Workshop R Clean Air Act Challenges Permitting Back Up/Emergency - - PDF document

Workshop R

Clean Air Act Challenges … Permitting Back Up/Emergency Generators: Surviving the EPA’s New Rules and Regulatory Maze in Ohio

Tuesday, March 26, 2019 2 p.m. to 3:15 p.m.

Biographical Information William J. Bruscino, P.E. Principal Consultant - Trinity Consultants 110 Polaris Parkway, Suite 200 Westerville, Ohio 43082 Phone: 614.433.0733 E-mail: bbruscino@trinityconsultants.com

• Mr. Bruscino manages air quality permitting and compliance services for industries such

as refining, chemical manufacturing upstream and midstream oil and gas, and general

• manufacturing. His experience includes Title V and PSD permitting in EPA Regions IV,

V, and VI as well as compliance assessments and implementation projects. Mr. Bruscino has also assisted multiple facilities in establishing Title V and minor source air compliance programs including environmental management information system (EMIS)

• implementations. More specifically, he has audited and developed regulatory

compliance programs for facilities operating a few emergency engines to corporate entities managing hundreds of engines. Mr. Bruscino currently manages Trinity’s Columbus, Ohio office and is a member of the Air & Waste Management Association. He received a Bachelor’s degree in chemical engineering from the University of Cincinnati and holds a Professional Engineering license in the State of Ohio. Michael E. Hopkins, P.E., Assistant Chief, Permitting Division of Air Pollution Control Ohio EPA, P.O. Box 1049, Columbus, OH 43216-0149 (614) 644-2270 FAX: (614) 644-3681 mike.hopkins@epa.ohio.gov Michael Hopkins has been with the Ohio EPA since 1980. He is currently the Assistant Chief, Permitting of the Ohio EPA. His duties include the review and final approval for all air pollution permit-to-install, permit-to-install and operate, and Title V permitting in the State, the development of technical support for air pollution control regulations, litigation support, MACT program support, Tax Program support and general air pollution planning activities. He has been in this position since April 2003. Before this assignment, he was in charge of the Air Quality Modeling and Planning Section with similar duties as above from August 1993 through April 2003. Prior to that assignment, he was in charge of the engineering section of the Ohio EPA Central District Office air

• program. The engineering section is responsible for reviewing air pollution permit-to-

install and permit-to-operate applications for compliance with air pollution regulations, facility inspections, complaint investigations, enforcement case development, policy and rule development, the Emissions Inventory Program, and other related duties in the central Ohio area.

• Mr. Hopkins earned his Bachelor’s degree in environmental engineering from the

Pennsylvania State University. He is a licensed Professional Engineer in the State of

• Ohio. He is a member of the Air and Waste Management Association, the National

Society of Professional Engineers and the Ohio Society of Professional Engineers.

MEC Workshop R – Permitting Your Engines and Managing EPA’s Rules

Cincinnati, OH – March 26, 2019

• Mr. Michael Hopkins - Ohio EPA
• Mr. William Bruscino - Trinity

˃ Identify Available Permitting Options ˃ Discuss Ohio-Specific Rules ˃ Future Changes ˃ Discuss Federally Applicable Rules

In this presentation, we will… .

Permit Exemptions

˃ Gets out of need to obtain permit ˃ May still have other obligations ˃ Found in OAC 3745-31-03(B)(1)

 (B)(1)(nn) - Maintenance NG Compressor

Engines

 (B)(1)(oo) - Emergency Gen, compressors,

water pumps

 (B)(1)(pp) - 2/4-stroke gas engines  (B)(1)(qq) - Non-road engines

NG Compressor Engine Exempt.

˃ <10 mmBtu/hr ˃ Use for maintenance purposes only ˃ Fired by NG, gasoline or distillate oil ˃ Complies w NSPS/MACT

Emergency Generator Exempt.

˃ ≤ 50 HP ˃ Burns gasoline, natural gas, distillate oil,

• r liquid petroleum gas

˃ Comply with NSPS IIII/JJJJ and RICE MACT ˃ “Emergency engine” definition includes

emergency Demand Response (DR)

Non-road Engine Exemption

˃ Definition found at OAC 3745-31-

01(CCCC)

˃ Intended for portable or transportable

engines

˃ Follows 40 CFR 89 - Control Of Emissions

From New And In-use Nonroad Compression-ignition Engines

Permit-by-rule - Qualifications

˃ PBR for Emergency Engines > 50 HP ˃ Limited to 500 hours per rolling, 12-

month period

˃ Use for non-emergency DR prohibited ˃ Fire only gasoline, natural gas, distillate

