epa/cogen/hybrid/exemptions etc

[mobile_bob]

so here is a theory i would like to run up the flagpole, and bear in mind i have not verified everything yet

a diesel engine that is tier 3 compliant by the epa and is installed in a truck has a set of exhaust gas parameters that
the engine must meet to remain compliant, however

the same engine installed in a diesel electric hybrid truck is reported to have dramatically lower emissions,based on the fact
the engine is only allowed to run at or near peak operating conditions, no low load, no load (idling) etc, where the batteries
and electric motor does the job.

now we all know the engine while running has to put back what was used by the motor during no load, low load, conditions
but it does that again under ideal peak load conditions.

navistar has built an engine that will meet tier 4 as a hybrid application  engine, requiring no urea after treatment.

so, here is the theory

if you take a quality single cylinder diesel that has all the proper stuff, (tstats, DI, cat, etc) and allow it only to run at
or near peak load (or which load that it produces the lowest emissions) and use it to charge a battery bank (much like a hybrid)
and then convert back to electricity via an inverter (much like a motor in a hybrid truck) you essentially have dramatically reduced
the emissions of that engine "in that specific application"

this may be the basis of a legal theory that might hold up and allow for an epa compliant genset, also...

there is movement to have the language changed from rating the engine  used in cogeneration to btu output converted rather
than crankshaft mechanical kwatts, this if it ever happens would be huge for the cogeneration game.

couple the two examples, (hydrid application and cogen reclassification from kwatt mechanical to btu's recovered) and we
will have an epa compliant engine.

what i am thinking is, with all the work being done by the big boys with reclassification, hybrid technologies etc, there is always
little opening left behind that are too small to exploit by the big manufactures, because of the micro market, but large enough for
us to stretch out in. its the rule of unforeseen consequences in play.

i am researching this hybrid application of the epa regs and am trying to determine exactly how they factor the reduction in emissions
based on simply using the engine in a hybrid application.

it stands to reason that for instance a 6/1 running all day long at 1 kwatt is going to put out much more polution than the same
engine running at 3kwatt output running only 1/3 of the time, that reduction in emissions has to be very substantial in my estimation.

further if they allow a reclassification for engines used in cogeneration to claim the full recovered btu's against the emissions produced
you just cut the emissions to less than 1/3 of a non cogen (generator) application.

so what is 1/3 or 1/3 ?  ans 10.9%

thats nearly a 90% reduction in emissions of a the same engine driving a genset and running all day to provide 1 kwatt per hour of electricity.

the key here to be taken seriously is probably to base this on an engine that is inherently as clean as is available, maybe a listeroid?
maybe a changfa DI, maybe its a redstone? that we will have to find out won't we, then...

build it into a cogenerator that has heat exchangers on both the coolant and exhaust systems, has a tstat controlled closed cooling system, probably an egr with some sort of basic control, a particulate filter, and a catalytic converter (which is not a bad thing
considering if it is doing its job it is improving the exhaust heat quality for the heat exchanger anyway), have it charge batteries
and feeding an inverter to cover low, and part load operation, then

we present it to the epa with the proper educational materials clearly illustrating how the connection to hybrid technology is working here
and how the recovery of waste heat should be included into the calculations of the unit output.

i think it could be argued from a legal standpoint successfully, the problem remains though how to get up the funding to have the unit
tested by the epa in their lab. that would likely require a petition signed by as many of us and other interested parties presented to
an agreeable congressman that could be pursuaded into attaching a rider to some other bill mandating the epa to provide low cost testing
to research groups that are either non profits or low profit concerns.

all we would be asking for is a law that states that the epa must accept for testing a single unit from a non profit or maybe a company
that has less than 10 employees and under 50 grand in taxable profits per year, and charge a flat fee of perhaps 1000 dollars to do the
certifaction testing.

think about it?  seems plausible to me, and we all hear all the bullcrap from our representatives how they are all in favor of AE, research and development of new technologies blah blah blah.... who knows?

if we could only get some language inserted as a rider that would direct or mandate the epa to have to accept single engines for testing
from R&D concerns that alone would be a huge step in the right direction.

pipe dream? probably

but thats ok, i have been told many times over the years this or that won't work, only to find out later that yes it can work, if you just
ask the right person the right question at the right time.

i am thinking we find a congressman, draft up the language we need, and start a letter writing campaign and see if it can be done.

who knows with those guys in washington all worried about reelection and having their noses buried in healthcare, the war, bailouts
global warming etc,, maybe we find one that will do the deed. maybe we find "one" thinking man or woman that represents us in washington that is smart enough to understand what is needed here. after all this is one rider that will not cost the government
any money so it won't upset someones budget.

thoughts?

bob g

[EBI-WPO]

Bob,
I for one, applaud your efforts and devotion to the cause. I don't think most people realize the implications of the EPA on EVERYONES life. It's uncomfortable now, it will only get worse..... unless something like you are suggesting can slip into place. Please don't give up your efforts, while waiting for others to "wake up and smell the coffee". I, and hopefully others will join in with what effort is possible, and hopefully, the goal could be realized. This is the only viable way I see to "win" at the present system.

