any problems or reasons for attrition for the sites:

 Unalaska                                   '
        While there were no major problems, minor problems included: delay due to engine overhaul,
 a filter leak, a lab result with a low TBN, and difficulty assembling the closed-loop process.

 Yakutat                                    '-
                                            I
        The mechanic, who is not paid per oil change, was kept informed and interested. The OCI was
 extended to 350 hours and the filter filament changed to 500 hours. The Gulf Coast by-pass filter
 reduced soot content of 20% for the first 350 hours. This could have been extended but the CAT 3512
 engine ran into cam and soot problems due to a poor overhaul. The Purifiner by-pass filter would have
 helped more, but the metal content in an engine was  high due to an overdue overhaul. Yakutat sends
 its waste oil to the city to burn for fuel.  This saves the city disposal costs and saves the city $5,000 per
 year in fuel.  Yakutat decided not to extend oil drain intervals further for these reasons: 1) risk of
 replacing a $450,000 engine was too high since it is the only energy source for the local cannery and
 FAA emergency  runway; 2) in May 1993, both engines used in the project needed an overhaul, but
 Yakutat shut them down and purchased a CAT 3516; and 3) the engine manufacturer, CAT, informed
 Yakutat in a letter that extending the OCI might void their warranty. CAT also told them that the 3412
 would need to be overhauled at 11,000 hours instead of the 20,000 hours promised  at time of
 purchase.                                   j

 Hoonah                                     •,
       A problem arose when the CAT 3508, for which baseline data was collected, was replaced by
 the CAT 3512 to handle the winter increase  in electrical needs. The by-pass filter was previously
 installed on 3508, so Hoonah was asked to install a filter on the 3512 as well.  The operations manager
 became ill in November 1992 causing delay of filter installation.

 Kiana            •_••.,
       Problems were: 1) the mechanic quit in Obtober 1992 causing a delay; 2)  the CAT 3406 is
 used only in summer and the Cummins KTA1150 only in winter when there are more electrical needs;
3) due to fear of voiding their warranty, they only 'extended OCI a few times; and  4) it was extremely
difficult to communicate with the mechanic.      !
                                             22

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 Seward                            '   ,  •     !     .       ..
       There was a cooling system failure which; caused oil degradation and accelerated engine wear.
 Since it was a marine vessel it did not run the entire calendar year.

 Bethel
       They would not participate in the project unless we guaranteed to replace their engine, at a
 cost of approximately $500,000.00, if it was damaged.

 Snettisham                                   '
       This DOE site began the project at the beginning of the snow removal season and did not send
 any samples.  They dropped the project due to difficulties at the site and because they use mobile
 diesel engines instead of stationary engines.     ;

 TooksookBay
       Samples were sent without any information, making it impossible to record data.  They have no
 phone and due to its remote location and cultural and language differences, communication was
 unreliable.
       St. Mary's, Pilot Station, and Tatitlek had various obstacles that lead to attrition, many of which
are discussed below.

General Obstacles To Site Participation

       1)     Lack of flexibility of engine manufacturers to allow OCI extensions.
       2)     Fear of management to risk expensive and important equipment by extending OCI
              without assurance from engine manufacturer.
       3)     Low quality assurance of oil on market- 10-20% of oils on market are questionably
              labeled.
                             —<*£*              ...
       4)     Number of subject  sites and samples were cut to keep within budget after adding
              TFOUTtest.                                              -
       5)     Remoteness of Alaskan villages.
       6)     Small size of Alaskan villages  where one engine is usually the only source of energy.
       7)     Plant operators do  not know incentives for reducing waste oil.
       8)     Engine shut down due to overhaul and high hours on engine affects impact of filters.
       9)     In winter  when the temperature drops to -30 degrees Fahrenheit or lower.
       10)    Difficulty  getting JOAP Which was necessary to set condemnation limits for engines.
       11)    Cultural and language barriers of remote Alaskan villages.
       12)    Reducing pollution or waste oil is not a primary priority in some remote villages.
                                             23   .

-------
  TECHNICAL EQUIPMENT

         Many technologies exist for extending oil; life. Technologies selected for this project include oil
 drain interval extension, field monitoring, lab analysis, by-pass filtration, and a closed-loop re-blending
 process.                                     I

 Comparative Dielectric Analyzer (CDA1         i

         A portable battery-powered field CDA, the Lubrisensor model NI-2B, was selected to conduct
 field monitoring oil quality based on its cost, useability, and documentation ability in the field.
         The project used the Lubrisensor field monitor to test used oil samples.  The Lubrisensor is a
 field test instrument used to determine the deterioration in motor oil from continued use. By measuring
 any deviation of the dielectric constant between fresh and used oil, it indicates the overall condition of
 the oil and helps determine the  optimal oil change interval.
         An independent technical evaluation completed in West Germany concluded that there is a
. correlation between results obtained through lab methods and the change of the oil's dielectric constant
 measured by the Lubrisensor. The dielectric constant of an oil is the substance's ability to transfer
 electricity as compared to a vacuum.  In oil systems, this value is dependent upon the base oil plus
 additives or contaminants present.              >.
         The  study and the manufacturer recommend the Lubrisensor for the following:
         1)      Maximization of intervals between oil changes.
         2)      Early detection of mechanical failures in conjunction with preventive maintenance.
         3)      Avoidance of engine damage resulting from over used lubricants.
         4)      Reduction in the number of costly laboratory analyzed oil samples.

         Field CDA analysis requires 10 to 15 minutes including sample collection, calibration, and
 record keeping. All that is required is a sample of the new oil, a non aqueous/non halogenated solvent
 cleaner, and tissues. The portable" field oil testing units results were compared to more rigorous
 laboratory analysis. Both laboratory and field tests need to monitor engine failures and oil degradation.
 Engine failures are caused by worn bearings, rings, and other components. Worn components shed
 metal particles.  Micron sized metal particles are measured with a fluid analysis spectrometer.
 Microscopic metal particles from engine wear are counted electronically or manually with a microscope.
 Larger metal particles  are monitored with chip detectors in critical applications such as helicopter gear
 boxes. Coolant leaks accelerate component wear| by introducing salts which can be tested with the
 same equipment used to measure metal wear.  Water from cooling system failure is measured
 qualitatively by observing water  spattering from moisture contaminated oil when dripped onto a hot
 plate or  quantified with infrared  spectroscopy (IB).
                                              •  24

-------
        A lubricating oil's ability to protect an engine can be evaluated with test engines, or physical
 and chemical analyses. The only definitive test for measuring the ability of an oil to lubricate an engine
 is actual usage in a test engine followed by engine dismantlement and component inspection. This
 procedure is routinely used only for lubricant certification and costs tens of thousands of dollars per oil
 sample. Therefore, physical and chemical properties of oil are tested as a substitute. Physical oil tests
 measure viscosity at different temperatures. Chemical tests quantify additive content. A more elaborate
 and seldom used test called thin-film-oxidation-uptake, or TFOUT,  measures the performance of
 antioxidants. Buffering capacity, called TBN, can be easily measured; however, other types of additives
 can only be evaluated with in-engine performance tests. Total Base Number (TBN) of used engine oil
 measured by ASTM D664 seems to correlate with copper corrosivity, the  limit being at or below 2.
 Comparative IR spectroscopy evaluates oxidation, nitration, and contamination from fuel, carbon soot,
 and water. The procedures listed above require specialized training, equipment, and support facilities
 and are consequently performed in a laboratory dedicated to used oil analyses.
       Stationary diesel engines and one marine diesel engine were chosen to participate in this
project. A description of the engines at Unalaska are listed in Table 2.

       The Seward site engine is a diesel-fueled Volvo Penta model MD11C with a 3.05 quart capacity
oil sump, operated at 1,800 RPM which is 75% of rated maximum RPM. Fuel consumption is .50
gallons/hour. The only lubricating oil used is Chevron Delo 400, ISW040.

Filters                                        '..

       After an extensive review process based on product quality, product information, experience,
and cost, the following filter systems were chosen for use in the project:  Gulf Coast, Spinner, Purifiner,
Harvard, and Power Plus.       "**'    •          '•
                                              25

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TABLE 2 - Engine Information for Unalaska
UNIT
TYPE
SERIAL*
AR. #
OT.NO. #
GEN. SER.#
GEN. AR. #
GEN. TYPE
VOLTAGE
FUEL TIMING
KW-CONT
KW-PRIME
KW-STB
HP
RPM
WEIGHT
G.P.H.
25% GPH
KWOUT
50% GPH
KWOUT
75% GPH
KWOUT
100% GPH
KWOUT
UNIT
OIL CAPACITY

GEN. 4
3512
67Z00553
2W8869
6336
5YA0064
5N8448
SR4
48QV
86.6
675
830
900
1042
1200
22000
330
17.6
204
31.2
427.5
45.2
641
59.4
855
GEN. 4
81

GEN. 5
I 3512
I 67Z00498
\ 1W4217
! 3894
89649
CAT#6P61475
i A22250000
i 4160V
• 87.64
; 500
: 620
650
830
! 1200
i 22000
! 330
14.91
155
I
23.3
; 310
33.56
; 465
i 42.88
; 620
GEN. 5
81
26
GEN. 6
3516
73Z00272
2W8404
-
6SA649
7C2628
SR4
4160V
87.1
1200
1420
1600
1902
1800
27000
400
31.7
355
52
710
74.5
1065
98.7
1420
GEN. 6
106

GEN. 8
3516
73Z00272 -
2W8871
6377
96420
CAT#6P6-3000
A24736000
4160V
86.9
1180
1130
1200
1615
1200
27000
330
18.4
282
; 37.8
565
56.8
847
75.67
JJ_30
GEN. 8
219
:

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 ANALYTICAL METHODS
 Stage and
 Phase

 Stage 1
                                           Experimental Design
                         Description
Sampling
 Diagnostic
 Screening

 Stage 2

 Phase I
 Baseline
 Phase H
 Method
                         Check for abnormal engine conditions.
                         Oil changed at manufacturer's recommended
                         intervals and oil interval extended without
                         by—pass filters.

                         Installation of a by-pass filter and extension of oil
                         change interval.           ,
                         Installation of technology to recycle waste oil with
                         diesel fuel and extension of oil change interval.
One sample
at oil change
                                                                                 One sample
                                                                                 at oil change
                                                                                 One sample
                                                                                 at oil change
Phase ffl                 	aj	j	„__ „	_
                                                                                Fuel analysis

Diagnostic Screening        -                      ;

        A diagnostic screening was used to determine if the potential candidate had any problems which would

complicate the study such as a coolant leak or excessive engine wear. Approximately twice as many engines
needed were screened to assure that enough were available for the study.

        In one case, diagnostic screening revealed an engine with potentially serious problems unknown to the
owner/operator.  Useful information was collected. The portable oil analyzer clearly identified a lubricant

problem during the on site inspection. Laboratory analysis both confirmed the lubricant problem and suggested
potential sources.                                  ;
                                                                                                     as
Phase I: Baseline                              .-   - !

        Engines are run at normal and extended oil drain intervals without added filtration.


Phase II:  Methods                                j

        By-pass filters were added to the engines and oil drain intervals were extended.  Different brands of
filters were  rotated on each engine.


Phase III: Blending

        The Power Plus Smart Tank was used to recycle waste oil on engine #6 at Unalaska. The closed-loop
                                                   27

-------
 process was also used on the Volvo MD11C marine diesel engine at Seward.

 Field Testing CDA                               ;

         Numerous field tests were evaluated.  The tests evaluate solids, viscosity, TEN, and the oil's dielectric
 constant. Suspended solids can be qualitatively evaluated by spotting oil on blotted paper and quantitatively
 measured by solvent extraction.  Viscosity measurements are occasionally done with calibrated glass tubes or
 less frequently with semi permeable membranes. TEN can be field tested with test kits.  A lightweight, kg,
 battery powered electronic  instrument compares the dielectric constant of new to used oil as an indicator of both
 oxidation by-products and contamination from water or metals.  The sensor is a capacitance bridge operating at a
 frequency of 5 megahertz (44). This instrument will be referred to as comparative dielectric analyzer (CDA).
         A portable battery-powered field CDA was selected based on cost, use, and documentation.  Field CDA
 analysis requires  10 to 15 minutes including sample collection, calibration, and record keeping, and can be done
 on site.  The field unit  selected was the Lubrisensor model NI-2B.  The only additional equipment required was
 a sample of the new oil, a non-aqueous/non halogenated solvent cleaner, and tissues.  One out of twelve units
 needed a minor repair during the course of this study]
        Each oil sample is tested by a Lubrisensor at each site by the engine operator and at AHP before being
 sent to the lab for analysis. The project compared the Lubrisensor readings with lab analysis to discover whether
 the Lubrisensor was a good indicator for contamination in the oil.  AHP ordered ten lubrisensors from MRO
 Sales in September 1992 for a cost of $6,930  and borrowed two from the Alaska Department of Environmental
 Conservation.

 Laboratory Analysis

        A national search was conducted and a laboratory  selected based on quality assurance manuals,
 experience, and commercial availability. The  laboratory was monitored with a 20% frequency  of blanks, spikes.
 and standards.
        The samples taken in this project have been sent to the  Analysts Incorporated Laboratory in Oakland,
 California. Analysts Inc. is an independent oil and fuel testing laboratory, founded in 1960, specializing in
 controlled maintenance and correct oil drain interval programs through the analyses of used lubricating oil.
Through  spectrochemical analysis and related physical property tests, they quickly determine the condition of oil
                                                 i
 and fuels, as well as, the condition of the engine. Their oil analysis program follows six steps:
        1)      Identification forms;     2)       Collect samples;
        3)      Label samples;           4)       Send samples;
        5)      Lab reports              6)       Feedback on computerized                summary report-.
        For this project, Analysts test each sample of used oil for twenty-one metals and the total base number
at approximately $16.00 per used oil sample.  It analyzes each oil sample for depletion of additives, and liquid
                                                 '28

-------
 and solid contamination. Lab analysis can be a more efficient, inexpensive, and productive means of
 determining oil contamination or engine wear than conducting periodic maintenance and overhauls.
         Equipment manufacturers, oil companies, engine operators, supervisors, plant engineers, service
 managers, and filter suppliers have all benefited from lab analysis. It has also been utilized by the military,
 marine fleets, truck fleets, pipelines, and other users of industrial equipment.
         In a study completed in 1990, a'used oil sample and a coolant-spiked sample, were sent to seven labs
 throughout the United States to  compare the results of the analysis.  The study rated Analysts Incorporated of
 Oakland, California as scoring well on most parts of the test, including detection of the coolant spiked oil
 sample. See Table 3.                   i          '      -
                                                 i
 MAINTENANCE                     '•          [

         In addition to oil analyses, a uniform maintenance log will be kept on each piece of equipment,
 including information such as; oil added, repairs, hours of operation, load, changes in operating conditions, fuel
 consumption, and maintenance.