• il, or liquid petroleum gas

˃ Comply with NSPS IIII/JJJJ and RICE MACT

Permit-by-rule - Records

˃ Maintain following records: ˃ Monthly records that contain rolling, 12-

month summation of operating hours

˃ Records that show type of fuel used, and

%S for distillate

˃ Records of the total time operated in

emergency situations

˃ Also “general” obligations in 31-03(C)(1)

Permit-by-Rule - Notification

˃ One-time submission of “Qualifying

Criteria” form

˃ Submit to local office ˃ Once submitted, can construct/install ˃ Approval process very quick - <7 days typ. ˃ Approval posted on web ˃ No fee, no expiration

PBR Notification Form

Permit-by-Rule Stats

˃ Emergency Electrical Generators / Pump /

Compressor PBR

 Available since mid-2005  Can elect to have existing PTI revoked and go

PBR instead

˃ PBR available at:

 https://epa.ohio.gov/dapc/newpermits/issued  Go to “Active List of Permit-by-Rule”

˃ 8,979 PBRs for this category

Permit-to-Install and Operate

˃ What happens if your engines does not

qualify for the PBR?

 Must obtain a traditional Permit-to-Install and

Operate (PTIO)

 PTIO application requires emission estimates,

regulatory applicability, Best Available Technology (BAT) review, air dispersion modeling (if necessary), and appropriate application forms

˃ Agency review time: 1-3 months depending

• n complexity

Impact of Federal Rule 100-Hour Vacatur

˃ Ohio EPA will update OAC rule 3745-31-

01(NN)(2) to be consistent with federal rules

˃ Chapter 31 Interested Party package in 2019 ˃ State definition of emergency engine still

includes emergency DR despite federal vacatur

˃ Engines may be non-emergency in a federal

context but would still be emergency engines in the State of Ohio

˃ Such engines remain eligible for PBR

coverage

Case Study: Evaluation of Ohio EPA Requirements

˃ Emergency DR Participation?

 May participate as long as comply with PBR

provisions

 This will change when Ohio EPA revises the state

definition of “emergency engine” to exclude emergency DR ˃ Economic DR Participation?

 Must meet all criteria in OAC 3745-31-

01(NN)(2)(d)(i)-(v) which are functionally identical to 40 CFR 63.6640(f)(4)(ii)(A)-(E), or

 Requires Permit-to-Install and Operate (PTIO)  PTIO terms and conditions crafted on case-by-case

basis

Federal Engine Regulations – Brief Overview

Federal Regulations

Our Focus

˃ 40 CFR Part 60 Subpart IIII, S

t andards of Performance for [New] S t at ionary Compression Ignit ion Int ernal Combust ion Engines (CI ICE NSPS)

˃ 40 CFR Part 60 Subpart JJJJ, S

t andards of Performance for [New] S t at ionary S park Ignit ion Int ernal Combust ion Engines (SI ICE NSPS)

˃ 40 CFR Part 63 Subpart ZZZZ, Nat ional Emission

S t andards for Hazardous Air Pollut ant s for S t at ionary Reciprocat ing Int ernal Combust ion Engines (RICE

NESHAP)

˃ Also, Subpart A for each Part

Summary of Regulated Engine Pollutants

NSPS JJJJ NSPS IIII RICE MACT VOC NMHC/HC Formaldehyde and CO (as surrogates for Total HAPs) NOx NOx CO CO PM

Criteria Pollutants HAPs

˃ 40 CFR 89 - New and In-Use Nonroad CI Engines



Tiers 1, 2, and 3

˃ 40 CFR 1039 - New and In-Use Nonroad CI Engines



Tier 4

˃ 40 CFR 90 – Nonroad SI Engines < 19 kW ˃ 40 CFR 1048 – New Nonroad SI Engines > 19 kW ˃ 40 CFR 1054 – New Small Nonroad SI Engines ˃ 40 CFR 94 - Marine CI Engines



Tier 2

˃ 40 CFR 1042 - New and In-use Marine CI Engines



Tiers 3 and 4

˃ 40 CFR 91 - Marine SI Engines ˃ 40 CFR 1045 – Marine SI Engines



For more informat ion, e.g., hist ory, about Tier st andards, ht t p:/ / www.dieselnet .com/ st andards

Other Federal Regulations

Nonroad and Marine Engines

Nonroad and Marine Engines

˃ Not subject to IIII, JJJJ, & ZZZZ ˃ Marine ICE…an integral part of a marine vessel ˃ Nonroad (or “Non-road”) engine means any ICE

that is in or on a piece of equipment that is…

 self-propelled (may serve other purposes too); or  propelled while performing its function; or  portable or transportable

