Initial Generator Environmental Permitting
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 specific ratings (usually in horsepower) are exempt from permitting. However, suppose your facility or your application will not be exempted. In that case, you will need to consider how to apportion emissions between existing sources and the generation to achieve an optimal level of environmental modeling for your permit. Standby generator environmental permitting is not rocket science but 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 standby generator environmental permitting is used where a construction permit is given first and subsequent operating access once the criteria in the construction permit have been satisfied.
Depending on the capabilities of the permitting authority and its backlog, it may take:
• 30-90 days to obtain an essential permit.
• Up to 6 months for a more complex Title V permit.
• 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 accordingly.
You will also need to consider the impact of 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 need 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 machines 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 you will face when implementing one of these installations.
IEA can assist your company in determining permitting impacts and can work with your environmental staff to prepare and submit the necessary applications on your behalf. When it is called for, IEA can perform with its ecological consultant to prepare the point of emission required by computer modeling accepted by the permitting authority.
Contact IEA with questions about your standby generator environmental permitting or RICE/NESHAP needs.