This year was the first in my career in which EPA issued a Notice of Violation to a client due to non-compliance with a facility’s emergency generator maintenance and records.
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.
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.
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.
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.
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).
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)
Compliance Requirements
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.
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.
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.
Contact Cornerstone for help regarding emergency generator inspections and RICE MACT compliance.
Chris Koucky joined Cornerstone as Environmental Engineer, bringing years of industry experience in automotive, manufacturing, and tool and die. He currently assists our clients with air compliance services, Form R requirements, various permit applications, and Work Practice Plans to eliminate improper waste management, reduce facility air emissions, and/or minimize the chance of a chemical release.