♦Designed to be moved, e.g., on wheels or skids, etc. ♦And actually is moved routinely ♦Portability is moot if it remains [in service] at a location

(building, structure, facility, or installation)…

– for more than 12 months…or… – for seasonal sources, for the entire season (3 months or more) for at least 2 years 1068.30, 89.2, 90, 91, 94, 1039, 1042, 1045, 1048, 1054

“Mobile” = Onroad + Nonroad + Marine

Temporary Exemption –Two Big Caveats

• 1. Replacing one temporary engine with

another to be used for the same purpose does not restart the 12-month clock

The 12-mont h clock applies t o t he locat ion and purpose, not a part icular engine

• 2. An engine to be used temporarily in place of

a stationary engine (e.g., while it is being

• verhauled) is considered a stationary engine

The locat ion and purpose is st at ionary even if it consist s of more t han one engine over t ime

NSPS IIII

Standards of Performance for Stationary [ New] Compression Ignition Internal Combustion Engines

(Original proposal for CI ICE NSPS was in 1979; it was never finalized)

NSPS IIII Applicability

˃ Potentially applies to:

 All stationary compression-ignition engines

♦Reciprocating, rotary, other (except turbines)

 Of any size (horsepower rating)  Emergency & Non-Emergency

˃ If:

 Const ruct ed (ORDERED) after 7/11/2005 and

manufact ured after 4/1/2006

 Modified or reconst ruct ed after 7/11/2005

60.4200

NSPS IIII Emission Standards

˃ Pollutants: NMHC/HC, NOX, NMHC+NOX,

CO, PM

˃ The rule is modeled after the mobile

(nonroad and marine) standards

˃ General engine categories:

 Per-cylinder displacement < 10 L  10 L ≥ per-cylinder displacement > 30 L  Per-cylinder displacement ≥ 30 L  Emergency  Fire pump 60.4204 & 4205

NSPS IIII Emission Standards

˃ For displacement < 10 L/cylinder

 Meet nonroad “Tier” standards

♦Tiers 1, 2, & 3 in 89.112 ♦Tier 4 in 1039.102 ♦Specific requirements depend on use, model

year, displacement, and power

 Emergency engines are exempt from the

most stringent (Tier 4) standards

 Delayed schedule for fire pump engines 60.4204 & 4205

NSPS IIII Emission Standards

˃ For 10 L/cylinder ≥ Displacement < 30

L/cylinder

 “Tier” standards for marine engines

♦Tier 2 in Part 94; Tiers 3 and 4 in Part 1042

 Emergency engines are exempted from most

stringent (i.e., Tier 4) standards

˃ For Displacement ≥ 30 L/cylinder

 Standards for large marine engines

♦Achievable via the use of SCR & ESP

60.4204 & 4205

NSPS IIII Compliance Requirements

˃ Displacement < 30 L/cylinder

 Purchase certified engine and follow

manufacturer instructions or

 Conduct initial testing (and subsequent testing if

> 500 hp) and

 Develop and follow a maintenance plan  If pre-2007 model year, additional options:

♦Test of a similar engine or data from engine

manufacturer or control vendor indicating compliance

˃ Displacement ≥ 30 L/cylinder

 Testing and control device monitoring

60.4211

Engine Manufacturer Certifications

˃ Engine manufacturers must certify 2007

model year and later engines <30 L/cyl.

60.4201

Emergency Engines

 See discussion of definition and operational

requirements in MACT ZZZZ section

60.4211(f)

NSPS JJJJ

Standards of Performance for Stationary [ New] Spark Ignition Internal Combustion Engines

NSPS JJJJ Applicability

˃ Potentially applies to:

 All stationary spark-ignition engines

♦Reciprocating, rotary, other (except turbines)

 Of any size (horsepower rating)  That fires any fuel  Emergency & Non-Emergency

˃ Exemptions:

 Engines at test stands  National security exemption (upon request)

60.4230

Owners/operators of ICE modified or reconstructed after 6/12/2006

NSPS JJJJ Applicability

Constructed (ORDERED) after 6/12/2006 and manufactured after…

60.4230, 4236

Type / Size Manufactured Date ≥ 500 HP except LB 500 ≤ HP < 1350 7/1/2007 LB 500 ≤ HP < 1350 1/1/2008 < 500 hp 7/1/2008 Emergency > 25 hp 1/1/2009 If < 25 hp, no emergency / non‐emergency differentiation

NSPS JJJJ Standards

˃ Emission standards for HC/NMHC, NOX, CO,

and VOC (excluding CH2O)

