Environmental Health & Safety

Environmental Results Program (ERP)

Emergency Generators, Turbines and Fire Pumps

October 01, 2017

Regulatory Authority(s)

  • Massachusetts Department of Environmental Protection (MADEP)

Regulations Applicable

  • 310 CMR 7.26 (42) – Engine and Turbine (ERP) Regulation
  • 310 CMR 70

Noncompliance Enforcement

  • Penalties for non-compliance with the Massachusetts Department of Environmental Protection are based on the Administrative Penalty regulation, 310 CMR 5.00

Responsibility(s)

  • The overall responsibility for environmental compliance at Amherst College rests with the Board of Trustees and the President of the College.
  • For this plan, the following other departments and positions within the College shall assume responsibilities applicable to them.
  • Chief of Campus Operations
  • Director of Facilities
  • Facilities Supervisors responsible for the Central Energy Plant, Electrical and Mechanical Departments
  • Department of Environmental Health and Safety

Table of Contents Page

  1. Definitions2
  2. Applicability2
  3. Requirements2
  4. ERP Compliance, Permits and Costs3
  5. Emissions3
  6. Emissions Reporting Requirements4
  7. Fuel Requirements4
  8. Emergency Engine Operational Requirements4
  9. Stack Requirements5
  10. Sound Levels5
  11. Recordkeeping Requirements6
  12. EPA Requirements – Additional6
  1. Definitions
  • Adjacent Structure – a structure that is within 5L of the stack.
  • 5L means 5x the lesser dimension (height or maximum horizontal width) of the structure
  • Air Contaminant – Volatile Organic Compounds (VOC’s) which include;
  • Carbon Monoxide (CO)
  • Nitrogen Oxides (NO2)
  • Sulfur Dioxide (SO2)
  • Distillate Fuel Oil – Fuel oil that complies with the specifications for fuel oil, numbers 1 or 2, as defined by the American Society for Testing and Materials
  • Emergency – an electric power outage due to failure of the “grid” in whole or in part attributed to a fire, flood, weather emergencies, local equipment failure or other catastrophic event.
  • It shall also mean an imminent threat of power outage is likely due to failure of the electrical supply or when capacity deficiencies result in deviation of voltage from the electrical power supplier to the premises of three (3)% above or five (5)% below standard voltage, or periods during which the regional transmission organization directs the implementation of voltage reductions, voluntary load curtailments by customers, or automatic or manual load shedding within Massachusetts in response to unusually low frequency, equipment overload, capacity or energy deficiency, unacceptable voltage levels, or other such emergencies.
  • Emission – any discharge or release of an air contaminant to the ambient air
  • Engines – means spark ignition and compression ignition stationary reciprocating internal combustion engines
  • Rated Power Output – means the maximum electrical or equivalent mechanical power output stated on the nameplate affixed to the engine or turbine by the manufacturer
  • Supplier – Company or person(s) that manufactures, assembles, or otherwise supplies emergency engines or turbines
  1. Applicability

In accordance with the requirements of the Environmental Results Program, which became effective March 2006, an owner/operator who installs, alters or substantially reconstructs an emergency engine, including fire pumps and turbines with a rated power of 37kW or an emergency combustion turbine with a rated power output less than one (1) MW is subject to the requirements contained here-in.