 TECHNOLOGY                                 ;

         A Quality Assurance Plan (QAP), prepared at the beginning of this study (AHP 1991) described the
 detailed approach and scientific rationale used to extend oil life.
         The extension of OCI's, by-pass filtration units and a closed-loop process were used,on this project to
 reduce waste oil.                                 ;
                                                - * -                            -

 Extension of Oil Drain Interval                    ',         '              '

         Phase I, baseline, selected engines and determined the baseline trend of oil degradation during the cycle
 of a normal oil change interval.  This phase determined if the oil change interval can be extended based on
 analysis alone.                   "*~              ;

 By-Pass Filters

        The project used filtration as a means to extend oil life and reduce the amount of waste oil in remote
areas of Alaska. The purpose of filtration is to remove abrasive particles, and fuel product's from lubricating oil.
As the demands on engines have increased, the need for finer filtration has become more important.
        Oil is commonly filtered between the oil pump and the engine by diverting  100% of the oil through a
"full flow" filter able to remove large particles (greater than 20 'microns). Full-flow filters, which are standard
                                                   29

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TABLE 3 - Lab Selection Process
LAB NAME
SCORE .
Cost QA Data Total
Mgt.

Prof. Services Ind.
SW Research Inst.
Analysts Inc.
Spectra Petroleum
Oregon Analytical
Titan Labs
NC Machinery
Spectro Metrics
Spectro Metrics
/2G
20
8
20
20
0
20
20
20
19
760
'50
60
60
-
40
5 '
20
15
20
/20
18
18
I
18
•'-
5
I
*°
10
10
20
7100
88
,S<5
98
-
45
35
50
45
59
. . COMMENTS

-
Good QA, round robin '.ised oil
testing program, long term
experience in used oils, modem link-
Very good QA, Fed-Ex data, broad
based automotive research
capabilities
Excellent QA, long term experience
in used oils, JOAP participation,
LOAMs database
Price package only
EPA CLP program, very good QA
for drinking water/RCRA analysis,
site audit, little experience in used
engine oil analysis and interpretation
One check sample per 50 analysis,
QA too brief
CAT used oil verification samples
good but QA too brief
Data management Spec Net, QA
okay but toe brief
Excellent data base management
(ROAST), quarterly participation in
used oil cooperative lab evaluation,
brief QA description
            30

-------
 in every engine, treat the full flow of oil as it flows from the pump to the engine components.  The purpose of a
 full-flow filter is to screen out large, abrasive particles which could damage the engine, but not to clean oil or
 control engine wear.  The problem with using only a full-flow filter is that  they are inefficient  at removing  -
 liquid materials (such-as water, unburned fuel, or acids) and small metal contaminants below 20um from the oil.
 Used lube oil contains particles smaller than Sum which can cause engine wear. Particles in the 2 - 20 micron
                                                  i
 size can cause as much wear on piston rings, main and rod bearings as larger particles; therefore, some -
 equipment manufacturers use by-pass filters to remove particles in the range below 20 microns. By-pass filters
 are given their name because a portion of the oil flow is intercepted and "passes by" the main oil flow. This
 portion is about 10% of the main flow.              j
         During Phase n, the project used by-pass filters to reduce waste oil on diesel engines in Alaska. They
 filter finer particles than full-flow filters without restricting the ability of lubricants to reach the engine
 components.                                      i
         Recent studies by the U.S. Army indicate that by-pass filters lessen the concentration of ferromagnetic
 wear particles in diesel trucks without any adverse effects on calcium, magnesium, silicon, or zinc lubricant
 additives (43). Accelerated wear tests using by-pass filters found that normal engine  wear was  reduced in
 proportion to the filter micron rating (14) with a correlation coefficient of 0.996 (12).  The concentration of wear
 metals decreased up to 80% with increased filtration. '• However, used oil analysis from field operated vehicles
 will not be as clearly correlated due to decreased wear rates during normal  oil  change intervals.
        A by-pass filter is secondary to the full-flow filter. The primary requirement is a direct attempt to
 reduce long term wear by lowering the gross contamination level in the system.
        After the selection review process, the project selected the following by-pass filters:
         1)      Gulf Coast                     3)       Purifiner
        2)      Spinner                 4)  .    Harvard
        Phase n  methods used oil analysis to monitor the effects of several by-pass  filters on oil degradation.
 The analytical laboratory and project manager recommended an increase or decrease of oil change intervals
 based on the best information available from engine manufacturers and literature, but the actual  decision was
 made by the operator.  Regardless of the decision, the quality assurance plan guaranteed that the data collected
 was  of a known quality and useful in the statistical analysis.
        Bypass filters are popular because they can be added to equipment with simple modifications.
 Recently, several manufacturers such as Cummins and AC Rochester improved  standard equipment filters to the
 point that a stand alone by-pass filter may not be necessary.  In using by-pass filters,  the oil is removed from
 the lubricating system, passed through the by-pass filter where some of the insoluble contamination is removed,
 then returned to the system.  It is  a continuous process which is able to filter particles  down to <1 micron,
eliminate sulfi}ric acid buildup, and absorb water by diverting the oil by the pump to a second filter system and
returning it to  the sump.  For optimum filtration, it is important to change the filter element when clogged with
particles and add fresh oil, then hot drain and crush the old element for disposal.
                                                   31

-------
Closed-Loop Process                  <

        Phase HI consisted of recycling used oil and blending it with unused diesel fuel.  Based on cost and
effectiveness, a closed-loop filter was selected to improve the quality of the oil which was removed from
engines.  The filtered oil was blended for use in the diesel engine or as heating fuel.
        After receiving brochures, information packets, and prices from various distributors, AHP reviewed the
information and discussed the options with the engine,operators.  Based on all of the factors, the Power Plus
Smart Tank was chosen for the project. Power Plus ED3500S costs approximately $1600 and may allow an
energy tax credit up to 20%.  The Seward facility constructed its own blending system for the Volvo MD11C.
        Lubricating oil is removed at the rate of 1.3 ounces/engine-hour and blended in the fuel tank at 2%
oil:fuel. This removal rate uses the same amount of oil as changing the oil once every 150 hours.
        Sampling began at every 25  hours and upon good lab analysis, the removal rate was reduced by 50% to
.65 ounces/hr, and blended at 1% oil:fuel.  This removal rate uses the same amount of oil as changing the oil
once every 300 hours.                             ;
        A closed—loop process is a process in which the oil is removed from the engine at a set rate and
blended, in the fuel tank at a varied percentage of oil to fuel blend. While the amount of oil used in the engine
can vary, used oil is recycled back into the system.   ;
        The Power Plus claims to be the most complete engine lubricating control system for engines and
ensures optimal operating conditions and extended engine life,  while reducing maintenance costs and providing
continuous protection.                             :    .
        It can be programmed as an  automatic oil change system and replace removed oil with fresh oil.  It can
monitor and maintain the crankcase oil level and automatically change engine lube oil on a continual basis by
removing  a small amount of oil from crankcase and replacing it with fresh oil.

DATA EVALUATION
                                                -)
        The potential of extending oil life  by ultrafiltration and analysis was measured by the condition of the
oil, the ability to extend the oil drain  interval, and the lability to reduce the measured amount of waste oil each
site must dispose. _                           •     ,                                     .
        During the project, the methods or independent variables were oil analysis and filtration systems.  Oil
change intervals and cost were the dependent variables.                                   ,
                                                                                     . !
        Used oil samples of approximately one oz.  were taken from the diesel engines as often as every two
days.  Each sample was tested for deviations  in the dielectric constant by a Lubrisensor field monitor. This test
was conducted by the engine operator on site as well as at the AHP office by the project manager.  Next, the
sample was sent to the lab to analyze the physical and  chemical properties of the oil.  The lab results were sent
                                                 i        ,                             ,
to AHP for review and then forwarded to the engine operator.  A quality control sample was sent to the lab v/ith
every fifth used oil sample.           :
                                                 •32

-------
                                             . SECTION 4
                                                RESULTS
        The results of the data accumulated were plotted on graphs and are summarized below.
        Figure 3 shows the CDA readings against engine hours on oil for each of the by-pass filters on engine
 No. 4.  A higher CDA reading can be an indication of possible oil contamination.  The control plot is an
 extension of the oil drain interval without a by-pass filter.  On this engine, the control samples had lower CDA
 readings than samples from by-pass filters and were extended to a greater number of hours. This figure shows
 that the oil itself can be extended to at least 1000 hours without any CDA readings indicating oil contamination.
 The oil samples with by-pass filters extended oil drain intervals over 600 hours without any CDA readings
 indicating oil contamination.                       j
        Figure 4 shows the average oil life for an engine with a 105 gallon sump capacity at different OCI
 settings. Any engine following these recommendations should run their own control tests and monitor the engine
 and oil for any contamination.
        Figure 5 shows the CDA readings against engine hours on oil for each of the by-pass filters on engine
 No. 5.  On this engine  the control samples had lower CDA readings than samples from using the Spinner Filter.
 The samples using the Purifiner filter had a lower CDA reading than the Spinner or control samples.  All
 samples on this engine were able to extend their OCI:to over 800 hours without any CDA readings indicating oil
 contamination.
                                                 !                      -             -         -
        Figure 6 is the same as Figure 5 except that it shows that all the samples were within 95% confidence.
        Figure 7 shows the average oil life for engine No. 6 with different OCI settings. Any engine following
 these  recommendations should run their own control tests and monitor the engine and oil for any contamination.
        Figure 8 plots  the engine hours against CD A1 readings for the first and last five used oil control samples
 from engine No. 6 within a 95% confidence level. The control plot is an extension of the oil drain interval
 without a by-pass filter. As the hours on the engine and the OCI increased, so did the CDA readings.
        Figure 9 is the same as Figure 8 except that it plots the complete range of data points.
        .Figure 10 shows the CDA readings against engine hours on oil for each of the by-pass filters on engine
No. 6. On this engine, the Purifiner filter had slightly lower CDA readings than the control samples and the
samples using other filters.  All sets of samples exceeded 600 hours on oil, but the Harvard and control samples
CDA  readings indicated possible oil contamination.
        Figure 11  shows the CDA readings against the engine hours for the used oil control samples and the
Purifiner used oil samples on engine No. 6.  The control plot is an extension  of oil  drain interval without a
by-pass filter. This figure plots the complete range of data points. Both set of samples extended OCI over 800
hours, but had some CDA readings which indicate possible oil contamination.
                                                  33

-------
         Figure 12 shows the CDA readings against the engine hours for the used oil control samples and the
 Gulf Coast used oil samples on engine No. 8. This figure shows that on mis engine the control samples had
 lower CDA readings than the Gulf Coast samples, but that both sets of used oil samples were able to be
 extended to over 1200 hours without any CDA readings indicating oil contamination.
         Figure 13 is the same as Figure 12 except it plots the complete range of data points.
         Figure 14 plots the CDA and TEN readings against engine hours for the control samples on the >Volvo
 MD11C engine. This figure shows a direct relationship between CDA and TEN readings within a 95%
 confidence  level on this engine. This enables the engine operator to predict within a 95% confidence level the
 TEN level given the engine hours and a CDA reading^ This aids the operator because lab analyses take time
 and are costly.
         Figure 15 plots the TEN levels against the hours on oil for the control used oil samples  and the 1.5%
 oil:fuel blend samples on the Volvo MD11C engine within a 95% confidence level.  The control  plot is an
 extension of oil drain interval without a by-pass filter.  A lower TEN level is an indication of possible oil
 contamination. This figure shows that the blend samples were able to hold a higher TEN level over extended.
 hours ou the oil causing the engine less probability of oil contamination.
                                                  i
         Figure 16 shows the CDA readings against the engine hours for the control used oil samples and the
 1.5% oil:fuel blend samples on the Volvo MD11C engine within a 95% confidence level. The blend is a
 closed-loop process where used oil is blended with incoming fuel.  This figure  shows lower CDA readings than
 the control samples.  The blend samples were extended to over 200 hours without CDA readings  indicating any
 oil contamination.  The control samples were able to extend the oil to over 350 hours, but had CDA readings
 indicating possible oil contamination.
        Figure 17  is the same as Figure 14 except it plots the complete range of data points and  extends the data
 to the point where  TEN level would reach zero on the Volvo MD11C engine. This figure shows a direct
 relationship  between CDA and TEN readings within a 95% confidence level on this engine extended to over
 1000 hours. This enables the engine operator to  predict within a 95% confidence level  the TEN level given die
 engine hours and a CDA reading.  This aids the operator because lab analyses take time and are  costly.
        Data from the Unalaska and Seward engines were used for final graphs. Data from  the Hoonah and
 Yakutat sites was not as reliable. In Hoonah, used oil samples were taken from a CAT 3508 diesel engine for
baseline data, but then for winter Hoonah began to use a CAT 3512. The 3508 had no  by-pass filter and was
baseline data, but the CAT 3512 had a by-pass filter but no baseline data.
                                                  34

-------
             FIGURE 3 - Bypass Filter vs. Control Samples CAT 3512, Engine No. 4
     3.0
     2.5
C   2.0
 CL>
O
     1.5
      .0
    0.5
        0
                                                  Harvard
                                           • Guif Coast
                                              Spinner
                200
400    :   600       800



    Hours  on  Oil
                                                              control
1 000      120C
                                    35

-------
             FIGURE 4 - Average OU Life for Different Settings 105 g Oil Sump
   600
           Average  Oil Life; for  Different Settings
                          105 g  Oil Sump
   500
   400 L
-j


O
                  n	r
                                            OCI set for 1,000. hr
                                                 set for 750 hr  -
                                                CI set for 500 hr
           100   200   500   400 \  500   600

                             Enaine Hours
700 .  800   900  ' 1 COO
                                36

-------
             FIGURE 5 - Bypass Filter vs. Control Samples CAT 3512, Engine No. 5
     2.5
     2.0
 CO
 CD
Q
O
     1.5
     1.0
                                                     . Spinner
                                             control
                                                              Purl finer
    0.5
       0
200   -  400     ' 600      800


              Hours  on Oil
                                                        1000
1 200
                                    37

-------
          FIGURE 6 - Bypass Filter vs. Control Samples CAT 3512 Engine No. 5 with

                            Confidence Level
     2.5
     2.0
 00
 CO
 V   1.5
Q
O
      .0
    0.5
        0
                                                         Spinner
                                            95% confidence
                                                                control
                                                                  Purifiner
200 ,   .   400  ;     600       800.

