Air Permitting:
Municipal Facilities
with
Emergency Generators
Sam Cotter, P.E.
sam.cotter@cardinalengineers.com
7060 S. Yale, Suite 603 | Tulsa, OK 74136
Introduction

Generators are located at our utility pumping stations,
treatment plants, and civic buildings

Many generator installations require air permits


Local utility authorities may be unaware of permit requirements
Air compliance is a dynamic, developing field

Regulations have been recently implemented or modified
2
Outline

Introduce regulatory guidelines

Evaluate affected sources

Permitting requirements

Example scenarios

Other environmental considerations and permits
3
Stationary engines:

Generate backup power in case of an emergency

Generate power with digester gas

Engine-powered air compressor

Engine-powered water pumps

Electrical peak shaving
4
NESHAP
NSPS

New Source Performance
Standard

40 CFR 60

Subpart IIII

Subpart JJJJ

New Engines

Many other subparts
affect non-engine sources

National Emission
Standards for Hazardous
Air Pollutants

40 CFR 63


Subpart ZZZZ
New engines

Major sources affected

Existing engines

Many other subparts
affect non-engine sources
5
Definitions/Acronyms

Criteria pollutant: NOx, CO, VOC, PM

Emergency: Provides power during an emergency situation,
when utility power is interrupted

HAP: Hazardous Air Pollutant

NESHAP: National Emission Standards for Hazardous Air Pollutants

NSPS: New Source Performance Standards

RICE: Reciprocating Internal Combustion Engine

SI: Spark Ignition – Natural gas, gasoline, propane, digester gas

CI: Compression Ignition – Diesel
6
Definitions/Acronyms

“NEW”: Dependent on regulatory definition, date of construction

IIII: Governs compression-ignition sources constructed after 7/11/2005

JJJJ: Governs spark-ignition sources constructed after 6/12/2006


Applicability dates are dependent on size of engine
ZZZZ: Governs existing engines operation and maintenance

New & Existing, depending on area vs. major source

Existing: Constructed prior to 6/12/2006 for area source
7
“Why should I care?”

Improve air quality

You have a standby generator, or you know someone
who does

Compliance is driven by regulatory pressure

Mitigate risk/exposure to permit violations
8
Process of air compliance


Applicability analysis

“Am I subject to regulation?”

“Do I need a permit?”
Facility permitting


Permit application, calculations of emissions
Compliance assurance

Ongoing maintenance, testing, and report
9
“Do I have affected sources?”
Engine Characteristics
Stationary
Engines
Mobile
Engines
Compression
Ignition
Emergency
2-Stroke
4-Stroke
Non-Emergency
Rich burn
Spark Ignition
Landfill/Digester Gas
Lean burn
Important Engine Data

Horsepower

Date of construction (existing vs. new)

Annual hours: Emergency / Non-emergency

Emission certifications

Area vs. Major Source for HAPs
10
HAP: Major vs Area source

Area vs. Major affects compliance with NESHAP rules

Many small standby generator installations will most
likely fall under area source

Major: > 10 TPY HAP, or 25 TPY total HAPs

“Remote area”
11
NESHAP
NSPS

New Source Performance
Standard

40 CFR 60

Subpart IIII

Subpart JJJJ

National Emission
Standards for Hazardous
Air Pollutants

40 CFR 63

Subpart ZZZZ
12
“Am I subject to a regulation?”
Compliance determination
1.
Classify engine by key factors and engine data

Stationary?

Emergency or non-emergency?

New or existing?
2.
Determine if your engine is subject to NESHAP and/or NSPS
3.
Determine if source is area or major
4.
Determine compliance requirements
5.
Review compliance dates and address any noncompliance.
13
“I’m subject to regulations, now what?”
Achieve Compliance

Review compliance dates and address any
noncompliance

Submit any applicable initial notifications

Install controls

Self disclosure for any noncompliance identified


Communicate with state regulatory agency
Possible compliance requirements:

Install controls, meet compliance requirements,

Stack test

Engine maintenance
14
IIII Compliance
Newer Diesel Engines

Is the engine certified?
Emergency engines:

Operate control devices per manufacturer

Non-resettable hour meter

Diesel particulate filter: monitor backpressure
15
Certified engine

Manufacturer certifies to a specified emission
standard

Engine must be installed/maintained per
manufacturer specifications

For new spark-ignition (Subpart JJJJ), noncertified engines require initial emission test
and testing every 8,760 hours or 3 years
(whichever comes first)
16
IIII Emission Standards

