4 Steps to Managing Emergency Generators for EPA Engine Compliance

The RICE National Emission Standards for Hazardous Air Pollutants (NESHAP) offers few exclusions from applicability.

But the facility type allows some emergency engines at commercial and institutional facilities to be excluded from the RICE NESHAP, making it very important to confirm the facility type you are evaluating. Facility types include commercial, institutional, and industrial. The EPA guidance memo listing NAICS codes can help define your facility type.

The source type refers to the facility-wide potential to emit hazardous air pollutants (HAP). Area sources are defined as having the potential to emit fewer than 10 tons per year of any single HAP and fewer than 25 tons per year of total HAPs combined. Major sources are those equal to or greater than these levels.

You should evaluate your existing facility air permits and emissions calculations to verify whether you may be a major source of HAPs. Major sources of HAPs require Federal Title V air permits. Requirements for emergency generators at HAP major sources differ from those at area sources, and the great majority of facilities will be non-major or area sources of HAPs.

Fuel type is critical in determining regulatory requirements. Most emergency generators burn diesel fuel, natural gas, or propane. As a side note, diesel or oil-fired generators have fuel storage tanks that may have tank registration requirements and require Spill Prevention, Control, and Countermeasure (SPCC) planning. Remember to review for other potential environmental impacts, such as this, for your installation.

The purpose of your engine is also critical. Emergency and non-emergency engines have different requirements. For portable units, you must determine if they may be considered stationary, depending on how long they will remain at a location.

The RICE requirements are complex and challenging to navigate. Carefully step through the requirements, keeping your specific engine factors in mind. If you don’t have a construction date, you can use your engine model year to help you estimate.

Existing engines will be subject to the NESHAP unless excluded as an engine in an institutional facility with a model year before 2005. New engines must comply with the NSPS for compression ignition or spark ignition. Two engines with the same power rating but built at different times will have entirely different requirements. All of these factors may affect what RICE requirements apply to your engine.

Given its less stringent requirements, you may desire to meet the “emergency” definition. However, understand that the “emergency” definition limits demand response opportunities. If you wish to participate in non-emergency demand response, purchase a non-emergency generator.

Noncertified new engines may have stepped-up requirements, such as stack testing; check your specs carefully – be wary of terms such as “compliant capable.” This does not mean certified. Certified engines will have an EPA Family Number.

Navigating each of these rules is complicated. Use the factors in Step 1 to help understand and evaluate the applicable requirements. The EPA offers online guidance pages, including “Regulation Navigation Tools,” which you may find helpful.

While there may be commonalities, each state and some localities will have special requirements for RICE engines. This step is also where air permitting requirements will come into play.

There is too much variability across the U.S. to provide in-depth guidance for this step. Most states or localities will have regulatory codes that must be reviewed for applicability for an emissions source, such as a RICE engine. There is no shortcut to evaluating state and local requirements for a specific engine. In many cases, an air permit, if required, must be issued and “in hand” before initiating the site work for installation.

Create a summary of regulatory compliance information resulting from your engine evaluation. Feel free to reach out to me if you would like a copy of an example summary of air quality requirements for an emergency diesel engine.

A useful summary will document engine factors critical to the regulatory review, summarize the federal requirements, include a reference to the EPA Family Number, and give a reminder of the limitations of hours of operation as an emergency engine. It also will address the state agency’s environmental regulatory requirements, including permit coverage.

After completing a thorough review and following steps 1-3, you will have the findings necessary to take action to comply with requirements. An emergency generator operation log is required for nearly every engine. An example can be provided by request. Feel free to reach out to me for a copy.

Other actions may be specific to state or local requirements and may include applying for a permit. However, many agencies have options for registration or general permitting that may reduce the permitting process burden.

Be sure to keep other mandatory records based on the requirements determined in your evaluation. Proceed with submitting a permit application if it is required for your generator as soon as possible. If you are proposing a new engine, these steps should be completed well in advance, perhaps 3-6 months before installing it.

As you may realize, these steps require a reasonable amount of time and effort. Baking them into your pre-construction project schedule can help ensure you build methods of compliance and receive the required permits before installation.

Gannett Fleming has the experience to guide you through this process and assist you with your facility’s emergency generator engine compliance. Whether you partner with us or go it alone, achieving compliance can help prevent the dreaded notice of violation or added costs and delays to your project. Learn more about our environmental, regulatory, and public outreach services and the value we can bring your organization.