 Depends on use, fuel, model year, and power

˃ All engines ≤ 25 hp

 All are certified by the manufacturer to standards

in 90 or 1054

˃ Engines > 25 hp

 Purchase volunt arily certified engine (standards in

1048 or Table 1) and follow manufacturer’s instructions or

 Stack test and develop/follow a maintenance plan

60.4233, 4235, 4244(f)

NSPS JJJJ Requirements

Non-Emergency and Emergency ICE

˃ Purchase a certified engine



Follow mfr. Instructions…–or– maintenance plan



Upon loss of certification, initial performance test if ≥100 hp (within 1 year) and subsequent* performance tests if >500 HP



Cannot comply via non-cert ified opt ions

˃ Non-certified Engines



Maintenance plan



Initial performance test if ≥25 hp

♦Within 60/180 days



Subsequent* performance tests and initial notifications if >500 HP

* Every 8,760 hours or 3 years, whichever is first

60.4243

Required for: ≤ 25 hp; > 25 hp gasoline; > 25 hp RB LPG Required for: Modified and reconstructed engines

Emergency Engines

˃ See discussion of definition and operational

requirements in MACT ZZZZ section

˃ Certain (depending on power and build date)

emergency SI ICE not meeting non-emergency emissions standards must have a non-resettable hour meter:

 HP ≥ 500 HP “built” on or after 7/1/2010  130 ≤ HP < 500 “built” on or after 1/1/2011  HP < 130 “built” on or after 7/1/2008

“ built ” = “ manufact ured” based on reading of preambles

60.4243(d) & 4237

NESHAP ZZZZ

National Emissions Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines a.k.a., the RICE MACT

RICE MACT Applicability

˃ Applies to all stationary reciprocating ICE ˃ Exemptions:

 Engines at test stands  National security exemption (upon request)  Existing, emergency engines at residential,

commercial, and institutional area sources…

♦that do not operate and are not contractually obligated to

be available for more than 15 hr/yr for emergency demand response or voltage or frequency deviations

♦that do not supply power as part of a financial

arrangement with another entity

 What if a headquarters “commercial” office

building is co-located with a manufacturing plant?

♦Informally EPA has said that engines providing backup power

to the HQ building are exempt 63.6585

Existing v. New Sources

˃ Determination based on “commence construction”

date (start of on-site construction, not ordered)

˃ What if an engine is relocated to a new facility?



Relocation and/or a change in ownership of an existing RICE does not make it new

63.6590(a)

Potential RICE MACT Requirements

˃ Emission limits (CO and CH2O) ˃ Continuous & monthly monitoring (T and ΔP)

 Monitoring system evaluations

˃ Stack testing (emissions or catalyst activity) ˃ Reporting and notifications ˃ Management/work practices (maintenance) ˃ Hour meter ˃ Plans (testing, monitoring, maintenance) ˃ Recordkeeping

Overview of Requirements for Existing CI Engines

Source Status Use category Rating Emission Limit(s) Control Device Monitor Initial Perform. Test Ongoing Perform. Test Initial Notif./ Comp Reports Work Practices/

• Maint. Plan

Hour Meter

Major Non‐Emergency > 500 HP

    

Non‐Emergency 300 – 500 HP

  

Non‐Emergency 100 – 300 HP

  

Non‐Emergency < 100 HP



Emergency ≤ 500 HP

 

Emergency > 500 HP No MACT Requirements Limited Use > 500 HP No MACT Requirements Limited Use ≤ 500 HP No Such Category – Limited Use Provisions Only Apply to Existing RICE if > 500 HP Area Non‐Emergency > 500 HP

    

Non‐Emergency 300 – 500 HP

  

Non‐Emergency < 300 HP



Emergency Any

 

Note: Sometimes it is better to NOT be an emergency engine (same scenario with SI engines too)

Overview of Requirements for New CI Engines

Source Status Use category Rating Emission Limit(s) Control Device Monitor Initial Perform. Test Ongoing Perform. Test Initial Notif./ Comp Reports Hour Meter

Major Non‐Emergency > 500 HP

    

Non‐Emergency ≤ 500 HP Comply with NSPS Only Emergency > 500 HP IN only



Emergency ≤ 500 HP Comply with NSPS Only Limited Use > 500 HP

IN only

NAbS Limited Use ≤ 500 HP Comply with NSPS Only Area ALL ALL Comply with NSPS Only

Overview of Requirements for Existing SI Engines

Source Status Use category ICE Type Rating Emission Limit(s) Control Device Monitor / Engine Shutdown Initial Perform. Test / Cat. Activity Check Ongoing Perform. Test / Cat. Activity Check Initial Notif./ Comp Reports Work Practices/

