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January - February 2014 25
The documentation requirements for this rule give the EPA
and state environmental agencies the authority to request
compliance records for a period of up to five years, so owners/
operators must validate that the work practices have been imple-
mented and be able to supply substantiating records in a timely
fashion should a request be made. This may also be true for
other recordkeeping and reporting requirements.
Some industrial oil analysis labs such as TestOil offer
NESHAP-compliant reports to meet stationary engine oil anal-
ysis needs. These reports provide an analysis rating of
"compliant" or "non-compliant." Non-compliant oils will be
recommended for resampling to confirm the original data
reported. Alerts are based on test parameters for base number
or acid number (depending on the engine), viscosity and percent
water content. As per the regulations, operators will have two
business days to change their oil or take the unit out of operation
upon receipt of the non-compliant sample rating.
PArAMETEr CONDEMNING LIMITS
Base Number (CI
rICE only)
<30 percent of the BN of the oil
when new
Acid Number (SI
rICE only)
Increases by more than 3.0 mg of
potassium hydroxide per gram from the
AN of the oil when new
Viscosity
Changed by more than 20 percent from
the viscosity of the oil when new
% Water Content
by Volume
>0.5
Figure 4. The NESHAP ZZZZ oil analysis protocol
outlines specific parameters and condemning limits
for oil changes.
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