  • The applicability thresholds are based upon the engine or turbine rated power, not the electrical output of the electrical generator.
  • The 2 Fire Pumps are not included in the ERP, as they are electrically energized and not powered by internal combustion engines.
  1. Requirements
  • All emergency engines must meet the air emission limits specified in 310 CMR 7.26(42)
  • ERP’s must be submit a “Certification” within 60 days after the start (first fire) of the engine or turbine.
  • If compliance problems are identified (and cannot be corrected) before certification deadline, the College must file a Return to Compliance Plan (RTC) for each of the deficiencies along with the “Compliance Certificate”.
  • THE RTC requires an explanation of deficiency(s), the corrective actions to be taken, and the anticipated date of full compliance.
  • Amherst College must ensure that all of the new emergency engines or turbines are operated in compliance with the environmental regulations.
  • The engine or turbine must be run cleanly and efficiently, with minimal impact on the environment and only during those periods when emergency units are allowed to be operated
  • Amherst College “responsible person(s)” are required to sign the ERP Compliance Certification when all aspects of same have been accurately and completely finalized.
  • The responsible person(s) must have a clear understanding of the engine, fuel, stack mandates, as well as the maintenance, operation and recordkeeping requirements.
  • Emergency compression or spark ignition engine must comply with the applicable EPA Non-Road Compression Ignition Engine emission standards for the engine model year that matches the year of actual installation.
  • Example – a 500kW compression or spark-ignition engine installed in 2006 (new or used) must meet EPA’s non-road compression ignition engine emission limitations for a model year 2006, 500 kW engine.
  • 40 CFR Part 89, Section 89.112
  • Note! An emergency engine being moved to serve the same emergency power need within the same building is not considered installed after March 2006.
  • Emergency engines and turbines must comply with an emission limitation for Nitrogen Oxide set at 0.60 lbs / MW-hour.
  • Emergency engines and turbines must be so placed to avoid creating health and nuisance concerns from both the emissions and noise standpoints.
  • Emergency engines and turbines must be fueled with low sulfur biodiesel to minimize negative exhaust impacts from the engine.
  • Particulates from exhaust could include both Nitrogen Oxide (NOx) and Sulfur Dioxide (SO2)
  1. ERP Compliance/Permit Cost(s)
  • There are no fees for Compliance Certification for the Environmental Results Program (engines or turbines).
  • When submitting our Source Registration (310 CMR 7.12), we must also submit the Emergency Engine and/or Turbine installed under the ERP regulation.
  1. Emissions
  • Amherst College must keep documentation that the emergency engines and turbines, as designed and installed will comply with the applicable emission limits for the first three (3) years of operation, and that such operation follows the requirements of the manufacturers specifications.
  • The document shall be in the form of a written statement provided by the engine supplier as follows;
  • For emergency engines burning oil (generally compression-ignition or diesel engine), a statement that the certificate of conformity has been obtained pursuant to EPA’s non-road compression ignition engine requirements.
  • For emergencyengines burning natural gas or propane (generally spark ignition engines), a letter or other documentation form the engine supplier stating that the engine, including any add-on catalytic emission control, meets the non-road compression ignition emission limitations for the engine owner rating and model year
  • For emergency turbines using any fuel: a statement that the unit meets the emission limitation for Oxides of Nitrogen (NOx)
  • Visible emissions shall not exceed 20% opacity at any time during emergency engine and emergency turbine operation.
  • Visible emissions do not include water vapor
  1. Emissions Reporting Requirements
  • If the installation of the emergency engines and/or turbines result in us being subject to emissions reporting requirements, as specified in 310 CMR 7.12 for the first time, Amherst College must contact MADEP by January 31st and then must submit the Source Registration.
  • Installation of new emergency engines and/or turbines could result in Amherst College exceeding thresholds for other air pollution control requirements, including, but not limited to;
  • New Source Review
  • Operating Permits (additional)
  • Prevention of Significant Deterioration (PSD’s)
  • If Amherst College becomes a major source of air emissions, we could be required to comply with one or more of the following;
  • Emission Offsets and Non-Attainment Review
  • Operating Permits