               Hours  on  Oil
000
                                    38

-------
 FIGURE 7 - Average Oil Life for Different Oil Change Interval (OCI) Settings CAT 3516, Engine No. 6
    1000
     900  -
     800  -
tlO
CO
^H
0)
                                                     OCI set for 1,000 tir
                                                  OCI set for 750  hr
                                                       OCI set for 500 hr
0          1000
                                2000        3000

                                Engine Hours
4000         5000
                                   ^39

-------
        FIGURE 8 - Control Sample Variation with Time CAT 3516, Engine No. 6
     4.0
     3.5
     3.0
     2.5
Ctf
0)

-------
           FIGURE 9 - Control Sample Variation with Time CAT 3516, Engine No. 6
 Ctf
 CD
Q
O
      4.0
      3.5
     3.0
     2.5
     2.0
     1.5
     1.0
                 last five oil change  intervals
  a
                                                o  first five oil change intervals
     0.5
        0
200
 400           600


Hours on  Oil
                                                               300
                                                       1000
                                     '41

-------
          FIGURE 10 - Bypass Fflter vs. Control Samples CAT 3516, Engine No. 6
-a
 cd
 CD
Q
O
     4.0
     3.5
     3.0
     2.5
     2.0
     1.5
     1.0
                                            Harvard
     0.5
        0         200
                                                      control
                                                           Purifiner
,400   i     600        800


   Hours  on  Oil
1000       l200
                                    42

-------
 FIGURE 11 - Bypass Filter vs. Control Samples CAT 3516, Engine No. 6  With Data
 4.0
0.5
                           Hours  on  Oil
                              43

-------
          FIGURE 12 - Bypass FHter vs. Control Samples CAT 3516, Engine No. 8
     3.(
     2.5
     2.0
 fcfl
 CO
 d)
Q
O
1.5
     1.0
     0.5 L.
     0.0
                i        r
                                                          Gulf Coast
                                                               control
                         j	i	i	i	i	L
        0      200     400
                           600     800    1000

                          Hours on Oil
1 200    1400
                                  44

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         FIGURE 13 - Bypass EUter vs. Control Samples CAT 3516, Engine No. 8 With Data
     3..0
     2.5  -
     2.0  -
 GO
 fl
• -—1
T3
 03
        0      200     400     600     800     1000    1200    1400

                               Hours on  Oil
                                 45

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                  FIGURE 14 - Control Samples Engine, Volvo MD11C
                                                                      7.0
 00
 ioO
 g

T3
 cd
 0)
ffi

<
Q
O
    0.5
   150     200


Hours  on Oil
                                                  250
300
350
                                   46

-------
            FIGURE 15 - 1.5% Oil: Fuel Blend Engine, Volvo MD11C
                                                                 7.0
         i	r
                                                                 6.5
                                        blend
0        50
                  J	L
100   ,   150      200      250

     • Hours  on Oil
                                                6.0
                                                                 5.5  CD
                                                                 5.0
                                                                     GO
                                                                     CD
                                                                     *~!
                                                                     i—i
                                                                     cr
                                                       control
                                                               -I 4.0
                                               3.5
300      350

-------
           FIGURE 16 - 1.5% OH: Fuel Blend Engine, Volvo MD11C
 3.0
0.5
           50      100    -150     200      250     300



                      :   Hours on  Oil
                             48

-------
               FIGURE 17 - Control Extended to Zero TEN Engine, Volvo MD11C
 00
 ClO
 (0
 CD
Q
O
                                                                    o
       0    200   400   600.   800  |1000  1200  1400  1600  1800  2000


                             Hours  on Oil
                                   49

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                                               SECTION 5
                                              DISCUSSION
         This evaluation shows that there is a feasible potential for reduction of used oil.  A diesel engine
 operator could potentially reduce used oil waste volume by many gallons per year by extension of OCIs,
 ultrafiltration, or re-blending.  These practices would,save the operator money, require less downtime, and
 reduce disposal liabilities. All three techniques are easy to implement, and are inexpensive by theory that any
 process that saves money eventually pays for itself,   i
         Laboratory data was analyzed for indications of oil degradation such as changes in viscosity, decreases
 of Total Base Number (TEN), soot, oxidation, nitration, and suspended solids formation. None of the parameters
 listed, except TEN, limited oil life extension. In several samples, TEN values reached  zero, indicating, the oil
 needed changing. Without buffering capacity (TEN),  non-neutralized sulfur from combustion by-products
 reduces the pH, thus causing accelerated engine wear.
         This project chose to analyze Total Base Number (TEN) and comparative dielectric analyzer (CDA)
 data as the best indicators of oil quality.             i
         CDA is a portable battery powered field instrument used to determine the deterioration in motor oil
 from continued use.  By measuring any deviation of the dielectric constant between fresh and used oil, it
 indicates the  overall condition of the oil and helps to  determine optimal oil change intervals, as well  as
 signifying the possible danger of oil contamination.
        TBN is the quantity of hydrochloric acid, expressed in terms of the equivalent number of milligrams of
 potassium hydroxide which is required to neutralize all the basic constituents present in one gram of  the sample
 of petroleum  products or lubricants. The Total Base Number indicates relative changes that occur in an oil,
 regardless of color or other properties  of the oil.      ;
        Although the lab analyzed each used oil sample for twenty-one metals, TBN was the  one constant
 indicator on lab results of oil degradation  . Low TBN '• was the reason for each abnormal lab result. See Table 4.
        Due  to the cost and time involved in waiting for lab results on the quality of a used oil sample, this
 project chose to collect CDA data.  A  CDA reading of a used oil sample is not a definitive answer of oil quality.
 but gives a reading that can alert an operator of any potential oil contamination.  A high reading on the CDA
 acts as a, "red flag" to the operator and immediately allows the operator to  make an engine adjustment, change
 the oil, or send the sample to the lab. This can protect an operator from; risking  dangerous engine component
 wear, unnecessary downtime, and expensive lab tests,  i
        A plot of CDA response and TEN versus hours on oil revealed an inverse relationship, as can be seen
 in Figure 17.  TBN values were extrapolated to zero, the minimum acceptable value, to estimate maximum OCI
The boxed areas on the lower left of each graph indicate CDA readings at  depleted TBN. The more rapid
                                                  : 50

-------
 depletion of TEN in engine #4 compared to the same model engine #5 is a function of increased power demand
 met by higher RPM and increased fuel consumption. The more rapid depletion of TEN and increased CDA trend
 of engine #6 compared to the same model engine #8 is a function of decreased oil sump capacity. The number of
 CDA measurements, TEN analyses, and OCI for Engine 6 are listed below.
 Number of Samples Analyzed
Engine #
4 '
5
6
8
CDA
137
128
92
114
TBN
8
8
6
5
and OCI




FIELD DATA COMPARED TO LABORATORY DATA: ABNORMAL ENGINE WEAR

        One marine diesel engine (Volvo MD11C rated 23 hp) extended the OCI six fold. At midpoint with 190
hours on the oil, (manufacturers recommended OCI  is 50 hours) a cooling system failure caused oil degradation
and accelerated engine wear. Water contamination from the catastrophic failure of a seal was apparent from both
the CDA response and laboratory analysis (Figure 18,: top). The high CDA reading in combination with a visible
loss of coolant from the heat exchanger prompted repair of the seal. However, the oil was not changed because
CDA readings returned to normal. The decision to not change the oil after water seal failure might have been
disastrous.  This was an operators decision that goes against all training manuals, and is not recommended as
part of the possible oil savings that this study is working with.
        Oil contamination by water and coolant caused elevated levels of wear metals and salts. Aluminum was
the wear metal with the best quality control data and was plotted with CDA  field readings versus hours on oil
(Figure 18 bottom). Other wear metals showed similar correlation, although with more variation from sample to
sample.

NORMAL OIL DEGRADATION                  ;

        Criteria for determining OCI based on used oil analyses is difficult to get for four reasons. First, engine
manufacturers' data showing the safety factors built  into OCI are not public information. The safety factors, in
part, take into account the fact that lubricating oil  certification programs are inadequate and tests have been
falsified (42). Second a joint project of the U.S. Army, Motor Vehicle Manufacturers Association, and American
Petroleum Institute found that approximately 10%  of the lubricating oil on the market did not meet certification
requirements (46).  A revised oil labeling assessment program is currently attempting to introduce quality control
into the voluntary oil certification industry. The third problem with data interpretation is the use of proprietary
wear metal trend algorithms, created by. commercial  laboratories for advising clients on oil and engine condition

-------
 Limited public information regarding the interpretation of used oil analyses is available from the Department of
 Defense Joint Oil Analysis Program Manual including information from studying  Air Force, Navy, and Army
 engines and transmissions (46).  Some of the engines referenced are commercially available. Finally, many
 engine operators send used'bil samples to a lubricant supplier who tests for excessive engine wear. Lubricant
 suppliers may have a conflict-of-interest in recommending increased OCIs thus lowering sales. The manufacturer
 of the CDA suggests a relative value of 4 as a safe rejection threshold for petroleum based multi-viscosity oils
 and recommends correlation with laboratory analyses.'

 ABNORMAL ENGINE WEAR

        In the marine diesel engine, water  was likely contaminating oil prior to seal failure, although neither the
 CDA response nor laboratory analysis detected water except at the time of failure. Water is difficult to  detect,
 probably because of evaporation caused by  normal engine operating conditions. However, corrosive effects were
 apparent from laboratory analysis. The lab first reported signs of contamination (40 hours on oil), then  abnormal
 conditions (55 hours), followed by critical (190 hours) concentrations of six wear metals followed by a gradual
 decline because of old oil dilution with new replenishing oil. The accumulation of wear metals did not  trigger an
 exceptional rise in  the CDA response. Consequently, GDA response cannot be  solely relied upon to indicate
 critical levels of wear metals in similar incidents.
        In the engines studied, TEN depletion was the only observed indication of oil degradation. If the oil had
 a higher initial TEN, eventually other degradation mechanisms  may be evident with IR tests. However, the
 absence of used oil traceable standards for IR analyses leaves precision and accuracy unknown.
        For the four engines at Unalaska there were 12 abnormal lab results due to low TEN and two  lab tests
 which recommended to monitor TEN.  See Table 4  Engine #6 had five low TEN readings.  On three of them
 there  was no by-pass filter due to required  work on the engine. The operator had to change injectors, increase
kw output, and replace a rear seal.  The other two low TEN'readings on engine #6 were due to problems in
connecting the Power Plus smart tank.
        Engine #5 had one abnormal lab result due to normal oil degradation,  there were 869 hours on the oil,
with the Spinner by-pass filter in place at that time.  Due to the low TEN reading the  lab recommended the
operator increase monitoring for TEN.  The TEN reading was from a sample taken directly before the beginning
of a top end overhaul of engine #5.
        Engine #4 had two abnormal lab results due to a low TEN reading and one lab result recommending  the
operator to monitor TEN. One low TEN reading was when the Harvard by-pass filter was running and was due
to normal oil degradation.  There  were 831  hours on the oil.  The other low TEN reading was from a sample
taken  when the engine was ready  for a major overhaul and some fuel was in the oil sample.  The monitor TEN
reading was taken when the Gulf  Coast filter was running and the engine needed CAP gaskets at the time.
                                                 .52

-------
           FIGURE 18 - Total Base Numbers and CDA Response Compared to Hours on Ofl


         Engine No. 4  CAT 3512     ;        Engine No.  5   CAT.3512

     OCI=500hr  sump=83g  :85.5kl   :    OCI=500hr  sump=83g  630kW
 SO  3 -
Q
O
                                          4 r~
                                          3 -
                                      T3
                                       Cd
                                       V
'&
     U.M I I I I I I I I IJL1 I I I 1 i I n l\l I I t I I I i	 I | | | , , , , . ,
     0     500   1000  1500   2000  250Q

            Hours on Oil



        Engine No. 6  CAT 3516

  OCI=500hr   sump = 105g  1585k₯
          500   1000   1500   2000   2500


             Hours  on Oil
            Engine No. 8  CAT 3516

           = 1000hr sump=220g  1200kW
4


C
•b
c\3


2

O
O

I


	
f- \ ' „ ;• ' T~
" \ " /
- 	 __.y 	 ,.a,.iv
.CDA-,3.,4 £
— • \ a CDTJ • - ,_
\ oa /oa
\ 'a
a o-' ._
•* A
a ab Wl
oar*
OTmcna \ 	
a/ oo \
•• CD .-O3 \
o o .a . \
/ o *\ . ••
aaoa \ _
— ocjoa \
CfiDQ \
S° A -TBN=0
«ra \ '•
\ '
' " T ' ' ' T 1 1 n t • T U j i ' i n • 1 1 r • i [ r i im t n !.,,..'. .>.
"7 A
? / - **•
e -j .
o
5 £ • 00 3
CO ' S
4 CJ ,
w ! J;

^ 2: * ^

2 3 i 0

ra
I • 1
A

r '\ ' ' ' '
• ' \
- '\. ^
\
rn -5 \ '° °° •"'"' ~* i
~ CDA=-2.3 	 	 \ 	 S. 	 - 	 •"'"

a\s o x"' •

a ..- a a \ i
•* RC* S' DO \ i
a c co' oa oa \ ;
aaaoaoffuataic ocna ' \ -'TBN^^O
— ra cc...a niao zxn \ ; -
D .-• '" \ =
j oi<3 use a a \ .
,..'* a csr a o- o \ |
•_.l 1 -.1 I ^ i 1 ! > i • i t", i ! > 1 ; i • r i i i i t 1 u i A i i i i 1 i i i , « .
         500   1000   1500  2000   2500
            Hours on. Oil
                                                      500
                                                                1500  2000
                   Hours on Oil
                 "OCI" means oil change interval measured in hours

                    "sump" means capacity of oil sump in gallons

                          "kW means 80% of  rated power
  Total Base Numbers (Filled Circles) And CDA Response (Hollow Squaies) Compared To Houis On Oil.

-------
 FIGURE 19 - Quality Control Samples for Total Base Number
'A
CO
s
=5  3
a

-------
              FIGURE 20 - Quality Control Samples for Blanks
14
12
10
 8
 4
 2
 0
 method detection limit
_l	I	I	!	i   i   i
J	L
                                                   _L	I	L
     FE CR  Nl AL PB CU SN AG- Tl SI  B NA MO P  ZN CA BA MG  V

                             Element
                              55

-------
        Engine #8 had four abnormal lab results due to low TBN readings.  The Gulf Coast Filter was running
during all four samples.  They were all due to normal oil degradation with hours on the oil of ,918 hours, 966
hours, 1038 hours, and 1181 hours.
        Engine #4 had two high readings of copper, one sample with the Harvard filter running and one sample
with the Gulf Coast filter running. Engine #8  had one lab result with a high reading of copper.  The Gulf Coast
filter was  running during that sample.
        Other engines studied were not included in these calculations for several reasons. Operators of road
equipment volunteered by a federal facility previously changed oil every 100 hours or monthly, whichever came
first. Since using the CDA for nearly a year they have yet to change their oil. A privately owned southwest
Alaska power plant with 3,000 hp EMD engines never changes their oil because the high oil consumption rate
means the "oil always changes itself." Limited use of the CDA confirmed their OCI. In western Alaska, a utility
serving the greatest land area of any utility cooperative  in the world was unwilling to ignore manufacturers'
recommendations for OCI, as was another cooperative utility in southeast Alaska.

ECONOMIC EVALUATION
        Source reduction savings were calculated by extrapolating TBN depletion rates to zero and comparing
the potential for increased OCIs with manufacturers OCI recommendations. Based on a 5,000 hour per year
operational period, the potential source reduction for each engine is tabulated below.

