Lane Regional Air Protection Agency (LRAPA) is proposing to roll out a new General Air Contaminant Discharge Permit (ACDP) Attachment AQGP-05a for emergency generators. AQGP-05a will be assigned to, or may be requested by, sources with a new or existing General ACDP that have emergency fire pumps and/or generators with an aggregate horsepower (hp) of less than or equal to 3,000 hp.
Almost all emergency fire pumps and generators are subject to federal regulatory requirements under 40 CFR 60, New Source Performance Standards (NSPS) Subpart IIII and JJJJ and 40 CFR 63, National Emission Standards for Hazardous Air Pollutants (NESHAP) Subpart ZZZZ; collectively referred to as the Stationary Engine Rules.
Emergency fire pumps and generators with an aggregate horsepower rating less than or equal to 3,000 hp qualify in Oregon as categorically insignificant units; and therefore, are not required to be included as a permitted unit. Although such a unit is not permitted, it is still required to comply with federal and state regulatory requirements. AQGP-05a details the regulatory requirements applicable to emergency fire pumps and generators, providing attachment holders with clear indication of requirements.
Additional permit qualifications to apply for the AQGP-05a attachment include:
- Remaining an area source category for Hazardous Air Pollutants (HAPs) by emitting less than 10 tons per year of a single HAP or 25 tons per year of totals HAPs;
- Emergency generator(s) are not equipped with emission controls;
- The emergency fire pump and/or generator(s) subject to NSPS Subpart IIII or JJJJ is (are) certified by the manufacturer to meet applicable emission limitations;
- Having an engine displacement less than 30 liters per cylinder if subject to 40 CFR 60 Subpart IIII; or
- Having an engine power greater than 25 hp if subject to 40 CFR 60 Subpart JJJJ.
Additionally, the generator must meet the definition of emergency power defined by the federal regulations as well as follow the default permit conditions surrounding reporting, tracking, operating, etc. as detailed in the Attachment. These sources are deemed categorically insignificant activities, and therefore do not get included in facility-wide plant site emission limits (PSELs) established in the General ACDP. However, they do have an annual report requirement that includes a summary of complaints relating to air quality received by the permittee during the year.
Fees for annual renewal for General Permit Attachment are $194 as listed in LRAPA section 37-8020 Table 2. The timeline expected to receive this attachment after request has not yet been defined.
This permit attachment is currently in a public comment period, with comments due by December 12th, 2023, at 5:00 pm. You can participate in public comment as well as find more information about the permit attachment at the following link: Public Notice for Proposed General Air Quality Permit Attachment for Emergency Generators (AQGP-050a) | Lane Regional Air Protection Agency (lrapa.org)
Trinity has expertise and extensive experience in both formulating and navigating evaluations with local air agencies, as well as permitting and air dispersion modeling for emergency generators. To determine whether your facility would qualify for this permit attachment, potential implications of the document, or any other follow-up questions, please email Beth Ryder or Jesse Gonzalez in Trinity’s Portland office, or call 503.713.5550.
