When considering the addition of standby generators, you must recognize they are an emission source. Many commercial and industrial customers may already have emission sources permitted by a local, State or Federal authority. In some jurisdictions, emergency only generators and generators below certain ratings (usually in horsepower) are exempt from permitting. However, if your facility or your application will not be exempted, you will need to consider how to apportion emissions between existing sources and the generation in order to achieve an optimal level of environmental modeling for your permit. Standby generator environmental permitting is not rocket science, but it must be approached carefully.
In many jurisdictions, the permitting authority precludes any construction or even receipt of the generators at the proposed site until the permit application has been reviewed and a permit issued. In some jurisdictions, a two-step process for standby generator environmental permitting is used where a construction permit is issued first along with a subsequent operating permit once the criteria in the construction permit has been satisfied.
Depending on the capabilities of the permitting authority and its backlog, it may take:
• 30-90 days to obtain a basic permit;
• Up to 6 months for a more complex Title V permit; and
• 12 months or more for PSD permits.
The bottom line is that you must recognize that standby generator environmental permitting will impact project schedules and you should plan ahead.
You will also need to consider the impact of recently enacted RICE/NESHAP regulations. Depending on your application and the age of your engine, your installation may be required to install an Oxidation Catalyst and be subject to continuous monitoring. You will likely also be subject to specific maintenance and operations criteria and required to file reports with your permitting authority.
While such an installation is usually fairly straightforward, it can be a distraction from your other duties, particularly if you only have a small number of engines. IEA has installed Oxidation Catalysts on 50 engines in its fleet and has acquired a significant level of expertise in this area. IEA has worked with the US EPA during the installation and testing of these units and has already solved most of the problems that you will face when implementing one of these installations.
IEA can assist your company in determining permitting impacts, permitting applicability and can work with your environmental staff to prepare and submit the necessary permit applications on your behalf. In circumstances where it is called for, IEA can work with its environmental consultant to prepare the necessary emission point computer modeling accepted by the permitting authority.
Contact IEA with any questions related to your standby generator environmental permitting or RICE/NESHAP needs.