Engines that are used to generate power in emergency situations are often overlooked; however, most facilities operate them, regardless of industry and size. Whether they power a generator or a fire pump, the vast majority of these emergency engines are subject to one or more U.S. Environmental Protection Agency (EPA) regulations, which focus on engine operating practices and emissions. EPA engine regulations consist of the New Source Performance Standards (NSPS) in 40 CFR Part 60, Subparts IIII and JJJJ, and the National Emissions Standards for Hazardous Air Pollutants (NESHAP) in 40 CFR Part 63, Subpart ZZZZ. As a source subject to an applicable requirement in 40 CFR Parts 60, 61, or 63, each engine is required to be covered by an air permit or a registration, regardless of the small emissions impact. This article explains Kentucky air permitting for an engine.
When trying to decipher EPA engine regulations, the best place to start is to clearly understand the definitions to determine what needs to be known about an engine and how it will be regulated. See EHS Quarterly Issue 8 for more general details about how to decipher engine dichotomy. Most importantly, know the difference between a generator and an engine.
Kentucky Air Permitting for an Engine
In Kentucky, air permitting is required before construction of even the concrete pad or building where the engine will be installed. Whether or not a source requires an air permit and which type of permit is required depends on its site-wide potential-to-emit (PTE) for regulated air pollutants. The lowest level of permitting in Kentucky is covered under 401 KAR 52:070 for registration of air contaminant sources. The qualifying PTE for registration is between 2 – 10 tpy of a hazardous air pollutant (HAP), 5 – 25 tpy of combined HAPs, 10 – 25 tpy of a regulated air pollutant, or if the PTE is less than these cutoffs but the source is subject to an applicable requirement in 40 CFR Parts 60, 61, or 63. As the vast majority of engines are subject to applicable requirement in 40 CFR Parts 60 or 63, at least registration is required. Registration applications require the applicable air permitting forms.
As the facility-wide PTE increases, the required permit type changes from registration to state-origin to Conditional Major to Title V. If the site is permitted as state-origin, Conditional Major, or Title V, the engine installation cannot be covered under a registration, and must be incorporated into the site’s existing air permit. Although engines may qualify as insignificant activities from an emissions perspective, being subject to the engine regulations, which are not considered “generally applicable,” disqualifies them from being considered insignificant activities. For state-origin permit revision applications under 401 KAR 52:040, applicable air permitting forms are required by regulation. For Conditional Major (401 KAR 52:030) and Title V (401 KAR 52:020) sources, an engine may qualify for a 502(b)(10) change notification, which does not explicitly require the applicable air permitting forms until permit renewal. In practice, however, it is preferred to provide the applicable air permitting forms with the 502(b)(10) change notification to ensure complete information is submitted. If the Conditional Major or Title V permit does not already include the necessary regulatory applicability for the proposed engine, a Minor Revision permit application is required, which requires the air permitting forms by regulation.
The first step is gathering the necessary information to estimate emissions associated with the engine, perform relevant regulatory analyses, and prepare the corresponding application. Necessary information includes, but is not limited to, EPA Certificates of Conformity, vendor specification sheets including drawings if available, and emissions data sheets. To determine the engine rating, the specification sheet and emissions data sheet should be reviewed to determine the appropriate maximum power rating and fuel consumption to use in the permit application.
The next step in support of the DEP7007N form is to generate detailed emissions calculations. This is especially critical for spark ignition engines when determining if they are rich or lean burn. Although certification testing as documented on the emissions data sheet does not represent the absolute maximum capability of your particular engine, using these factors is generally preferred in Kentucky to develop a PTE and document compliance with the relevant emissions standards.
Once the information is gathered, populate the DEP7007EE form for Internal Combustion Engines. A required attachment for this form is the EPA Certificate of Conformity if the engine is certified. This form requires detailed information about the engine including:
- Manufacturer and model
- Model year and date of manufacture
- Date of proposed construction commencement
- List of applicable regulations
- Ignition type (compression or spark)
- Engine family details (stroke and burn type)
- Maximum engine power and speed
- Total displacement and number of cylinders
- Fuel type and maximum consumption
- Emission factors (duplicative of the DEP7007N form for Source Emissions Profile)
As noted on the DEP7007EE form, the DEP7007AI, N, V, and GG forms are also required. The DEP7007GG form is for control equipment, which is often not included for emergency engines, so this form may be left out. The DEP7007N form requires the emissions information, partially redundant with DEP7007EE, as well as the stack information including planned location onsite. Stack information (diameter, height, flowrate, temperature) is generally available on the specification sheet and/or a drawing. The DEP7007V form, required for major and synthetic minor sources only, details the regulatory requirements from 40 CFR Part 63, Subpart ZZZZ and/or 40 CFR Part 60, Subparts IIII or JJJJ. The specific details for each engine, as included in the DEP7007EE form, will inform the regulatory applicability.
With the documentation, air permitting forms, and detailed emissions calculations, the last step is to write a narrative cover letter or report to explain how all the pieces come together to form your permit application. The permit application is then compiled as a single .PDF file for submittal to Kentucky via eForms. Once the unit is onsite, take photos of the nameplate of both the engine and what it is powering (generator of fire pump) to validate the details against your permit and permit application.
For someone who has done hundreds of engine applications in Kentucky, please reach out to Elisabeth Martin in Trinity’s Covington Office for more information.
