Emergency Generators and Oil SPCC Permits

You are prepared, but are you permitted to be prepared?  If your non-industrial building (e.g., office building or retail facility) has an emergency electrical generator or fire pump that is powered by an internal combustion engine, did you know that many states require an air pollution permit for these sources?  To check the applicability of your situation, consult your state regulations for air pollution permitting:

• Start by checking state regulations for exemptions.  Some states exempt all emergency generators if they are used only for emergencies.  Some states also exempt smaller sources (e.g., 50 HP or less) from permitting.
• Next, if you cannot claim an exemption, you may be able to follow streamlined permitting options for your sources that take very little effort to complete.  Commonly known as “Permit-By-Rule or “General Permits,” these are often one- to two-page applications.
• Finally, larger engines may require standard Air Operating Permits, since they may have federal rules that also apply.

Note that for any of these permitted sources, recordkeeping is typically required. This may include recording fuel use, hours of operation, and maintenance records.

In addition, keep in mind that if your generator is diesel- or gasoline-fueled, oil spill plans may be required.  Add up the oil storage capacity of all fuel tanks and hydraulic elevator sumps, other hydraulic systems, and oil-filled electrical transformers that you own or lease. (Do not count utility-owned transformers.) Count only the oil stored in a container which has a capacity of 55 gallons or more.  If this sum is equal to or greater than 1,320 gallons of oils, your facility needs an Oil Spill Prevention, Control and Countermeasure (Oil SPCC) plan.  This federally required plan (40 CFR 112) details how your facility prevents and will respond to oil spills.

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