                                     Source Reduction Opportunities
ENGINE
NO.
4
5
6
8
OCI in Hours
Initial Final
500
500
500
1,000
1,200
2,300
830
1,750
ORIGINAL REDUCTION
Gallons per Year
830-530 =300 gal.
830 - 650 = 180 gal.
1,050-430 =620 gal.
1,100-470 =630 gal.
% SOURCE
REDUCTION
64
78
41
43
                                                  56

-------
         TABLE 4 - Abnormal Lab Results due to a Low TBN from Unalaska Engines
USED OIL
SAMPLE*
1
2
3
4
5
6
7
3
9
10
11
12
13
14
ENGINE*
6
6
6
6
6
5
5
4
4
4
8
8
8
8 ;
HOURS ON ODL
'566
576
: 365
559
; 422
• 869
618
831
' 644 •
: 724
1038
1 1181
918
' 966
CDA READING
3.0
3.9
3.6
3.4
3.6
2.6
2.1
2.9
2.8
3.0
2.6
2.9
2.6
2.6
FILTER
Control
Control
Control
Control
Control
Spinner
Spinner
Harvard
Gulf Coast
Gulf Coast
Gulf Coast
Gulf Coast
Gulf Coast
Gulf Coast
The row listing the number of samples-only includes those samples actually sent to the lab for analysis and aot the
samples tested by the CDA.'
                                           57

-------
 Costs

         Operating costs for the facilities in this project were obtained during on-site visits, records kept by
 AHP, and from the manufacturers of the products.

         Costs for the current practice engine operators, following engine manufacturer recommended OCI and
 disposing of waste oil, include the following:  purchase of oil, storage of oil, disposal of oil. If oil is not

 hazardous, then the disposal cost is $1.00 to 1.25 a gallon.  If the oil is contaminated with a hazardous material,
 it is increasingly more. Cost varies in rural Alaska, depending on location.

         Operating costs for disposal of used oil were adjusted to an annual basis and  the amount of used oil
 generated. Labor costs are determined by noting  the operator time for maintenance and changing oil and

 disposal of oil, and energy costs  estimated if the operator chooses to burn the used oil in a used oil burner for
 heat.
 Economic Analysis
                                           Critical Measurements
  Parameter
  Condemnation Limit
  Oil Change Interval

  Costs
    Oil Replacement
    Filter Elements
    Used Oil Testing
    Waste Oil Disposal
                                                      Measurement
Concentration, % change, or deviation
Total hours at condemnation limit

$/hours
($/gallon)(gallon/hour)
($/element)(element/hour)
($/test)(test/hour)
($/gallon)(gallongs/hour)
        The highest single cost associated with increased oil change intervals may be accelerated engine wear.
Shortened engine life not only wastes a resource (the engine) but could increase pollution caused by exhaust

emissions.  Increased concentrations of wear metals should result in accelerated engine wear.  For this reason
wear metals should be monitored and oils changed timely to avoid excess wear.

        Economic measurements are also needed; for example, equipment purchase, installation, maintenance.
testing, oil replacement, and disposal. The table above lists critical measurements as a function of engine
operational hours.                       i           '


Recommended Calculation
        Oil life extension economics is.a function of lubrication costs. For example, if during a 10,000 hour IC

                                                  '.58

-------
 control engine oil costs are $4,000 for purchase (oc) and $1,000 for disposal (dc) and experimental engine oil
 costs are $1,000 for purchase (oX) and $250 for disposal (dX) plus $1,500 for testing (t) and $1,000 for filter
 installation and replacement (f); then the oil cost ratio would be 0.75 (O).
        Because extending the interval between oil changes may affect engine life, a second ratio should  be
 calculated based on wear metals. For example, if 1,500 milligrams of metals were lost from the control engine
 (xC) and 1,000 milligrams lost from the experimental engine (wX) then the engine wear ratio would be 0.67
 (W). This could be interpreted to mean that metal wear on the experimental engine was only 67% of the control
 engine.
        Data reduction uses two ratios. The first ratio compares economics of oil life extension and the second
 compares wear metals. It is important that the uncertainties are known in each variable. A large uncertainty of
 one measurement such as disposal costs could outweigh another more precise and accurate measurement like
 purchasing costs. Therefore, to insure meaningful results of known quality, all the data should be compared for
 precision and accuracy.
                        6              •          !
 Oil Cost Ratio                                                                         ;

        The oil cost ratio compares the cost of experimental engine oil replacement,  disposal, filtration, and
 testing to the cost of control engine oil replacement and disposal. A ratio of 1.0 would mean costs are equal for
 experimental and control. Values less than 1.0 mean the experimental engine cost the corresponding fractional
 amount less to operate than the control engine.      l

                                 oX + dX + f + t
                        o   =	•	"
                                     oC + dC     :

                        O  = oil cost ratio        ,
                        o  = oil consumption costs
                        d  = oil disposal costs
                        f  = filter costs
                        t  = testing costs
Oil Consumption Costs
        Accurate and full cost accounting is not easy. The cost of oil is only one expense.  Other costs are
harder to account for: ordering, invoice tracking and payments, shipping, storage, inventory control, and losses of
purchased oil. For purposes of this study, we only considered the cost of purchase from operator records.
                                                   59

-------
 Oil Disposal Costs                                [                                      :

         Disposal costs are payments for transport, treatment, and disposal. If used oil is burned on site or
 re-blended into fuel, then disposal cost will be calculated as a fraction of expected waste oil burner life.

 Filter Costs                                       :                                                >

         Initial purchase price, installation (parts and labor), and element replacement are considered filter costs.
 Costs per hour should use the normal expected engine life span to calculate average costs.

 Testing Costs                                     :

         Payments to the laboratory for wear metals analysis and oil performance are costs of testing. Assume:

 0       5,000 hours on engine per year
 P       Oil change every 200 hours (25 per year)
 °       20 gallons of oil per change               ;
 o       Fuel oil cost $1.25 per gallon (includes shipment to rural village)
 °       Waste oil disposal cost $0.50 per gallon
 °       Waste oil back haul cost $0.50 per gallon
 o       Filtration equipment can cost $1000 to $1500^ plus elements at $20.00 each
 o       Equipment installation can cost between $200.00 and $1,000.00 depending upon       complexity and
 if owner does work                                •
 o       Lubrisensor cost of $600.00 and lab samples at $16.00 each

         Based on the above assumptions, changing oil at recommended intervals would
 cost  $1,125.00 for oil purchase and  disposal. This does not include labor or extra disposal or spill fees.
 Extending the oil change interval with or without filtration would reduce this cost proportionately. Engines in this
 project extended oil change intervals from 2x to six fold. With a 4x increase in the oil change interval, the
 annual oil test would be $281.25 with the purchase on a by-pass filter in conjunction with field monitoring and
 lab analysis. The operator would regain capital cost in 2.5 year pay back period. Using  the Power Plus
 re-blending technology, the operator would use more oil, but would negate disposal fees,  element costs and
regain capital costs in a 2 year pay back period. The Power Plus sets its own oil change interval and there is no
 need for labor time to charge or dispose of oil.
        Based on a 5,000 hour per year operational period, engines at Unalaska saved over 2,000 gallons per
year.  One engine at Unalaska along with the engine at Seward eliminated waste oil while  using the Power Plus
re-blend technology.                  ;                                          '        :
                                                  ,60

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                                              SECTION 6

                                        QUALITY ASSURANCE

        A Quality Assurance Project Plan (QAPjP) was prepared and approved by the EPA before testing began
(Alaska Health Project, 1990). This QAPjP was established according the EPA requirements as a method to
verify accuracy and precision (48). The experimental design, field testing procedures, and laboratory analytical
procedures are covered.  Serial dilutions of traceable elemental standards were prepared by an independent
laboratory. Traceable viscosity standards were used as received.  The QA objectives outlined in this QAPjP are
discussed below.                      •                   •
        All measurements, data gathering equipment, and data generation activities were routinely assessed for
precision, accuracy, completeness, and detection limits;.

SITE TESTING

        All on-site testing was independently verified on a centrally located CDA which was calibrated before
each test.  Because temperature can be a variable in the field, each sample was equilibrated to ambient
temperatures 24 hours prior to measurement in a centrally located office. There was no significant difference
between the field data and the central verification data, so all field data was used in the calculations and graphs.
        Quality control for the Lubrisensor is commercially unavailable, but every used oil sample was
independently tested with a centrally located CDA to verify field results.  Table 6 shows the relative percentage
difference between CDA field readings of ;used oil samples and CDA readings from the central control location.
Out of the hundreds of CDA readings, we randomly chose 10 readings, at least one from each engine from
various stages of the project, and calculated the RPD using the precision formula from the QAPjP to find the
precision of the CDA field readings.  Due to the high precision rating, the field readings were used for data
calculations.

LABORATORY TESTING

        All analyses were performed as planned except for the following variations.  Quality Control lab data is
presented  as per the JOAP manual so the format differs slightly from that presented in the QA Plan.  All Data is
included in the appendices and is listed by site and engine.
        CDA instrumental precision and accuracy was evaluated using  11 instruments purchased for this study
with four concentrations of standards. As a check on instrument  stability, field CDA instrument tests were
verified with a calibrated central CDA instrument.
        Elemental quality control limits for precision and accuracy were calculated using the fluid analysis
                                                  161

-------
spectrometer operation manual as described in the Quality Assurance Plan. Completeness, indicated by upper
(UCL) and lower control limits (LCL) were calculated for each element at the method detection limit (MDL) and
both spike concentrations (9.00 and 90.0 ppm). The low spike concentration was below the MDL for P, Ca, and
Ba. Quality control limits for viscosity were adjusted for modifications in the ASTM methods; namely, a
decrease of analysis time resulting in an increase of error. Accuracy quality control limits were met 95% of the
time for all parameters. Blanks quality control limits were met 73% of the time, which is lower than planned, but
still within parameters. Precision was met only 41% of the time. Viscosity checks were within control in 95% of
the samples. The results are summarized in the list below and depicted on Figures 19-24.

                                         Quality Control Limits
Parameter
Blanks
viscosity
9 ppm control
accuracy
precision
90 ppm control
accuracy
precision
N
11
19

11
11

11
11
% in control
73
95

95
41

95
37
As a check on CDA response stability, traceable standards were prepared for dissolved elements at four
concentrations (Figure 25).  The standard was a base oil containing soluble forms of 21 elements at 9,  100, 300,
500, and 900 ppm for each metal. For example, the 9 ppm standards contained 189 ppm total of 21 solubilized
elements.  The CDA  was unresponsive to the 9 ppm standard.  Standard deviations were calculated as a measure
of precision.  Because the initial CDA response is not linear, only values above 0.5 were used in further
calculations.
                                                  62

-------
FIGURE 21 r Quality Control Samples for Viscosity
15
GO
CD
^
0
-i-J
CO
-, — 1
-tJ
£
QJ
O '
10
c
Firs
of 1
iii iii
UCL
• • • • - 15-21 cSt
9
• * •
; standard
LCL . j •
0 - ,
: UCL
10.96 c^t 0 0 0 o ,
standard O °
: LCL ~
ii; r i i i

) 100 200 300 400 500 600 700
t Day : . Last L \
992 " "of 199 •
                     '63

-------
             FIGURE 22 - Precision forlQuality Control Spikes of 9 ppm
CD
CO

cO   2
CD

CD"
    0
                                                 1	1	T
          upper control limit
        FE CR Nl AL PB CD SN AG  T!  SI  B NA MO  P  ZN  CA BA WG  V


                                 Element
                                  64

-------
              FIGURE 23 - Accuracy for Quality Control Spikes of 9 ppm
i — i   r  i   i
                                                                  i  T
     15
X
CD
o
CO
o
O

-------
               FIGURE 24 - Precision for Quality Control Spikes of 90 ppm
     70
     60
X
-S2   so
CO

CO   30-
CD
OH
CD


     20
     10
      0
                     "i	1—i	1	i	r
                              upper control limit
          FE CR N!  AL PB CU SN AG Tl SI  B  NA MO  P ZN CA BA MG  V

                                   Element
                                   66

-------
               FIGURE 25 - Accuracy for Quality Control Spikes of 90 ppm
 X
 
 cd
 CD

 oT
     140
            FE.CR  Ni  AL PB CU SN AG  Tl  SI   B NA MO  P ZN' CA BA MG V


                                     Element
                                    67

-------
             FIGURE 26 - Calibration Curve for Comparative Dielectric Analyzers
                             Calibration  Curve for CDA
GO
r^


-5

a  ,-,
a;  2
a     \
^     I
    o
      o
                                      Staadard deviation





                                       N=39
200
400            600



Standard (ppm)
                                                                    800
                           Calibration Curve For Comparative Dielectric Analyzers
                                        68

-------
FIGURE 27 - Quality Control Samples for Total Base Number
                 34      5



                 Duplicate A
s
7
                    69

-------
 TOTAL BASE NUMBER

         Critical measurements listed in Table 5 have;estimates of precision calculated using relative difference .
 of duplicates by the equation listed below the table.  Duplicates prepared for assessing method precision will be
 analyzed at a frequency of one duplicate every ten samples.
         Precise data are reproducible, have low standard deviations, and do not have a large range. Data, with
 low precision may be affected by sampling errors, instrumental variations, contamination, or improper sample
 storage. Sources of imprecision are found by  multiple sample collection and multiple analyses of the same
 sample. (See Figure 26)
         Precision for TEN was assessed by the use of duplicate samples and calculated as described in the
 QAPjP. As  described in the QA Plan, Section 2.1, precision was measured by calculating the relative percent
 differences (RPD) of duplicate samples.   Duplicate samples were  described in the QA Plan, Section 8.1.
 Fourteen duplicate samples were selected to access accuracy of TEN. It was unforeseen that eight of the
 fourteen duplicate samples would be 0. Due to this we did not accumulate as much data as we desired, but
 enough to sufficiently calculate the precision of TEN. See TEN Precision Table 5.
         There is no commercially available standard for TEN, therefore, we were unable to assess accuracy of
 TEN. However since the rate of decrease of TEN is what is important, the precision is more important for our
 test and the RPD formula fulfills our need to determine the precision of rate of decrease of TEN.
         As described in the QA Plan, Section 2.2, accuracy was calculated from the analysis of a matrix spike.
 Accurate data are values close to the "true" value. Because the "real" or "true" value is unknown, accuracy is
 harder to determine than precision. Errors in accuracy may result from sample collection, matrix interferences,
 handling, sample preparation, or instruments, to name a few sources. The use of "known" standards and spikes
 can help determine the data accuracy.
         Measurements for accuracy were estimated by calculation of per cent recovery of laboratory matrix
 spikes by the following  equation.  % recovery = (100)(SM-M)/S where M is reported value of unspiked matrix,
 S is known value of spike concentration, and SM is reported value of matrix and spike.
         Analyses of matrix spike samples !or standard reference materials will be analyzed at a frequency of one
 matrix for every 20 samples analyzed for each method and sample type.
        As described in the QA Plan, Section 2.3, Completeness was reported as the percentage of all
 measurements whose results are judged to be valid. The goal of completeness for this project was 90% for all
 measurements.      •                                                                    >   •
        Completeness is reported as the percentage of all measurements made whose results are judged to be
 valid.  The following formula was used to determine completeness.  C=100 (V/TO), where V is number of
measurements judged valid, T is total number of measurements,  and C is percent completeness. Completeness
means a percentage of valid data obtained from a measurement system compared to the amount of data that was
                                                  70

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                       TABLE 5 - Precision Data for Total Base Number
SAMPLE
NUMBER
1
2
3
• 4
5
6
7
8
9
10
11
12
13
14

REGULAR
SAMPLE A ' .
4.43 • ' ' ',
6.78 :
2.63 • i •
0.60
0.60
0.00
0.00
0.00
0.00
0.00
O.QO
o.oc ;
o.oo ;
0.00
TOTAL RPD
DUPLICATE
SAMPLE A
4.98
6.55
3.33
0.00
0.00
0180
0.00
0.00
0.00
0.00
0.00
0.00
0.00
O.GO

RPD
1.0.57
: ' 3.45
. .' , . ' 23.49
200
200
0
• ; • • o
0
0
0
0
0
0
0
31.25
Relative Percent Difference (RPD) of TBN Between used Oil Sample and duplicate is calculated using fie formula:
Precision =     CRaauIarKDuplicate x 100                    .      -
                       (Regular -K Duplicate                 '                           '
                                            71

-------
 planned to be obtained to achieve a particular statistical level of confidence in the data resulting from the
 measurement system. Data from critical measurements taken in this project were not used to assess risks to
 public health and the environment.

