Are you responsible for multiple sites in Wyoming and use fuel-fired engines to support your operations? You may not be aware of the option to apply for a “Fleet Permit” to cover multiple stationary engines, even if they are located at different sites across the state. With a Fleet Permit, companies can cover tens or even hundreds of reciprocating engines under a single permit. Covering multiple engines from different sites under one permit can save time and result in simpler management of compliance obligations compared to permitting each site individually.
Who Can Apply for a “Fleet Permit”?
Fleet Permits are most practical for companies that operate several sites with similar engines. This can include oil and gas production sites that use fuel-fired engines for lift compression to assist with gas production. A Fleet Permit can be used at:
- Oil and gas well sites with approved Applications for Permit to Drill (APDs) from the Wyoming Oil and Gas Conservation Commission (WOGCC)
- Sites that are already permitted for air emission generating activities (not necessarily engines) by the Wyoming Department of Environmental Quality Air Quality Division (AQD).
This restriction is to ensure that the property has already been evaluated for appropriate land use and that impacts to sage grouse and ungulates have been reviewed.
When applying for a Fleet Permit, it is important to note that the AQD will want to ensure that total horsepower at any one site is below a certain amount to manage the need to evaluate engine emission impacts via dispersion modeling or other approaches. There isn’t a firm limit for this total as it depends on AQD expectations and experience with other permittees, but in the past, it has been on the order of 2,700 horsepower. If you need that much or more at a particular facility, a fleet permit may not work for that site.
What permit conditions can I expect in a “Fleet Permit”?
There are several common permit conditions that can be expected to be found in a Fleet Permit.
- The date of “commencement of construction” must be reported within thirty days of commencement – for a fleet permit, this will mean placement of the first engine under the permit. This is so the AQD will know the permit has been activated.
- Permittees will likely be required to submit a notification within fifteen days of startup or shutdown/removal of each engine in the fleet.
- Each engine will be subject to certain emission limits, at least for NOx and CO and possibly for VOC and/or formaldehyde.
- Upon placement of an engine (including like-kind replacements), permittees will be required to complete initial performance tests and report results within thirty days of achieving a maximum design rate but not later than ninety (90) days following initial start-up.
- Ongoing testing will likely be required every 12 months.
- Each stationary engine and any emission control devices must be operated and maintained according to the manufacturer’s emission-related written instructions or according to a site-developed maintenance plan.
- Most fleet permits conclude with more general conditions such as that engines must not cause emissions from a facility to exceed the major source threshold and must follow all applicable requirements of 40 CFR part 60, subpart JJJJ, and 40 CFR part 63, subpart ZZZZ.
Limitations and Watchouts
Facilities in the Upper Green River Basin (UGRB), an ozone nonattainment area in Southwest Wyoming, must be managed separately from sites in other parts of the state due to requirements related to managing ozone precursors. Fuel fired engines emit nitrogen oxides and volatile organic compounds, which are ozone precursors – any increases of these pollutants in the UGRB must be offset with decreases elsewhere in the area. As a result, Fleet Permits for the UGRB will be separate from those that cover the rest of the state.
The AQD will require careful tracking of engines covered by a Fleet Permit to ensure it is clear in their records (and yours!) what federal and state/permit requirements apply to your engines at which sites. Whether you use a Fleet Permit or traditional site-specific permits for your engines, tracking engine serial numbers, locations, replacements, notifications, and stack testing requires organization and attention.
Some states do not require permitting for engines that will be in place for less than 12 months. The AQD does not follow this approach and may expect preconstruction permitting for such engines. If in doubt about permitting requirements in Wyoming, reach out to the AQD New Source Review program or Trinity for assistance.
Trinity often gets questions about who is responsible for permitting engines, especially if they are rental units. If an emission-generating activity (such as a fuel-fired engine) is occurring at a site you own or operate, you may be held accountable for compliance with regulatory requirements for those engines. If the rental company holds an air permit for an engine at your site – some rental companies use Fleet Permits – it is prudent for you to be aware of the permit requirements. A common requirement for rental company Fleet Permits is to restrict placement of an engine at any particular site for less than 12 months. This is to ensure that federal emission standards for stationary engines will not apply.
Application Tips
The Wyoming AQD strongly prefers that applicants use the online IMPACT system for application submittal; whether you use it or prepare a paper application, there are key elements that should be included to facilitate processing of your application.
- A cover letter/project description to describe in narrative form what you are requesting
- Calculations for potential emissions for each engine type and the associated basis/assumptions, for criteria pollutants and hazardous air pollutants (at least formaldehyde)
- Specifications for all the engine makes/models you want to be in your “fleet”
- Description of control equipment such as catalyst and air-fuel ratio control
- Contact names, emails/phone numbers
- Regulation applicability (NSPS JJJJ/IIII, NESHAP ZZZZ)
While engines covered by a Fleet Permit can be spread out across sites in multiple counties, applicants must specify which counties they wish to cover in their fleet permit so the AQD can place notices of proposed permit authorizations in those counties, in accordance with their public notice responsibilities. In addition, while it’s always a good idea to prepare a permit application to cover all realistic future scenarios, after a Fleet Permit is issued it is possible to apply for modification of an existing engine fleet to add additional engines or locations.
If you want the ability to keep an engine at any site for more than 12 months in your Fleet Permit, make sure you specify that in your application (and be prepared to comply with federal standards for stationary engines, including New Source Performance Standards and National Emission Standards for Hazardous Air Pollutants).
To learn more about whether obtaining a Fleet Permit to cover engines at multiple sites makes sense for your company, please contact Trinity’s Cheyenne office or call 307.421.0021.