  • Prevention of Significant Deterioration (PSD) Requirements
  1. Fuel Requirements
  • Effective July 2007, Amherst College must not accept delivery of fuel oil for emergency engines that does not conform to the EPA’s sulfur limits for transportation distillate fuel
  • 15 ppm sulfur
  1. Emergency Engine Operational Requirements
  • The responsible person(s) shall ensure that each emergency engine does not exceed the 300-hour annual run time, as required.
  • Each emergency engine and turbines are allowed to operate no more than 300 hours during a rolling 12-month period.
  • This includes periods of operation and normal maintenance and testing as recommended by the engine or turbine manufacturer.
  • All units must be equipped with a non-turn back hour counter that is maintained in working order.
  1. Stack Requirements
  • The emergency engine stack must;
  • discharge vertically upward
  • have stack heads or other devices designed to prevent ice, snow, water and other precipitation from entering the stack
  • not restrict the vertical flow of exhaust gas stream
  • devices such as “shanty caps” and “egg beaters” are prohibited.
  • “coning” of a stack is still permissible
  • not more than 1” change in diameter to every 5” in length of cone is recommended in order to avoid serious backpressure that may affect air flow at the point of origin.
  • be designed to minimize plume entrapment in wakes caused by obstructions to air streams.
  • Any emission impacts of exhaust stacks upon sensitive receptors, including, but not limited to people, air intakes, doors and windows that open, or otherwise considered to be nuisance type shall minimize the negative affects by using the appropriate engineering controls, which include, but are not limited to;
  • avoiding areas where the exhaust from the emergency engine will subject person(s) to the odor and particulates
  • installation of stacks that are of appropriate height, which will minimize the negative impacts on people and the environment, such as through doors, windows, mechanical ventilation systems and general exposure upon a street or walkway.
  • Emergency engines and turbines with a rated output of 300kW, but < 1 MW, shall have a stack that is not less than 10’ above the adjacent building rooftop, facility or the emergency engine or turbine enclosure, whichever is lower.
  • Engines with a rated power output 1 MW, shall have a stack with a minimum height of 1.5 times the height of the building, facility on which the stack is located.
  • If the stack is lower than the required 1.5x the building height or lower than the height of the structure that is within 5L of the stack.
  • 5L means 5 times the lesser of the height or maximum projected width of the structure
  1. Sound Levels
  • Amherst College is also responsible for verifying that the emergency engines are so located or otherwise protected so as to minimize the nuisance of noise, and the reduction of sound levels.
  1. Recordkeeping Requirements
  • The following records must be maintained by the Electrical Shop Supervisor for the life of the ERP emergency engine and/or turbine;
  • Emergency engine information, which includes the type, make, model and rated power output
  • Must maintain copies of all certificates, documents and other relevant information as supplied by the emergency engine/turbine manufacturer(s).
  • If applicable, the results of an air quality model run which demonstrates that the emergency engine and/or turbine emissions have not caused an exceedance of the National Air Quality Standards (NAQS)
  • The Electrical Shop Supervisor must also maintain the following individual emergency engine records for not less than 3 years;
  • monthly log of hours of operation, fuel type, and for diesel, both the heating values and sulfur content.
  • monthly calculation of the total hors operated in the previous 12 months.
  • monthly logs must also reference purchase orders, invoices, maintenance repairs/replacement costs, and other documents to substantiate information
  1. EPA – Additional Requirements
  • In addition to the requirements identified in the MADEP ERP regulations, Amherst College must ensure that they verify that the necessary requirements of the Federal EPA, which may also apply are not overlooked. These include, but are not limited to;
  • 40 CFR 60 Subpart IIII – Standards of Performance for Stationary Compression Ignition Internal Combustion Engines
  • 40 CFR 60 Subpart JJJJ – Standards of Performance for Stationary Spark Ignition Internal Combustion Engines
  • 40 CFR 63 Subpart ZZZZ – National Emissions Standards for Hazardous Air Pollutants (NESHAPs) for Stationary Reciprocating Internal Combustion Engines

MADEP – Offices and Assistance

  • Western Mass Regional Office(413) 784-1100
  • MADEP – ERP – Emergency Engine and Turbines

PO Box 120-165

Boston, MA 02112-0165

ERP Compliance Certification

  • Assistance and Information

Appendix A – List of Emergency Engines and Turbines

1