 DATA INPUT

        Results from samples collected at each site were compiled on data sheets and entered into a database.
 To ensure accuracy, the data was entered twice by two
 separate individuals.  Each data set was cross checked for discrepancies.  Entries that
 differed were cross checked with the original data sheet in which the samples appeared and appropriate
 corrections were made.

 LIMITATIONS AND QUALIFICATIONS

        Based on the above QA data, the results  of the on-site and laboratory testing can be considered as a
 valid basis for drawing conclusions about  product and1 source reduction.
        Data for economic analysis and for setting oil change intervals were obtained from sites used in this
 study and the readers must adjust them in  their own case.

 Critical Measurements                              I

 Wear Metal(mg/hr)
    Iron, Chromium,  Aluminum,
    Copper, Lead, Zinc, Nickel,          ;           •       .
    Silver, and Molybdenum
    Oil Consumption(L/hr)
    Filtration Cost($/hr)
    Testing Costs($/hr)                              ;
    Disposal Costs ($/hr)

DATA EtEDUCTION

        oX + dX + f +  t
O   =	
          oC + dC

O   = oil cost ratio                   ;.
                                                  72

-------
o   = oil consumption costs
d   = oil disposal costs
f  = filter costs
t  = testing costs
                           Filters for 1200 HP engine w. 70 gallon sump capacity

Harvard 1000
Purifiner PR240
Gulf Coast
Spinner n-200
Housing
420
685
430-530
1535
i ,
Filters :
80
32
1
0
No.
2
1
1
1
Total Cost ($)
1000
717
1050
1535
Spinner
Model #
60
100-6
200
600
Cost ( $)
354 ;
548 i
1535
2826 !
Sump Capacity, gals
15-35
15-35
25-70
100-250 ;
Gulf Coast
Model No.
A-l
B-l
C
Cost ($)
housing/filter
278-425
342-526 i
110-169
Filter Vol., (quarts)
4-8
8- 16
1-2
Capacity', Horsepower
up to 300 HP
lip to 600 HP '
N/A
Harvard
Model No.
61/71 '
101
150
251
500
750
1000
Cost, ( $ )
housing/filter
1/1.5
286/15
330/36
330/23
383/45
434/53 :
476/80
Filter Vol., (quarts)
1.25
2
4
6
12
16
20
Sump Capacity, gals

3
4
6
10
15
35
                                                   73

-------
Purifiner
Model No.
RP 6(8)
RP 8(12)
RP24
RP40
RP60
RP240
Cost, ($)
housing/filter '
150/10 .
289/11
335/14
435/20
475/24
685/32 j
Filter Vol., (quarts)
N/A
1
2
3.6
5
9.5
Sump Capacity, gals
(2)
2(3)
6
10
15
60
                                                    74

-------
                                               SECTION 7
                                             CONCLUSIONS
        This study focused on answering;the  objectives described in section 1.2. The study finds that:
        1.  Oil change intervals can be extended beyond engine manufacturer's warranty recommendations
without oil degradation.  To ensure protecting the engine while extending "the oil change interval it is
recommended to use field monitoring of oil condition.  There is a consistent relation in measuring oil
degradation between CDA readings and TEN levels.  However, each engine, or group of engines, and situation is
unique. Therefore, extensions of OCI dependent on CDA response should be correlated with laboratory analysis
for each engine, lubricating oil, and fuel type.  The probability of oil decreasing TEN increases between 800 and
2000 hours and at a CDA reading of 3.0 to 6.0 for the engines tested in this study.
        2.  Oil samples from stationary diesel engines which used by-pass filters showed no less oil
contamination than control samples. Other studies have revealed that oil change intervals can be extended when
using by-pass filters, but they had  no control data. Based on a 5,000 hour per year operational period, one
facility studied (Unalaska) saved over 2,000 gallons per year of lubricating oil.  The Power Plus used oil blend
unit limits oil degradation and eliminates waste oil for stationary diesel engine operators. The Power Plus unit is
efficient, effective, and affordable.   One engine at Unalaska and the engine at Seward eliminated waste oil using
the Power Plus re-blend technology.
        3.  Small isolated communities can reduce the amount of waste oil they generate.  However, the ability
to do so is primarily based on operator ability, interest and desire to closely monitor the engine oiling process.
This increased attention is needed because degradation levels need to be determined individually for each engine
and oil by establishing baseline data.                ;
        The study further found no significant health hazard from polynuclear aromatic hydrocarbons (PAHs)  in
the used oil sampled resulting from oil  exchange intervals or burning used  oil.
                                                   75

-------
                                               SECTION 8
                                         RECOMMENDATIONS
 OPPORTUNITIES

         The following are some of the potential opportunities to reduce or eliminate the problem of used oil
 disposal:                                         ;                                   .
          1)    Have engine manufacturers extend the recommended oil drain interval in warranties; If engine
 manufacturers were more flexible in extending recommended oil drain intervals consumers could extend the oil
 drain interval without risking a violation of the expressed recommendation in the warranty.  A two-fold increase
 in the OCI would reduce the waste oil by 50%.
          2)    Improve consumer awareness on issues such as: higher oil grade, new certification system, and
 the ability to extend oil drain intervals without engine wear, ultrafiltration, used oil burners; A recent test by
 AAMA reported that nearly 50% of the public did not recognize or know the intent of the API certification
 symbol.  If the consumer was made aware of the certification process it may hold the oil marketer more
 accountable and add to the quality assurance  of the  oilL  By raising awareness, consumers may feel confident in
 extending oil drain intervals due to a more uniform  and predictable quality of oil on the market.
          3)    Develop  a more uniform and predictable quality of oil on the market that meets the growing
 needs of engine developments; If the assurance of quality on the market is improved, then engine manufacturers
 may feel safe extending the recommended oil drain  interval in the warranties. For this to occur, the quality of
 oil would have to improve beyond the needs  of engine' improvements, fuel saving requirements, and clean air
 emission standards.                                 .
          4)    Improve the pre-market requirements of the oil certification system;  An improved certification
 system, similar to the one currently adopted by AAMA and API, requires additional pre-market testing, tougher
 license agreements between the certification group and the oil marketer, and  improved quality control
 mechanisms.                                                      .          '           ,
          5)     Strengthen license agreements between oil certifying body and the oil marketer to improve the
quality control mechanisms;
          6)     Improve after market testing of certified oil; improve enforcement of the certification system.
Action needs to be taken when an oil marketer places a faulty oil on the market with a certification label.  This
is a violation.of the certification license agreement, the organizations Code of Ethics, and the FTC's Act.
Increased enforcement might improve quality  assurance and allow engine manufacturers to extend recommended
oil drain  intervals. The OLAP program never tested 100% of the oils produced, and there was  no guarantee that
an oil would be tested once it was on the market.  Tougher and more extensive post market testing would
                                                  76

-------
 encourage oil manufacturers to increase the quality assurance of oil marketed. Funding to cover the increased
 expense of the post market testing would come from license fees.
          7)     Improve enforcement of the certification system;
          8)     Use of filtration, monitoring; and lab analysis; Improved oil filters or advancements in by-pass
 systems can delay contamination of the oil.  A closed-loop  process may even eliminate oil changes completely.
          9)     Use technology for alternatives for used oil disposal.
         10)      Use alternatives to oil as a lubricant.
         11)      Burn used oil on site using approved waste oil burners.
         12)      EPA can regulate used oil as hazardpus waste or states can pass laws requiring stations to
 accept used oil. Any law passed should be enforced. .One problem which is occurring in California, from
 regulating used oil as a hazardous waste is the buildup of oil filters.  Landfills can't accept hazardous waste and
 a market must be found to accept the filters.  Currently no federal regulation mandates the crushing and draining
 of used oil filters before they are placed in a landfill.
         13)      Curb side pickup or community collection  sites.  Oregon, France and the Netherlands have
 extensive programs from curbside pickup to numerous collection sites. It can be funded by a tax on lubricating
 oil.  Rhode Island imposed a product charge of $.20 per gallon and South Carolina and Texas have an $.08 per
 gallon tax.
         14)     Public education to encourage the proper disposal of used oil.
         15)     Offer franchises to transporters of used oil  in different regions.  In France this has increased
 proper disposal of used oil tremendously.
         16)     Require all government agencies to purchase re-refined oil when possible as is done in New
 Zealand.  This is done on 50% of government vehicles in New York and Canada, while our military presently
 uses a 25% re-refined content oil.                   ,                                     i

 OBSTACLES

        The following are several obstacles to the reduction of waste oil:
         1)      Conservative oil drain intervals recommended by engine manufacturers in warranties; The
 recommended oil drain intervals are conservative so that the  manufacturers can protect their engines from the
 risk of faulty, oil. Consumers must follow these recommendations or risk violating the warranty.
        2)      Low consumer confidence and awareness of options; Along with the need to comply with
 engine warranties, consumers are more willing to spend the low price for an oil change than to risk damage to
 the engine from extended oil drain intervals.          :
        3)      Low minimum standard of oil on market; Engine manufacturers must protect against the
minimum oil quality on the market to allow themselves a margin of safety since warranty claims can be very
costly. (Conversation with Ann Pharo of EMA  on July  14,  1992).  Engine manufacturers are constantly
developing new and more efficient engines to comply with consumer needs,  fuel saving engine requirements,
                                                  77

-------
and new clean air emission standards.  Engine manufacturers claim that they need to improve engines and oil
quality to keep pace with increasing air emission standards, but EPA regulations covering the Clean Air Act do
not regulate maintenance of oil or the recommended oil drain interval. EPA certifies the engine warranty
requirements for air emissions.  EPA is regulating the extension of intervals of maintenance to promote higher
quality of products.  EPA claims that the oil drain interval is left to the discretion of the engine manufacturer
because the protection of engines is too important and costly to be regulated for air emissions. (Conversation
with Mike Donaldson of EPA in August, 1992).  By the time the minimum standard for the quality of oil on the
market is improved, improvements made by engine manufacturers require a higher quality of oil.
        4)      Low degree of assurance that oil on the market is of the quality it is labeled; It is also difficult
for engine manufacturers to extend the recommended oil drain  intervals in their warranties because there is a low
degree of assurance that oil on the market is of the quality it is labeled.  This low assurance of quality is
documented by post market testing of engine oils with the API certification label.  Tests done by the military and
the SAE OLAP program have concluded that up to 20% of the oil on the market is mislabeled.
        5)      Risks facing engine operator of extending oil  life;
Many diesel engine facilities in rural Alaska are the energy source for the village and the cost of an oil change is
less than a new engine.
        6)      Waste oil is not regulated as a hazardous waste unless contaminated;
        7)      Cross cultural communications; and
        8)      Advances in the quality assurance of oil is only an assurance, not an improvement in the
quality of oil.
                                                   78

-------
                                    REFERENCES
1.     Facility Pollution Prevention Guide. EPA-600/R-92/088, U.S. Environmental Protection
       Agency. 1992.

2.     Cummins Engine Oil Recommendations. Bull. No. 3810340. Cummins Engine Co.,
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3.     Spearot, J. General Motors Research Laboratory. Letter to Alaska Health Project.
       August 6, 1992.                   ;

4.     Alaska Health Project.  Used Oil Management in Alaska.  Research Report for Alaska
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5.     Chappell, R.  Refuge Cleaners Estimate $10 Million Bill. Anchorage Daily News,
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6.     Nolan, J., C. Harris, and S. Cavanaugh. Used Oil: Disposal Option, Management
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7.     Chemical and Engineering News, 65(46):, 1987.

8.     Graham, N. By-Pass Lube Oil Filtration.  SAE Technical Paper No. 860547.  Society of
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9.     Mayer, E.  Solid/Liquid Separation: Selection Techniques.  Fluid/Particle Separation J.,
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10.     Boone, E., and F. Didot.  Field Experience of Extended Oil Drain Intervals in Diesel
       Lubricant Performance.  SAE Technical Paper No. 760719. Society of Automotive
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11.     Alexander, W.R., L.T. Murphy, and G.L. Shank.  Improving Engine Durability Via Filters
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12.     Staley, D. Correlating Lube Oil Filtration Efficiencies with Engine Wear.  SAE Technical
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13.     Phillips, O.K. and P.D. Lane. Diesel Engine Wear with Spin-On-By-Pass Lube Oil Filters.
       SAE Paper No. 790089. Society of Automotive Engineers, Detroit, Michigan, 1979.


                                          79

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 14.    Wills, J. Lubrication Fundamentals. Parcel Dekker, Inc., NY, 1980.

 15.    Brown, G.  Full Flow and Bypass Oil Filtration in One Unit. SAE Technical Paper No.
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 16.    Romba, Phil.  Giving It A Go.  Lubrication and Filtration, (3):55-58, 1989.

 17.    Skydel, Seth.  Great Numbers, Lubrication and Filtration, (3):48-51, 1989.

 18.    Blair, M. Minimizing Production of Waste Oil at Remote Air Force Diesel Power Plants.
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 19.    Gergel, W.C., and T.J. Sheahan. Maximizing Petroleum Utilization Through Extension of
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 20.    Hudgens, R, and L.  Feldhaus.  Diesel Engine Lube Filter Life Related to Oil Chemistry.
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 21.    Naijar, Yousef.  Lubricants and Fuels Analysis as a Guide for Predictive Maintenance in
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 22.    Courtney, R.,  and H. Newhall.  Automotive Fuels for the 1980's. SAE Technical Paper
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 23.    DryofF, G. Manual on Significance of Tests for Petroleum Products. American Society
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 24.    Marino, M. Phosphate Ester Synthetic Lubricants.  Presentation to the Society of
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 25.    Pool, R. Synthesizing Oils is a Slippery Job. Science, 246(4929):444-445, 1989.

 26.    Sieloff, F., and J. Musser. What Does the Engine Designer Need to Know About Engine
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27.    Staley, D. of AC Products.  Personal communication.  10JAN91.
                                t            ."   -                 -
28.    Hsu, S., C. Ku and P. Pei.  Oxidative Degradation Mechanisms of Lubricants. In:
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                                          80

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 29.    Allman, L., A. Brehm, and C. Colyer.  The ABC's of Motor Oil Oxidation.  SAE
       Technical Paper No. 700510.  Society of Automotive Engineers, Detroit, Michigan, 1970.
       SPP-                    '         ;   •                            :
                                                                       !
 30.    Environmental Science and Technology, 24(11): 1441, 1990.

