SVreX wrote:
I am familiar with RICE NESHAP. As far as I am aware, it is applicable to units 200kw or larger, and will not be fully implemented until June 2013 IIRC. We'll be finished by then.
RICE is both a major and area source NESHAP, and applies to stationary engines only (though the definition of stationary is mighty loopy, as they can be on wheels). It goes mighty small in the area source application. Parts of the regulation have been stayed, but not the applicability parts.
Very significantly, RICE does not apply to truck engines (as I recall, that's what you're proposing to test). Not even truck engines taken out and running on a test cell. But "install" them (a very significant and important word here), and it does apply.
The test cell NESHAP (PPPPP) is for testing truck engines. This one is a major source NESHAP (10 tons per year of any one HAP, 25 tons per year combined of all HAPs). But it is potential to emit based for determining applicability, and your PTE will likely be over the limit. Though you could take a synthetic minor limit and hopefully stay under the applicability threshold. However, there is also the 1/2 actual rule of thumb used by EPA and the states. If your actual emissions are less than 1/2 the applicability, you do not need to take synthetic minor limits to avoid the rule. You're simply too small.
Pay close attention to the applicability of both NESHAPS (ZZZZ and PPPPP) and the NSPS (JJJJ and IIII). The definitions of when an engine is installed, or is mobile. You want to be very well versed on these applicabilities. Don't play smug and cute here. For it's not if you think you're not subject, it's if the regulators think you're not subject. I.e., you can think your tax exempt, but if the IRS doesn't agree, you lose.
Assuming you do "install" an engine, so RICE applies:
Rice intertwines with the various NSPS (JJJJ and IIII for example) and goes down to 5 hp. Most of it is engine HP triggered. Kw (electric) actually doesn't come into play (though a number of outside guidance documents incorrectly connect the dots to electric power).
End use triggers different requirements (electric generation vs direct mechanical power, emergency vs non emergency, where the electricity generated goes, hours of operation per year, etc). This is where I was cautioning you about how you load your unit. Don't think not selling electricity back to the grid exempts you from RICE, it does not, it just changes what requirements you are subject to (NSPS requrements as well).
Modify the engine under RICE (change fuel, change operating parameters, alter maintenance from OEM spec, retune the engine, etc), and you now essentially have to CARB certify the new configuration. This is one of the things I think you're going to run afoul of, from your description of what you're testing for and hoping to optimize.