Thank you again for your efforts and foresight.

Terry

[rcavictim]

I nominate Bob G for congressman.

Bearing in mind. If the opposite of pro is con, what is the opposite of progress?

Seriously.  That idea of making it law that individual or small research has a chance for testing and potential contribution to the large picture which is such a mess now, is a very good idea!  The downside might be the signal to noise ratio of these small researcher ideas.  There are a lot of crackpots out there like in the free energy camp for example who might 'discourage' the EPA from accepting any responsibility to play ball here.

[veggie]

Good idea bob. Well thought out.

The problem is adherence and verification.
If someone say's to the governing bodies "I'm importing an engine for a CHP system which is exempt under EPA ###", it would be impossible for the gov. to follow up and ensure compliance. For that reason, they would never open that door in the first place.
Small potatoes for them. They don't really care if one guy wants to build a CHP system, so they won't invest the time.
Unfortunately, there is not enough scale in this area yet. Eventually CHP will be the norm, but for now the non-complying products will be shut out.
Dealers like Central Marine Diesel could not certify that the engines they import/sell are going into CHP systems so it would be difficult for dealers to import based on this premis.
This leaves the individual to deal with the authorities for imports. Most difficult.

veggie

[M61hops]

Great idea Bob!  And veggie, maybe the Feds wouldn't care because the total #'s of engines would be so small that it won't affect air quality in almost any city, at least for many years until every house comes with one,  Even then, we should be able to get them to burn pretty darn clean if compared to coal fired electricty?  Or wood stoves?      Leland

[JohnF]

I like Bob's approach to this - and it seems to make sense.  But I have noticed a very worrying trend in law enforcement lately (and I'm a retired cop) where police/government (whatever agency you want to insert here) now tends to pick on the "little guy" because it is easier to obtain convictions and at the same time produce statistics showing what a great job they are doing.  They have just about stopped going after big targets (such as GM or Toyota) in favour of dragging "Joe Blow" into court, using the awesome power and money of the state to essentially batter an individual into submission.  Generally they get a fine that far exceeds the "crime" and they use this to intimidate other "joes".  I'm just not so sure they will not pick on an individual, it is just so much easier for "them".

[Westcliffe01]

Gentlemen, the EPA regs apply to those who wish to develop and sell diesel powered equipment.  It also applies only to equipment produced after the legislation takes effect.   A genset produced now could be legally sold to someone in 2012 when the Tier 4 regulations take effect, since it was compliant with all regulations at the time it was built.  Importers have to be compliant when their goods hit the dock, but if they stockpile millions of Tier 3 gensets or the like prior to 2012 and sell they years later, they would be compliant.  Its only when the engine is put into a piece of equipment and re-sold that things get stickier, since the integrator is responsible for meeting current regulations at the time of the build.   This is why surplus center is able to stock and sell "replacement engines" for older equipment which is not compliant with current regulations.

There are individual states and cities that take things a step further and impose tougher requirements than those provided federally by the EPA.  The best advise is generally not to live there...

Seriously though, there are plenty people out there with emissions measurement equipment and at these power levels your dynamometer consists of the generator and a bank of floodlights....  Unless anyone is wanting to get into production though, I don't see the point.  Our money as DIYers is better spent buying and rebuilding automotive or agricultural diesel engines and putting the rest of the system together effectively. 

One of the problems we have is simply the lack of availability of small turbodiesels (1.0 to 2.0L displacement).  The ones we do have are scarce (Tdi) and therefore dear.  Furthermore, the Tdi's have an electrically controlled pump and no-one has stepped up with a controller intended for stationary application.  I am focusing on this particular gap in the market, since I know many who would love a Tdi engine in their small pickup (like the 90's Toyotas), besides the potential use for stationary application.  It would be nice if we had access to Toyota and Nissan equipment, but these companies have had no diesel engine in the US for so long it is impractical as a starting point for a project that might last another 30 years.   Sooner or later, all that will be available will be common rail and a non automotive controller will be required for those too.  That will be quite a challenging job, since every detail regarding fuel pressure, start and stop of injection, number of injection pulses etc have to be controlled digitally.  At least with the Bosch in line pumps all you are doing is biasing the basic setpoint...

Basically, as long as we "recycle" automotive or agricultural engines for our applications, the feds are highly unlikely to be of any concern to us whatsoever.  Particularly when the nearest neighbor is a 1/4 mile or more away...

Regards
Keith