 31.    40 Code of Federal Regulations subpart E paragraph 266.40.  Used Oil Burned for Energy
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 32.    Standard Specification for Fuel Oils. American Society for Testing Materials Designation
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 33.    Watson, R., and T. McDonriel.  Additives: The Right Stuff for Automotive Engine Oils.
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 34.    Lubrication and Wear Fifth Convention.  Proceedings 1966-67. Vol. 181. part 30. page
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 35.    Sonnenburg, John G. and Lepera, M.E. Commercial Automotive Engine Oils - A
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 36.    Proceedings of the Fifth Lubrication and Wear Convention, Institution of Mechanical
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 38.    Hanna, Thomas H. Comments of MVMA to Congressman John D. Dingell Concerning
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 39.    Villena-Denton, V. New Twist to Engine Oil Standards Development. Lubricants World,
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 40.    Neff, J. Former Exxon Engineer Pleads Guilty to Falsifying Data. Anchorage Daily
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 41.    50 FR 49164 (1985).

42.    Lubrisensor Operating Manual. Northern Instruments Corp., Lino Lakes, Minnesota.

43.    Mason, C. and E. Frame. By-Pass Oil Filter Test Two-Year Program. Tank-Automotive
       Command, U.S. Army, 1990.                                        ;
                                        . 81

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44.    Butler, J., J. Stewart, and R. Teasley. Lube Oil Filtration Effect on Diesel Engine Wear.
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45.    Bowman, L.  The SAE Oil Labeling Assessment Program. SAE Technical Paper No.
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46.    Joint Oil Analysis Program Manual. NAVAIR 17-15-50.1, ARMY TM 38-301-1, ADI
       FORCE T.O. 33-1-37-1. U.S. Navy, Army, and Air Force, 1990.
                                                                           \
47.    Reller, C. A Quality Assurance Project Plan for Extending the Life of Lubricating Oil.
       EPA Contract No. CR-817011-01-0. U.S. Environmental Protection Agency, Cincinnati,
       Ohio.
                                        82

-------
                                   BIBLIOGRAPHY
 Alaska Health Project. Used Oil Management in Alaska.  Research Report for Alaska Dept. of
 Environmental Conservation, Juneau, Alaska, 1989.

 Alexander, W.R., L.T. Murphy, and G.L. Shank. Improving Engine Durability Via Filters and
 Lubricants.  SAE Technical Paper No. 85125. Society of Automotive Engineers, Tulsa,
 Oklahoma, 1985.                        :
                               !
 Altaian, L., A. Brehm, and C. Colyer. The ABC's of Motor Oil Oxidation. SAE Technical Paper
 No. 700510. Society of Automotive Engineers,  Detroit, Michigan, 1970. 8pp.

 Blair, M. Minimizing Production of Waste Oil at Remote Air Force Diesel Power Plants.  5099
 Civil Engineering Operation Squadron (CEOS),  1990.

 Boone, E., and F. Didot. Field Experience of Extended Oil Drain Intervals in Diesel Lubricant
 Performance. SAE Technical Paper No. 760719. Society of Automotive Engineers, St. Louis,
 1976.                          .

 Bowman, L. The SAE Oil Labeling Assessment Program. SAE Technical Paper No. 880710.
 Society of Automotive Engineers, 1988.

 Brown, G.  Full Flow and Bypass Oil Filtration in One Unit. SAE Technical Paper No. 881826,
 Society of Automotive Engineers, Toronto, Ontario, 1988.

 Butler, J., J. Stewart, and R. Teasley.  Lube Oil Filtration Effect on Diesel Engine Wear.  SAE
 Technical Paper No. 710813. Society of Automotive Engineers, 1971.

 Chappell, R. Refuge Cleaners Estimate $10 Million Bill. Anchorage Daily News, September 13,
 1987, p. Bl.                                                            I

 Chemical and Engineering News, 65(46):, 1987.

 Courtney, R., and H. Newhall.  Automotive Fuels for the 1980's. SAE Technical Paper No.
 790809.  Society of Automotive Engineers, Toronto, Ontario, 1979.

 Cummins Engine Oil Recommendations. Bull. No. 3810340. Cummins Engine Co., 1987.

Dryoff, G. Manual on Significance of Tests for Petroleum Products. American Society for
 Testing Materials MNL 1 1989.             i

Environmental Science and Technology, 24(11): 1441,  1990.

Facility Pollution Prevention Guide.  EPA-600/R-92/088, U.S. Environmental Protection Agency
 1992.


                                        ; 83

-------
 40 Code of Federal Regulations subpart E paragraph 266.40.  Used Oil Burned for Energy
 Recovery.  50 Federal Register 49025, November 29, 1985.

 50 FR 49164 (1985).

 Gergel, W.C., and TJ. Sheahan.  Maximizing Petroleum Utilization Through Extension of
 Passenger Car Oil Drain Periods - What's Required? SAE Technical Paper No. 760560.  Society
 of Automotive Engineers, St. Louis, Missouri, 1976.  16 pp.

 Graham, N. By-Pass Lube Oil Filtration. SAE Technical Paper No. 860547.  Society of
 Automotive Engineers, Toronto, Ontario, 1986.  10pp.                      ;

 Groh, D.C. and L.O. Bowman. SAE Oil Labeling Assessment Program - Three-Year Cumulative
 Report. SAE Technical Paper No. 902091.  Society of Automotive Engineers, Tulsa, Oklahoma,
 1990.

 Hanna, Thomas H. Comments of MVMA to Congressman John D. Dingell Concerning
 Voluntary Engine Oil Testing, Labeling and Licensing. Detroit, Michigan, 1991. ,
                                                                       I
 Hsu,  S., C. Ku and P. Pei. Oxidative Degradation Mechanisms of Lubricants. In: Aspects of
 Lubricant Oxidation.  American Society for Testing Materials, 1986.

 Hudgens, R, and L. Feldhaus. Diesel Engine Lube Filter Life Related to Oil Chemistry.  SAE
 Technical Paper No. 780974. Society of Automotive Engineers, Toronto, Ontario, 1978. 24 pp.

 Joint  Oil Analysis Program Manual.  NAVAIR 17-15-50.1, ARMY TM 38-301-1, AIR FORCE
 T.O. 33-1-37-1. U.S. Navy, Army, and Air Force, 1990.

 Lubrication and Wear Fifth Convention. Proceedings  1966-67. Vol. 181. part 30. page 238.
 Institution of Mechanical Engineers.  Westminster, London.

 Lubrisensor Operating Manual. Northern Instruments Corp., Lino Lakes, Minnesota.

 Marino, M. Phosphate Ester Synthetic Lubricants. Presentation to the Society of Tribologists
 and Lubrication Engineers. FMC Corp., Philadelphia,  Pennsylvania, 1991.

 Mason, C. and E. Frame. By-Pass Oil Filter Test Two-Year Program. Tank-Automotive
 Command, U.S. Army, 1990.

Mayer, E.  Solid/Liquid Separation: Selection Techniques.  Fluid/Particle Separation J., 1(2):,
 1988.

Najjar, Yousef. Lubricants and Fuels Analysis as a Guide for Predictive Maintenance in Diesel
Engines. FUEL, 66(3):431-433, 1987.                                     !
                                         *84

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 Neff, J.  Former Exxon Engineer Pleads Guilty to Falsifying Data.  Anchorage Daily News, June
 5, 1992, p. B6.

 Nolan, J., C. Harris, and S. Cavanaugh.  Used Oil: Disposal Option, Management Practices and
 Potential Liability. Government Institutes, Inc.,  1989.

 Phillips,  O.K. and P.O. Lane.  Diesel Engine Wear with Spin-On-By-Pass Lube Oil Filters. SAE
 Paper No. 790089.  Society of Automotive Engineers, Detroit, Michigan, 1979.

 Pool,R.  Synthesizing Oils is a Slippery Job. Science, 246(4929):444-445, 1989.

 Proceedings of the Fifth Lubrication and Wear Convention, Institution of Mechanical Engineers,
 London, England, 1967, p. 238.

 Reller, C. A Quality Assurance Project Plan for Extending the Life of Lubricating Oil.  EPA
 Contract No. CR-817011-01-0.  U.S. Environmental Protection Agency, Cincinnati, Ohio.

 Romba,Phil. Giving It A Go. Lubrication and Filtration, (3):55-58, 1989.

 Sieloff, F., and J. Musser. What Does the Engine Designer Need to Know About Engine Oils?
 SAE Technical Paper No. 821571.  Society of Automotive Engineers, Toronto, Ontario, 1982.

 Skydel, Seth. Great Numbers, Lubrication and Filtration, (3):48-51, 1989.

 Sonnenburg, John G. and Lepera, M.E. Commercial Automotive Engine Oils - A Laboratory
 Assessment  of Their Quality Report No.  2287; U.S. Army Mobility Equipment Research and
 Development Command, Fort Belvoir, Virginia, 1979.

 Spearot,  J.  General Motors Research Laboratory. Letter to Alaska Health Project. August 6
 1992.

 Staley, D. of AC Products. Personal communication. 10JAN91.

 Staley, D. Correlating Lube Oil Filtration Efficiencies with Engine Wear.  SAE Technical Paper
No. 881825. Society of Automotive Engineers, 1988.

 Standard Specification for Fuel Oils.  American Society for Testing Materials Designation D 396-
89.

Villena-Denton, V. New Twist to Engine Oil Standards Development. Lubricants World
 1(12): 1,7, 1991.

Watson, R.,  and T. McDonnel. Additives: The Right Stuff for Automotive Engine Oils. SAE
Technical Paper No.  841208.  Society of Automotive Engineers, Toronto, Ontario, 1984.

Wills, J. Lubrication Fundamentals.  Marcel Dekker, Inc., NY, 1980.

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 APPENDIX A


       There are two types of warranties, expressed and implied. An expressed
 warranty is the written  guarantee of  the  product expressly  stated by the
 engine  manufacturer.   The  express warranty is extended to the  first
 buyer/owner of the vehicle and can be transferred to a second buyer/owner
 for a nominal fee.  An implied warranty is usually defined by  state law.  An
 implied warranty of merchantability is the understanding that the product is
 reasonably fit for  the  general purpose for which it was sold.  An implied
 warranty of fitness for a particular purpose is the inherent understanding
 that the product is suited  for the consumers special purposes  if the special
 purposes were specifically disclosed to manufacturer; not merely to the dealer,
 during  the purchase.  These implied warranties are  limited,  to the extent
 allowed by law, to the time  period covered by the written warranties set  forth
 by the manufacturer. Certain changes or modifications made to  the vehicle do
 not, in and of themselves, void the limited warranties.(l)   The basic warranty
 covers cost of all parts and labor needed to repair any item on a vehicle that is
 defective in material, workmanship or factory preparation. (2)   Most limited
 warranties  do not cover costs of normal scheduled  maintenance of  your
 vehicle.   It doesn't  cover costs of lubrication,  filters  or  other  normal
 maintenance parts.  The goal: of this project is to find solutions to the problem
 of waste oil.  One solution is to extend the life of oil by extending oil drain
 intervals. If an engine operator extended  the oil drain interval of his engine
 by twofold, then the  result would be half of the waste oil to  dispose and a
 decrease in cost.  Although  this sounds  like a simple alternative for car owners
 and engine operators, it is deterred by the requirements in express warranties
 of engine companies.
(1)     Such changes could be installation of non-brand parts, components or equipment, modification of the vehicle or its components.
or the especial use of special, non-manufacturer, materials or additives. This Basic Warranty only covers vehicle if it is operated and
maintained in the manner described in the Owners Manual     ;                                . •*•"""•*

(2)     Engine warranties are "Umited to defects in workmanship or materials." They expressly state recommendations for which oil to
use and the drain interval. The consumer may use other products but it may affect the warranty. If the new product used at the discretion
of the consumer was responsible for the damage to the engine then the warranty does not apply, for example, CUMMINS- warranty void If,
at Hie same time as failure, the engine is found to have been modified so as to substantially alter its operating characteristics. (Oil filter is
not substantial) International Harvester- If engine failure is caused by use of an untested after-market item, then warranty is VOID. IH
dealers sell bypass filters and it changes OCI from 200 hr/6OOO mites to 32S hr/10,OOO mites. If malfunction occurs as result of alteration
or use of non-authorized part, then warranty does not apply. Every new vehicle must meet federal and state emission standards so the
warranty covers the cost of repairing or adjusting the vehicle's emission control systems that are defective in detail or workmanship or
lactory preparation.                                                           '



A dealer gives a consumer a warranty in consideration for buying a vehicle.
There are two types of warranties,  written and implied.(3)    The purpose of the
warranty is to guarantee that the product is of good workmanship, has no
defects, and is similar to what was in the mind of the buyer.
       The standard warranty covers repairs to  any vehicle  defect related to
materials or workmanship noted during the expressed warranty period.  Along
with the  warranty,  each engine company  recommends  a  maintenance
schedule which includes a recommended oil drain interval.  This indicates how
often the  engine operator should drain  the oil in order to  comply with the
warranty.  Each consumer must use reasonable and  necessary maintenance to
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 comply with the warranty.(4) Any damage to the engine caused by a deviation
 in the recommended oil drain interval is not covered by the warranty.
       The simple solution would  be for  engine companies to extend the
 recommended oil drain interval in the warranty, but this can  only occur if 1)
 the  quality of the engine is improved or 2)  the  quality of the oil is improved.
 The engine companies  need  assurance that the  quality of the oil used  by
 operators is sufficient to handle extended oil drain intervals.
       A problem facing engine manufacturers  is  the difficulty in defending
 an action by a  consumer for failure to honor  a warranty.  When  asked' to
 determine if engine damage  submitted on warranty claims  was due to not
 following recommended oil  change intervals,  engine manufacturers have
 found  it very  difficult to prove  that  an oil wa.s used longer  that  the
 recommended interval without knowledge  of the type of driving  to which the
 engine was subjected or what oil was used.(5)

 Prompted by governmental investigations into  the ambiguity of warranties
 being  offered to purchasers of automobiles, Congress enacted the Magnuson-
 Moss Warranty Act, 15 USC 45, in 1975, in an attempt to put manufacturers and
 consumers on  equal  footing  by  requiring  warranties to  be  more
 understandable.   In passing  the  Act,  Congress  intended to  prevent
 corporations from using unfair methods of competition in commerce. Federal
 Trade Comm. v.  Klesner. 274 US 145, 47 SCt 557 (1927).  The paramount aim is
 protection of the public from evils likely to result from destruction  of
 competition or restriction of it in  substantial degree.  FTC v. Raladam Co.. 381
 US 357, 85 SCt 1498 (1965). In any case, a prerequisite  to application of FTC Act
 is unfair interference with interstate trade and  such  deception of public as to
 cause it to buy and pay for something which  it is  not getting.  Ford Motor Co. v.
 FTC, 120 F2d 175 (1941CA6)
(3)     "Written warranty" isdefinedas: "(A) any written affirmation of fact or promise made in connection with the
sale of a consumer product by a supplier to a buyer which relates to the nature of the material or workmanship and
affirms that such material or workmanship is defect free or will meet a specified level of performance over a period of
time, or (B) any undertaking in writing in connection with the sale by a supplier of a consumer product to refund, repair,
replace, or take other remedial action with respect to such product in the event that such product fails to meet the
specifications set forth in the undertaking, which written affirmation, promise, or undertaking becomes part of the basis
of the bargain between supplier and a buyer for purposes other than resale of such product" 15 USC 2301(6). The
term "implied warranty" is defined "under state law (as modified by sections 108 and 104(a) [15 USC 2308 and
2304(a}] in connection with the sale by a supplier of a consumer product"  15 USC 2301(7).


