Emergency Generators – are you in compliance?

Operation of emergency generators can trigger a number of environmental compliance obligations. Generators that operate using diesel fuel can trigger the SPCC (spill containment) obligations depending on the size of the fuel tank. These generators can also trigger air permitting requirements including operation and record keeping requirements.

The majority of my clients have an emergency generator on site. Many maintain them appropriately and keep the required records, but sometimes these requirements can slip through the cracks. Facilities should be aware of the requirements that apply to generators and ensure they are documenting compliance. The potential consequences of non-compliance include inspection violations, fines, and required reporting in annual compliance certifications.

DOES YOUR FACILITY HAVE AN EMERGENCY GENERATOR?

The first step is to determine if your facility has generators on site. This may seem obvious, but I have seen several instances where a facility’s environmental team was either unaware they had a generator or did not know the specific requirements that applied to the units. I have also seen generators installed without the environmental team’s knowledge. If you are unsure, ask your maintenance department to verify.

ACTIONS TO BE TAKEN IF YOUR FACILITY HAS ONE OR MORE EMERGENCY GENERATORS

1. Determine what type of engine drives your emergency generator.

Find out when the unit was manufactured, what type of fuel it uses, and the unit’s horsepower rating. This information is often on the nameplate of the unit.

2. Determine if your emergency generator must be permitted.

Depending on your state and its operational activities, your generator may or may not require an air permit. This is a state-by-state determination since each state has its own rules for handling emergency generator permitting. Some states may have a general permit for emergency generators at facilities that would otherwise not have an air permit. Others may have regulations that apply beyond the federal requirements.

3. Determine what requirements apply to your generator(s).

Based on the above information, the generator will be subject to parts of 40 CFR 60, Subpart JJJJ, 40 CFR 60, Subpart IIII, and/or 40 CFR 63, Subpart ZZZZ. These regulations are referred to as the RICE MACT (Reciprocating Internal Combustion Engine Maximum Achievable Control Technology).

WHAT ARE THE “NEW” OR “EXISTING” GENERATOR CATEGORIES?

The manufacturer date will determine if your emergency generator is considered “new” or “existing” with respect to the requirements. For example, a generator with a compression ignition (diesel) engine is considered new if it was manufactured after April 1, 2006.

“New” Emergency Generators

For most new units, owners achieve compliance by purchasing an engine that is certified by the EPA and by installing, configuring, operating, and maintaining the engine per the manufacturer’s instructions. To comply with regulations, it is necessary to maintain records of the certification and maintenance conducted.

If a facility that is already classified as a major source installs a generator with greater than 500 horsepower, EPA requires the facility to submit an initial notification to their agency. This is the only type of emergency generator that requires the notification submittal.

“Existing” Emergency Generators

Compliance for “existing” generators can be achieved by adhering to the following requirements and specific maintenance items on schedule:

Maintenance Items (Applies to all emergency generators except >500 HP at major sources)

• Change oil and filter and inspect all hoses and belts every 500 hours of operation or annually, whichever comes first
  • Alternately, the operator may use oil an analysis program instead of prescribed oil change frequency
• Compression Ignition (diesel) – Inspect air cleaner every 1,000 hours or annually, whichever comes first
• Spark Ignition (natural gas, gasoline, propane, etc.) – Inspect spark plugs every 1,000 hours or annually, whichever comes first

Compliance Requirements

• Operate/maintain engine and control device per manufacturer’s instructions or owner-developed maintenance plan
• Emergency engines must have a meter and record hours of operation
• Retain all maintenance records

OPERATING HOURS

Each emergency generator (except >500 HP at major sources) must have a non-resettable hour meter installed. This is critical to accurately record the hours of operation. For each operating event, owners must record the hours and distinguish if the event was used for emergency response or in a non-emergency situation.

• Each generator may be operated for up to a maximum of 100 hours per calendar year for maintenance checks, readiness testing, emergency demand response, and non-emergency usage.
• A limit of 50 of those hours can be non-emergency situations.

If either threshold is exceeded, EPA will reclassify the generator as a “non-emergency” unit, causing it to be subject to a different set of regulations including possible performance testing.

MAINTAINING COMPLIANCE

The most difficult part of emergency generator compliance is determining into which category your unit falls. Once you have made that determination, maintaining compliance is rather straightforward. You can conduct the prescribed maintenance at the established frequencies and record the hours of operation distinguishing between types of use.

The key is to maintain sufficient records demonstrating compliance with each requirement. This will help ensure your facility is in compliance with the RICE MACT generator requirements and avoid violations and possible fines in the future.

Please contact us if you have questions how these requirements may apply to your facility.