Refer to tables in regulation
Table 1:
Emission Standards for Stationary Pre-2007 Model Year Engines With a
Displacement of <10 Liters per Cylinder and 2007-2010 Model Year Engines >2,237 KW
(3,000 HP) and With a Displacement of <10 Liters per Cylinder
17
JJJJ Compliance

Spark Ignition (Natural gas, gasoline, propane, digester gas)

New engine:

The easiest way to comply with JJJJ: buy a certified engine

Often requires a catalyst to meet emission limits

Stack testing


Every 8,760 hours or 3 years, whichever comes first
Engines < 25 HP must comply with other federal regulations

40 CFR 90, can include certification
18
JJJJ Emission Standards
19
ZZZZ Compliance

Variables affecting compliance requirements:

Size and type of engine

Area vs. major source for HAP

New vs. Existing


New engine at an area source meets ZZZZ by complying with 40
CFR 60 subpart IIII or subpart JJJJ
Assuming existing emergency engine, area source:

Oil change / maintenance annually or by hours of operation

Non-resettable hour meter

Limits on operational hours under some conditions
20
40 CFR 63 Subpart ZZZZ Table 2d:
ZZZZ

Requirements for Existing Stationary RICE Located at Area Sources of HAP Emissions
See tables for
compliance requirements
21
“How do I maintain compliance?”
Continuous Compliance
Subpart IIII

Operation and maintenance per manufacturer guidelines

Maintenance of control devices
Subpart JJJJ

Operation and maintenance per manufacturer guidelines

Stack testing
Subpart ZZZZ

Maintenance requirements
Annual Air Emission Inventory

Permitted facilities are required to report annual air emissions
22
“Do I need a permit?”
Generally:
If federally
applicable
requirements
apply

Permit may
be required
Federally applicable requirements:

Subpart IIII

Subpart JJJJ

Subpart ZZZZ

Requirements vary slightly by state

Evaluate on a case-by-case basis
23
Oklahoma permitting

General permit for area source NESHAP facilities and
small NSPS facilities

Form 100-360

Existing facilities subject to NESHAP may be
permit-exempt if no modifications have
been made

Contact: Oklahoma DEQ

http://www.deq.state.ok.us/aqdnew/index.htm
24
Louisiana permitting

Louisiana DEQ

Subject to LAC 33:III 311


311 permit is specific to stationary RICE
http://www.deq.louisiana.gov/portal/DIVISIONS/AirPermits
EngineeringandPlanning/RegulatoryPermits.aspx
25
Arkansas permitting

Arkansas DEQ Regulation No. 18

Section 18.301(B)(3) indicates certain
conditions where IIII/JJJJ/ZZZZ engines
may be exempt from permitting

Minor source general permit


Submit Notice of Intent form

Emission estimates
http://www.adeq.state.ar.us/air/branch_permits/perm
26
it_aps_inst.htm
“What if my engine is already installed?

May require self disclosure to regulatory agency
27
Case Study:

Cummins DQDAA

Date ordered: February 2012

Standby generator

476 HP engine, 250 kW generator capacity

Fuel: Diesel

Location: Norman, OK
28
Applicability analysis

Questions:

Stationary?
YES

Emergency?
YES

New vs. Existing?
NEW

SI or CI?
CI

Subject to NESHAP ZZZZ?
YES

Area source or major source? AREA (Maintenance requirements)

Subject to NSPS IIII or JJJJ? YES - IIII

Certified?
YES

What permit is required?
GENERAL PERMIT
29
Other regulatory considerations

Above ground tanks: Total facility oil storage > 1,350
gal, need SPCC

Underground fuel storage tank: Register with state
agency

Tier II reporting
30
Summary
1.
Stationary engines can be subject to federal regulations
2.
Regulatory applicability is dependent on engine characteristics
and date of construction
3.
Regulations may require maintenance, testing, and permitting
31
Compliance tools
Compliance determination quiz

http://www.epa.gov/ttn/atw/rice/output/quiz.html
EPA guidance for reciprocating engines:

http://www.epa.gov/region1/rice/
TCEQ resources with flowcharts for JJJJ and IIII applicability

http://tceq.state.tx.us/permitting/air/rules/federal/60/60
hmpg.html
KDHE Guidance documents

http://www.kdheks.gov/air-permit/CEtech_guidance.html
32
EPA Compliance of Stationary
Engines
at Water & Wastewater Facilities
Sam Cotter, P.E.
sam.cotter@cardinalengineers.com
7060 S. Yale, Suite 603 | Tulsa, OK 74136