(4)    The term reasonable and necessary maintenance consists of those operations (A) which the consumer
reasonably can be expressed to perform or have performed and (B) which are necessary to keep any consumer product
performing its intended function and operating at a reasonable level of performance. 15 USC 2301 (9)

(5)    (Statement by James A. Spearot of General Motors).

      The Act comes into play whenever a manufacturer provides a  written
warranty.(6)  If a consumer does not have a written warranty, then  they can
bring an action for a breach of an implied warranty  of merchantability if the
goods are not fit for a particular purpose or  do not conform to the promises or
affirmances of fact  made on the container or label,, if any. UCCS2-314. Under
the Magnuson Moss Act, if  the written warranty is extended, then the implied
warranty cannot  be modified-  or disclaimed.  Also,  an implied warranty can
only be limited  to  the duration of the written warranty and such language
must appear on the container.
      The Act has its own private cause  of  action for a violation and allows
attorney  fees for the  prevailing plaintiff which increases  the ability  for
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 consumers to find attorneys who are willing to take the case.  The Act does
 allow a repurchase/refund remedy that must be included in all "full" written
 warranties, but in cases involving breach of service contract, implied  or
 limited warranties, the measure of damages is same as state law.
       The manufacturer may  not  make representations  as to quality  or
 performance characteristics of a product unless representation is true and
 unless  at  time or making each such  representation, the manufacturer
 possesses and relies  upon competent  and reliable  scientific  tests which
 substantiate each representation.  Re Renuzit Home Products. 99 FTC 291 (1982).
 Whatever a label says it must be accurate because all contracts contain an
 implied understanding not to deliver mislabeled goods.  UCC  S  2-314, comment
 JLw*                                             •   _
       Engine manufacturers do not feel comfortable extending recommended
 oil drain intervals because evidence reveals a low quality assurance of oil and
 questionable labeling practices on the marketer  It is deceptive advertising
 and a violation of 15USC45:to alter report on respective qualities of product
 where report misrepresented quality of tested products as  found  by testing
 company. Country Tweeds. Inc. v. FTC. 326 F2d 144 (1964CA2).
      Several different legal actions can have a direct or  indirect effect on
 the waste oil dilemma.  First, a consumer who buys faulty oil  may bring action
 against the  oil marketer for breach of express and implied  warranty.   The
 cause of action, or ticket into court, for breach of express warranty is 15 USC
 45(a).  In this scenario, the American Petroleum Institute (API)  certification
 label on the oil container is an expressed statement to  the consumer assuring
 the quality of the oil.  The consumer  relies on this statement  in purchasing the
 product and may bring action, but this is unlikely because a consumer would
 have to buy a  large amount of faulty or mislabeled oil to make the action
 financially worthwhile and  it would be  expensive  to prove that the oil was
 faulty and directly caused engine damage.  If such a suit did occur, it could
 effect the waste oil dilemma by encouraging oil manufacturers to assure that
 the quality of the oil is what is expressed on the label.  This  quality assurance
 may allow engine manufacturers to extend the recommended  oil drain interval
 in the warranties.  An unproved  quality of oil might  reduce the amount of
 waste oil.
(6)     Under the Act a written warranty is defined in 15 USC 45( 1)(A) and (B). infra. The Act's definition of warranty
differs from the UCC's definition of express warranties in two ways. First, under the Magnuson Moss Act the express
warranty must be in writing and second, it only applies to consumer goods.

(7)     In 1992, a former Exxon mechanical engineer pleaded guilty to falsifying tests to obtain Pentagon and private
industry approval for additives to Exxon lubricants. The individual knowingly concealed the falsification of oil additive
tests submitted to the Army and the Lubricant Review Institute, an oil industry agency that offers advice to the Army on
fuels and lubricants. Private companies also customarily purchase lubricants that meet military specifications: Associated
Pressarticle by Joseph Neff dated June 5, 1992.
      A second possible legal action is in the case of a consumer whose engine
failed and who files suit against the engine  manufacturer for failure to honor
an expressed warranty if the engine manufacturer did not repair or replace
the defect.  This might occur  if the engine manufacturer  claims that the
warranty is void because the consumer failed to follow proper maintenance
guidelines concerning oil drain recommendations in the warranty. To defend
these lawsuits the engine  manufacturer must  prove that the engine failure
was a direct cause of faulty oil or improper maintenance by the vehicle owner.
Since this can be a difficult and expensive task, these actions usually settle out
of court. The result of this type of action on the waste oil dilemma is stringent
recommended oil drain intervals by engine manufacturers in  order  to reduce
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 the costs of warranty claims.  Engine manufacturers would also demand a
 higher quality of oil for use in their engines and more assurance of quality in
 the certification process. These needs might influence oil manufacturers to
 produce a higher quality product of oil, which might reduce  the amount of
 waste oil.
       A third possible legal action is where an engine manufacturer  petitions
 the Federal Trade Commission  (FTC)  claiming  that oil  marketers are  in
 violation of deceptive trade practices in commerce which is prohibited by the
 FTC Act.(8).  Factors FTC considers in determining if a trade practice  is unfair
 are whether it has been considered unlawful, offends public policy established
 by law,  or is  within some:concept  of unfairness, whether it is immoral,
 unethical, oppressive, or unscrupulous, and whether it causes substantial
 injury to consumers or competitors.  Re Pfizer.  Inc.. 81 FTC 23 (1972). The
 violation is valid if  the marketed oil  is  not the quality  assured by  the
 certification label  on the  container.   Such an  action could  pressure oil
 marketers to raise the quality of oil to the standard on the label.  If the quality
 was improved, engine manufacturers might  extend the recommended  oil drain
 interval resulting in a decrease in waste oil.

       Engine manufacturers ;are concerned  with oil placed on the market that
 does not meet certification requirements.  The low quality oil is purchased by
 consumers and used in vehicles.  Engine damage often occurs resulting in  a
 warranty claim at the expense of the  engine manufacturer. Recent studies by
 The Society of Automotive Engineers (SAE) and the U.S. Army have concluded
 that many oils on the market are questionably labeled.(9)  The Act applies to
 both labels and advertisements.  FTC v. Kay. 35  Fsd 160 (1929CA7).  While
 labeling and advertising are often considered together, there is good reason to
 insist  on higher degree  of truth in labeling statements because consumers
 may accept labeling statements literally while viewing  advertising with more
 jaundiced eye.  Korber Hats, Inc. v. FTC. 311 F2d 328 (1962CA1).

 (8)     The commission is hereby empowered and directed to prevent corporations from using unfair methods of
 competition in or affecting commerce and unfair or deceptive acts or practices in or affecting commerce, which are
 unlawful. 15 USC 45(a)(2). The terms "unfair methods of competition" and "unfair or deceptive practices" are not
 limited to specific practices, but take their meaning from facts of each case and impact of particular practice. Pan
 American World Airways. Inc. v. United States. 371 US 296, 83 SCt 476 (1963).
                             [        - ...       .          . .
 (9)     In 1979 the Army tested the quality of 17 commercial oils and concluded that 11 products failed to meet one
 or more of the specification's physical/chemical requirements and 6 of the products had insufficient additives. All of the
 products were advertised to meet the API performance level. SAE initiated the Oil labeling Assessment Program (OLAP)
 since 1987. The U.S. Army, in order to get reasonable assurance that oil it purchases actually meets industry standards,
 sponsored the project and provided funding for the first two years, but funding now is shared by the Army, MVMA, ILMA,
 and API. The program's objective was to analyze samples of oil on the market nationwide, identify questionably labeled
 samples, and attempt to resolve problems with quality assurance. Testing has shown as high as 16.5% of the oils sampled
 were questionably labeled.
       A fourth type of action that could effect the  waste oil dilemma is where
 an organization or individual petitioned the  FTC to  take action against another
 organization/company  that  violated  the  FTC  Act.   For  example, the
 International Lubricant Manufacturers Association (ILMA)  filed  a complaint
with the FTC against the Motor Vehicle  Manufacturers Association (MVMA)
 claiming  that MVMA was  violating the FTC Act by requiring consumers to use
 specific brand name products for oil maintenance in order to  comply with the
warranty. Since oil maintenance is  not covered in warranties, consumers are
 able to use any product without violating  provisions of the  warranty.  As a
result  of this action, MVMA agreed not to require the use of  brand names in
maintenance not covered by  the warranty.   Engine manufacturers can
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 petition FTC for a waiver of this provision, but such has never occurred.  This
 had little direct effect on the waste oil dilemma, but shows the ability of one
 organization to take action if another organization is violating the FTC Act.
       The FTC  has entered into consent agreements alleging violations of the
 Warranty Act with at least one manufacturer and several dealers.uo)
 Trademark Enforcement

       The API   symbol  of certification  is  a  trademark  used  by  oil
 manufacturers.  It represents the standard for minimum quality of oil on the
 market. It is an expressed statement to consumers that the container of oil has
 been tested and meets the minimum standard  of  quality.  The current API
 classification  system is voluntary with very few assurances on quality.


 MVMA                    :         '-.                             ;
       The Motor Vehicle Manufacturers Association represents most of the
 large engine and vehicle manufacturers in America.  The goal of the
 organization is to promote the interests of the vehicle manufacture industry
 in the United  States.  In 1987 they joined with the Japanese Automotive
 Manufacturers Association (JAMA) to form the International Lubricant
 Standardization and Approval Committee (ILSAC)  with the purpose of
 establishing minimum performance standards for engine oil.  ILSAC GF-1 was
 the first standard established for passenger cars and is the basis for the North
 American  Lubricant Standardization  and-Approval System (NALSAS) proposed
 by MVMA  in 1990. MVMA was not satisfied with the current tripartite system
 and the quality of the oil that received the API certification symbol.  In  an
 attempt to improve the minimum standard of quality for  oil on the market and
 to have a larger voice in the development of engine performance standards,
 they independently established NALSAS.
(10)    Renault U.S.A. incorrectly attempted to limit implied warranties to one year or 12,000 miles, instead of the
required two years or 24,000 miles. The FTC required Renault to cease the alleged unlawful practice of a limitation on
implied warranty rights and to notify all consumers of the mistake FTC has entered into consent agreements with several
dealers who attempted to disclaim all implies; warranties and failed to disclose warranty information before the sale.


MVMA and API broke off talks in early 1990, but  in June 1991, under pressure
from ILMA(ii),  an alternative system proposed  by CMA(i2), MVMA  and API
reunited to jointly establish a new oil certification system.  The new system
would integrate  some of the NALSAS items into the API "donut" symbol.


API
      The American  Petroleum Institute  represents  the  interests  of oil
manufacturers  and producers in the  United States.   API  is an  inaugural
member of  the current tripartite system and oversees  the certification
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 process.  API is also in cooperation with MVMA  in  developing the new oil
 certification system in an effort to make product improvements and enhance
 customer satisfaction.

 License  Approval  Process

       The  ILSAC Certification Mark, jointly established between MVMA and
 JAMA, should begin in April; 1993.  Although MVMA had intended to establish
 NALSAS,  and their own Independent licensing  system, it was decided that the
 ILSAC Certification Symbol will co-exist side by side with a revised API service
 symbol,  which began in 1993.   These new systems  arose out  of engine
 manufacturers' desires to have a  greater voice in development of new engine
 performance  standards.  Despite MVMA's success in gaining more influence in
 the development  of new minimum performance standards, API will own,
 license, and administer both marks and be responsible for monitoring the new
 licensing system:   Under the new proposal,  any individual,  company, or
 association  can submit a request for new oil performance standard to SAE. SAE
 will establish a task force  consisting  of three ILSAC  members,  three SAE
 members, and a non-voting liaison from ASTM, API and other technical
 societies.  The new performance standard for the ILSAC Certification  Mark
 must meet  all physical, chemical,  bench, and engine  testing requirements.
 The API symbol may be placed  anywhere on the container, but  the  ILSAC
 certification mark must be placed on the front.  It is at the discretion of the oil
 marketer to apply for one or both of the marks. To gain and API license, the
 oil marketer must submit an application (which includes engine test results
 and the CMA Product Approval Code of Practice), a technical program data
 sheet, the license agreement/and  a formulation code identification sheet.  The
 license flat fee is $500, a $300 increase, plus  an additional $1,000 for every
 million gallons sold.
(11)    In February of 1991, an attorney for ILMA wrote MVMA ordering MVMA to cease and desist from damaging
comments regarding engine oils produced by ILMA members. MVMA claimed that many of these engine oils were low
quality and questionably labeled. ILMA claimed that since the engine oils displayed the API symbol that they must
conform to API standards. In the letter to MVMA, ILMA stated it would be forced to consider all avenues available to
protect its rights if the unsubstantiated claims did not stop.
(12)    CMA developed the Product Approval Code of Practice as an alternative system for engine testing and
monitoring. MVMA felt that if API adopted the CMA guidelines and continued improvements, then they could abandon
in independent NALSAS system.


Appendix B


                            CERTIFICATION

       Since 1911 a system has existed  for the automotive and oil industry to
classify  oils  into  service \ and  performance  categories.  Along  with
performance  categories, adequate test methods are established  to  verify
performance of the oil.  By certifying oil before it enters the marketplace oil
manufacturers  can  be  assured  that consumers  will select  oil  due  to
                                   91

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performance characteristics and type of  service for which the  oil was
intended.

In 1970, SAE, American Petroleum Industry (API) and the American Society for
Testing and Materials (ASTM) agreed to form the tripartite system and develop
an  engine oil performance  and  classification system  that assured  the
minimum standard quality of oil.

They designed  the API  "donut seal of approval"  which displayed  the
appropriate API  service category, the SAE viscosity grade, and if applicable,
energy conserving features of the oil.

The API symbol is a representation by the oil marketer to the purchaser that
the product conforms to the applicable standards and speculations for engine
oils established by the automotive and oil industries.  After several years of
dominance by the oil manufacturers  in  the standards and certification
process,  the  Motor Vehicle Manufacturers Association (MVMA)  decided to
increase their participation in the prbcess to protect then- interests.  MVMA
believed that there were  too  many oils marketed in a false or deceptive
manner and it was depriving consumers full performance of their vehicles.

In order to gain a larger voice  in  the oil  certification framework,  MVMA
independently established the North  American Lubricant Standardization and
Approval System (NALSAS).  This alternative system sought to improve test
methods and  performance criteria so that the minimum standard of oil quality
remained on par with changes  in  equipment design, fuels,  maintenance
practices and government standards.

