Environmental Health & Safety Environmental Results Program (ERP) (Emergency Generators, Turbines & Fire Pumps)

December 2022

Regulatory Authority(s)

• Massachusetts Department of Environmental Protection (MADEP)

Regulations Applicable

• 310 CMR 7.26 (42) – Engine and Turbine (ERP) Regulation
• 310 CMR 70
• 40 CFR, Part 60 Subpart IIII

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

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
• Gas - Natural vs Propane
  
  • Natural Gas (LNG) - lighter than air flammable gas, consisting largely of methane and other hydrocarbons, occurring naturally underground (often in association with petroleum) and used as fuel.
  • Propane Gas (LPG) - a heavier than air flammable gaseous alkane found in crude petroleum and natural gas and used especially as fuel and in chemical synthesis
• 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

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.

The requirements of 40 CFR, Part 60, Subpart IIII apply to all emissions from Stationary Compression Ignition Internal Combustion Engines, depend on the year of the generator manufacture, and is specific to those engines that run on diesel fuel. 

The requirements of 40 CFR, Part 60, Subpart JJJJ do not apply to Amherst College, as they are specifically required for Stationary Spark Ignition Internal Combustion Engines that are field by gasoline. 

The requirements of 40 CFR, Part 63 Subpart ZZZZ also do not apply to Amherst College, as we do not own or operate a Stationary Reciprocating Internal Combustion Engine (RICE) that emits a Hazardous Air Pollutant (HAP)

Requirements

• All emergency engines must meet the air emission limits specified in 310 CMR 7.26(42)
• All emergency generators installed at Amherst College must have appropriate documentation and required information that ensures it meets or exceeds emission requirements, and shall have the EPA Certificate of Conformity as required by the Clean Air Act
• 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 NonRoad 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)
• All documentation for the installation of, and monitoring for the stationary generators shall be provided to the office of Environmental Health and Safety for reasons of regulatory compliance.

Generator (Engine) Purchase

• The department purchasing an emergency engine or turbine must ensure that the unit conforms to Amherst College specifications, in compliance with the requirements of the local, state and federal building, environmental, fire, health and safety regulations.
  
  • It is the responsibility of the purchasing department to provide the required documentation, including the specific engine's Certificate of Conformity and to complete the Emergency Engine or Turbine Certification Form, which can be found at the end of this document.
  • Certificate of Conformity

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.

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 emergency engines 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
• Depending on the year of manufacturer after 1996 and the power rating (KW) of the generator, Amherst College may be required to comply with emissions and monitoring requirements for applicable generators. 
  • Emission standards for each generator are required over the entire life of the generator service

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

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

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.

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
• Stack height options include;
  • Roof mounted generators with a stack;
    •   5' above the enclosure for engines rated < 300kW and,
    • 10' for engines rated between 300 kW and 999 kW.
    • 1.5 times the height/projected with of the building and higher than any adjacent building if > 1MW
  • Ground located generators, adjacent to other buildings, if possible, the stack should run up the side of the building and exit;
    •   5' above the roof for engines rated < 300 kW and,
    • 10' above the roof for engines rated between 300 kW and 999 kW
    • 1.5 times the height of the building and taller than any adjacent building if >1 MW
  • If not feasible to run the stack up the side of an adjacent building, or if there are no adjacent buildings, the the stack should exit;
    •   5' above the roof of the enclosure if the engine is rated < 300 kW, or
    • 10' above the roof of the enclosure if the engine is rated between 300 kW and 999 kW
    • 1.5 times higher that adjacent building if the engine is rated > 1 MW.
  • If an engine stack discharges near operable windows, fresh air intakes or areas in close proximity to pedestrians all efforts should be taken to relocate the engine or modify the stack to reduce the risk to person(s).

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.

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

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

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Amherst College Emergency Engine or Turbine Certification Form - Fillable