MVMA decided to move forward with the NALSAS program, whereas, API
questioned the need for a second system and decided to remain  with  the
tripartite system.  A chain of events occurred, questioning the quality of oil on
the market, that put pressure on API.  In response to these events, API met
with MVMA to develop a single system.  As a result of these meetings,  MVMA
proposed an alternative to NALSAS and after modification it was approved by
the API Lubricants Subcommittee. The final document was released  this past
summer.                   ;

The new system  integrates the NALSAS items into the API "donut" symbol to
create the SH oil category.  API owns, licenses, and administers the new system
and is responsible for monitoring and licensing. To gain and API license,  the
oil marketer must submit an application, a technical program data sheet,  the
license agreement, and a formulation code identification sheet.  The license
flat fee is $500, a $300 increase, plus an additional $1,000 for  every million
gallons sold.
The new oil certification process has improved both its pre-market and post
market requirements.  The Multiple Test Acceptance Criteria is now used to
discover if a given oil meets the minimum performance requirements.  The old
API process only required a single  pass for each oil which  meant  an oil
marketer could retest the oil an infinite number of times and if it passed once,
it was certified, but under the new system the mean value of each parameter
must be a pass. An oil marketer must also provide a product traceability code
and new physical and chemical bench and engine test results.  The Chemical
Manufacturer's Association (GMA) Code of Practice has also been  adopted as
part of the  certification process.      ;
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 The Oil Labeling Assessment Program (OLAP) post market test program will
 continue, but more  engine oils will  be chosen for audit by an unbiased
 selection of licensed oils in the field.  Any violation could result in temporary
 or permanent suspension of the license and a recall of oils in the market.

  HISTORY  OF THE ENGINE SERVICE CLASSIFICATION  SYSTEM
       In 1911, the Society For Automotive Engineers  (SAE)  developed the
 Crankcase Oil Viscosity Classification System.  This  system, which classified
 engine oils by viscosity only, remained the only system until 1947 when,  in
 response to  interindustry need for consideration of other  factors, the
 American Petroleum  Institute (API) adopted a three part systemas).  Although
 an improvement, this early system failed to consider such factors as  engine
 operating  conditions, gas or  diesel engines,  and composition of fuels.
 Recognizing  these inadequacies,  the API Lubrication  Subcommittee,  in
 cooperation  with the American  Society for Testing and Materials (ASTM),
 developed the Engine Service Classification System in 1952(14).
       Despite any gains, there  remained  two  major  demands on  the oil
 certification process.  One was the need  for  a more effective means  to
 communicate engine oil performance, and service classification information to
 industry, and the other was the  desire of the automotive industry for a more
 flexible system to satisfy its changing warranties, maintenance,  service, and
 lubrication requirements.
       In response to these demands, the  current  tripartite system was created
 in 1970 when SAE, API, and ASTM agreed to cooperate to  develop an engine oil
 performance and classification systemas). This categorization allowed  engine
 oils to be precisely defined and selected due to  performance  characteristics
 and the type of service for which it is intended.  In 1970, a ninth class  of
 service was added  to reflect the  new model  vehicles.  In conjunction with the
 new certification system,  the tripartite (API, ASTM,  and SAE), established  a
 voluntary labeling program based on self certification.  It was intended  to
 inform consumers of the quality of the oil they purchased.  API designed the
 symbol to display the appropriate API service  category, the SAE viscosity
 grade, and if applicable, energy  conserving features of the oil on the bottle  of
 each oil marketed.
•(13)    ItdesignatEdcrankcaseoilsasRegularType(mineralous), Premium Type (oils containing oxidation inhibitors),
and Heavy Duty Type (oils containing oxidation inhibitors and additives).

(14)    This system, which was revised in 1955 and 1960, separated gasoline and diesel engine performance by
classifying service categories (ML, MM, and MS for gas engines: DG, DM, and DS for diesel engines) which provided a basis
for selecting crankcase oils.                    .                             !

(15)    The new classification system jointly established and designated oils as SA, AP, SC, SD, SE, CA, CB, CC, and CD. It
applied to passenger cars, gas and diesel trucks as well as off-highway equipment.

There  have only been .two major changes in the tripartite system since  1970.
First, in 1983 when API established the use of a registered trademark service
symbol, and  second in 1989 when licenses  were required to provide chemical
and physical data to certify that engine oils meet licensed performance.
       Due to the need for  diesel truck services to reduce maintenance  costs,
down time, and waste oil, SAE began a program in 1973 to develop an  oil that
could withstand extended drain intervals.  SAE concluded that recommended oil
drain  intervals were largely  very conservative and some current oils  were
capable of extended drain  intervals if proper maintenance was followed.
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       Over the years, performance  categories have become obsolete because
test methods were no longer available to verify performance.  Recent studies
have concluded  that  a substantial percentage of oil on  the market is of
substandard qualityue).
       As a result, the API indicated that too often the API symbol is used to sell
inferior products and  SAE was requested to  take the lead in an aggressive
effort to control the use of quality designations.  These events were partially
responsible for the introduction of the API service trademark symbol in 1983
and the Oil Labeling Assessment Program (OLAP) program in  1985.
       The  concept for  the  OLAP  was  initiated in the  API  Lubricant
Subcommittee in 1979, but budget  constraints forced API to discontinue
development of the program. The U.S. Army, which funded the first two years
of OLAP, initially sponsored the  program because of its desire  to increase
flexibility in purchasing oil which  met industry standards rather than only
oils which met military specifications!;i?).  The Army hoped the OLAP program
would give  them  reasonable  assurance in  purchasing  commercial oils.
Although, hi 1982, the Army  requested SAE to  begin studying OLAP  in an
attempt to identify questionably labeled  oils on the market, the first year of
operation was not until 1987.   The program's objective was to  1) obtain and
analyze a representative sample of engine oils sold in North America, and 2)
identify those which have viscosity or additive deviations, and 3) attempt to
resolve the problem of questionably labeled products through  correspondence
with the marketers.                                               :
       hi  1989, API filed a formal  complaint with the FTC with regard, to
certain automobile warranties  that have conditions on the use of automatic
transmission fluids identified by brand trade, and corporate names.  Requiring
the consumer to use a specific brand for a part not covered in the  warranty is
in violation  of the FTC  Act, 15 USC 45.  The engine manufacturer settled  the
dispute and now complies with the Act.
       Later in 1983, API established the Engine Oil Licensing  and Certification
System to ensure the  quality of products being marketed and to enhance
consumer awareness of lubricants for new vehicles.
(16)   A1977 Ford survey on aftermarket oil provided to API Marketing Committee revealed substantial percentages
of substandard quality oil on the market A1978 General Motors survey presented to SAE F&L Technical Committee
revealed substantial percentages of substandard quality oil on the market A 1979 U.S. Army survey of commercial
engine oils revealed substantial percentages of substandard quality oil on the market A 1983 API survey presented to
SAE F&L Technical Committee revealed substantial percentages of substandard quality oil on the market A1983
Industry survey presented by Tom Franklin to the SAE F&L Technical Committee revealed substantial percentages of
substandard quality oil on the market.

(17)   The two major specification used by the military are MIL-L-2104." Lubricating Oil, Internal Combustion Engine,
Tactical Service," and MIL-L-46152, "Lubricating Oil, Internal Combustion Engine, Administrative Service." The military
has their own specifications because using commercial oils from a wide range of products could result in engine problems
due to the use of military vehicles in extreme conditions.

In  1987, in response to major shortcomings in  the  current  certification
system and  the inability of vehicle manufacturers to  have  a voice in the
tripartite  framework, MVMA decided to  operate within its own framework  to
develop and alternative  system, hi 1991, MVMA  developed and proposed for
comment the North American Lubricant Standardization and Approval System
for Passenger Car Engine Oils (NALSAS).  This alternative  system was based on
a responsible minimum standard combined with regular improvements hi test
methods and performance criteria that insured the standard remained on par
with  changes  in equipment design, fuels, maintenance  practices  and
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 government  standards.  MVMA believed  that  there were too many oils
 marketed  in a  false  or  deceptive  manner,  depriving  consumers  full
 performance of their vehicles(i8).  Engine manufacturers claimed  that the
 engine failure was caused by faulty oil, but it was difficult and expensive  to
 prove so they settled most warranty claims.  Due to this problem, engine
 manufacturers wanted a stronger voice in  the certification  system, quality
 assurance of oil, and a decrease in their warranty claims due to faulty oil.
       After MVMA proposed NALSAS, it circulated the document to industry
 and interested parties for comments.   API and oil marketers questioned the
 need for a second system and attacked NALSAS for attempting to improve the
 API  certification  system.;  Despite  complaints from  most  major oil
 manufacturers concerning  the  complexity of two certification systems, the
 tripartite and NALSAS, MVMA  decided to  move forward  with the  NALSAS
 program. API decided to remain with  the tripartite system and not work with
 MVMA until  certain  events changed  the  arena.  First, Exxon was caught
 falsifying data in the oil certification  process; then, the military  threatened
 API with suit for  faulty oil that displayed the  API certification label; and
 finally  the  military threatened to  replace  their  military specification
 requirement for oil purchases with the NALSAS program.
       In response to these events, API met with MVMA in early 1991 to discuss
 engine oil licensing/certification, and the possibility of developing  a single
 system.  This was an attempt by API to alleviate MVMA's concerns relating to
 the current  tripartite  system  without sacrificing its  own voice   in  the
 structure. As a result of these  meetings, MVMA  proposed an alternative to
 NALSAS and after modification, it was  approved by  the  API  Lubricants
 Subcommittee(i9).
       The International Lubricant Standardization and Approval committee
 (ILSA) developed a standard to include the performance requirements along
 with  chemical an physical properties of  those engine oils  that  vehicle
 manufacturers may deem  necessary  for  satisfactory equipment life and
 performance.
(18)   MVMA stated "the marketer of substandard engine oil has been the cause of the problem and has probably
been able to avoid any liability because identifying the source of harm is difficult"

(19)   On November 15,1991, an MVMA/API Task Force developed the API Engine Oil Licensing and Certification
System (EDITS) and circulated it for comment Twenty-six sources filed comments and the Task Force sent responses to
each. On March 09,1992, the Task Force proposed the second draft of EOLCS and circulated it for comment The final
document is now being completed and should be in use by 1994.
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oil condition monitoring

                           HISTORY OF OIL DRAIN INTERVALS

        In 1928, the Ford Model A's recommended drain interval was 500 miles. 3 From 1946 to
1967, advances in oil quality resulted in varied oil drain interval recommendations. Not until "1968,
when API introduced Service SD, we're the oil drain interval recommendations of the four major
engine manufacturers similar.
        Early on, consensus was that engine wear, control of engine deposits and resistance to
oil thickening, limited the ability to extend oil drain intervals for passenger vehicles, but a 30-year
study completed in 1976 concluded that technology was available to achieve longer drain
intervals than recommended in present automobiles. 20  The increase in OCI's since 1928 were
due to the development of superior lubricants. Oil drain intervals do not correlate with
improvements in oil quality,  but with emission controls, service/design factors, and test updating.
As early as 1956, it was known that controlled field tests were the key to understanding the
variables involved in extending oil drain intervals, because there are no engine tests to define oil
performance in extending drain service.
        In 1959, the populace believed that oil was disposable and that frequent oil changes
could solve engine wear.  For example, in  1961, it became policy that improved engine
performance could be obtained by more frequent ojl drains of top quality oils. This would assure
engine performance and create more of a market for oil manufacturers.
        From 1953 to 1963, new additive technology and definition of oil quality  through
sequence tests contributed  to doubling the oil drain interval. Lab tests have led in the field of
formulation of high quality motor oils that provide satisfactory lubrication to today's engines in
normal or severe service conditions.
        The requirements of unleaded fuel in 1975 made it feasible to extend oil drain intervals.
In tests done in 1963 and 1976, it was concluded that extended oil life should be base on new
additive technology to counteract the increased stress on lubricants and to meet new
performance requirements.
        Oil viscosity increase may be a significant limitation in extending oil change intervals.
Engines today are under more stress from environmental and operational factors. Extending the
drain interval is a constructive way to deal with oil conservation, waste oil disposal, and the
consumer's desire for less frequent rnaintenance.
        Despite the improved quality assurances in the new API/MVMA oil certification system,
engine manufacturers claim  that this will not allow them to extend the oil  drain interval recommend
in the engine warranty because 1) it is only an assurance, not an improvement in the quality of oil,
2) an increase in the manufacture of more fuel efficient vehicles will put  more stress on the oil, and
3) the stricter clean air emission guidelines might put more stress on the oil. Although these
points raise valid questions, they are not necessarily obstacles to extending
       20
               Recommended normal oil drain intervals in 1976 were:
American Motors        5000 miles or 5 months
Chrysler.               5000 miles or 5 months  >
Ford                  5000 miles of 5 months
General Motors  7000 miles or 5 months
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 the life of oil.  The new certification system will not only result in a higher percentage of valid Oil in
 the marketplace, but will improve the quality of oil by requiring extensive oil testing, MTAC
 methodology, and aftermarket tests. 21
        In improving and assuring the quality of oil in the marketplace, the new certification system
 will help, not hinder, the engine manufactures in meeting the need for more fuel efficient
 vehicles. The improvement in lubrication would offset any requirement for greater fuel efficiency
 and allow engine manufacturers to relax an already stringent oil change interval recommendation.
 The same point can be made for meeting stricter clean air emission guidelines.

        The current oil change interval recommendations by engine manufacturers are to short'
 and only allow flexibility due to driving conditions even though there are several factors that affect
 oil drain requirements. 22 Monitoring the condition of the oil is necessary to protect the engine.
 Oil should bee changed before the point of contamination.  Since drivers can't tell when that point
 occur, the automobile manufacturers recommend oil change at 1) a"certain time or 2) a maximum
 mileage limit, whichever comes first. The API recommends that motor oil be changed at regular
 intervals, with a minimum of what is prescribed in the car owners manual.  Since driving conditions
 vary, a driver must pay attention to the severe service  recommendation.
        21                         ;
                Under this methodology, a normal oil whose performance would pass 98% of the time
undes- the old guidelines would now only pass 90% of the time under the new system. Therefore, the oil
manufacturer can improve the margin of error in performance or accept the risk of failing testing and have to
pay the expense of reformulating the oil. The result will be significantly better oils in the  marketplace.


        22
                Engine design effects oil requirements. Historically manufactures built small engines with
high outputs. The increased output was obtained through higher compression ratios which forced the oil to
minimize the deposit formulation and made lubrication essential. Lately, due to exhaust controls, unleaded
gas has been used which  is a tower combustion. Also there is an increase in fuel efficient cars which have
smaller engines. These changes have increased the demand on lubricating cite because under the hood
temperature is greater. Soot and oxidation can occur when engine is used in cold temperature or city
driving.  Hot temperature and high speed driving can also cause problems. Driving habits effect oil
lubrication and drain intervals.  Today people do more stop and go driving and the engine does not get to
warm to operating temperature, therefor the oil is easily contaminated.  (63% of trips are  less than 6 mites)
Highway driving is ideal, but if conditionsiare too hot then oxidation can occur. Today's driving conditions
require oils to use additives. A driver must change the oil as recommended, with particular attention to the
type of driving conditions that are defined as severe and require more frequent oil changes.
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