• Maint. Plan

Hour Meter

Major Non‐Emergency 4SRB > 500 HP

    

Non‐Emergency 2SLB, 4SLB > 500 HP No MACT Requirements Non‐Emergency Landfill/Digester Gas > 500 HP No MACT Requirements Non‐Emergency 2SLB, 4SLB, 4SRB 100 – 500 HP

  

Non‐Emergency Landfill/Digester Gas 100 – 500 HP

  

Non‐Emergency 2SLB, 4SLB, 4SRB < 100 HP



Non‐Emergency Landfill/Digester Gas < 100 HP



Emergency Any ≤ 500 HP

 

Emergency Any > 500 HP No MACT Requirements Limited Use Any > 500 HP No MACT Requirements Limited Use Any ≤ 500 HP No Such Category – Limited Use Provisions Only Apply to Existing RICE if > 500 HP Area Non‐Emergency 4SLB, 4SRB > 500 HP

    

Non‐Emergency 4SLB, 4SRB if <24 hrs/yr or remote > 500 HP



Non‐Emergency 4SLB, 4SRB ≤ 500 HP



Non‐Emergency 2SLB Any



Non‐Emergency Landfill/Digester Any



Emergency Any Any

 

Overview of Requirements for New SI Engines

Source Status Use category ICE Type Rating Emission Limit(s) Control Device Monitor Initial Perform. Test / Cat. Activity Check Ongoing Perform. Test / Cat. Activity Check Initial Notif./ Comp Reports Hour Meter

Major Non‐Emergency 4SRB > 500 HP

    

Non‐Emergency 2SLB > 500 HP

    

Non‐Emergency 4SLB > 500 HP

    

Non‐Emergency 4SLB If manf’d ≥ 1/1/08 250 – 500 HP

    

Non‐Emergency 4SLB If manf’d < 1/1/08 250 – 500 HP No MACT Requirements Non‐Emergency 4SRB ≤ 500 HP Comply with NSPS Only Non‐Emergency 2SLB ≤ 500 HP Comply with NSPS Only Non‐Emergency 4SLB < 250 HP Comply with NSPS Only Non‐Emergency Landfill/Digester Gas > 500 HP I.N. & Fuel usage Non‐Emergency Landfill/Digester Gas ≤ 500 HP Comply with NSPS Only Emergency ALL > 500 HP I.N. only



Emergency ALL ≤ 500 HP Comply with NSPS Only Emergency 4SLB If manf’d ≥ 1/1/08 250 – 500 HP



Limited Use ALL > 500 HP

I.N. only

NAbS Limited Use ALL ≤ 500 HP Comply with NSPS Only Area ALL ALL ALL Comply with NSPS Only

Work Practice Standards

˃ Minimize startup and idling time (30

minutes)

 Startup means the time from initial start

until applied load and engine and associated equipment (including catalyst) reaches steady state or normal operation

 How do you demonstrate compliance?

♦Log startups, durations? ♦Point to startup procedure?

63.6625 & 6640

˃ Develop and follow maintenance plan

 Or manufacturer’s emissions-related instructions

˃ Oil & filter changes on specified frequencies

 Generally, 4320 hrs for 2S; 1440 for 4S; 1000 hrs for

CI, and 500 hrs for emergency RICE

 Optional oil analysis program

˃ Inspections of spark plugs, belts, and hoses on

specified frequencies

 Generally, 4320 hrs for 2S; 1440 for 4S; 500 hrs for

CI, and 500 or 1000 hrs for emergency RICE ˃ Maintenance documentation will be key

Tables 1 – 4, 63.6625(e)

Maintenance As Work Practice

Engines with NO Requirements

˃ Technically, still “affected sources” ˃ At major sources, existing RICE > 500 hp:

 SI 2SLB  SI 4SLB  Emergency

♦If it does not operate and is not contractually obligated to

be available for more than 15 hr/yr for emergency demand response or voltage or frequency deviations  Limited use (LU)  Landfill or digester gas (LG/DG)

(>10% gross heat input annually)

63.6590(b)(3)

Original floor was ‘no control’. Will be reconsidered…in 8 years

Engines Subject To Limited Requirements

˃ At major sources, new and reconstructed

RICE > 500 hp:

 Emergency

♦If it does not operate and is not contractually obligated to be

available for more than 15 hr/yr for emergency demand response or voltage or frequency deviations

♦Initial notification only

 Limited use

♦Initial notification only

 Landfill or digester gas

♦Initial notification and daily fuel monitoring & reporting

63.6590(b)(1) & (2)

Some Important Definitions Emergency RICE

˃ The RICE is operated to provide

electrical power or mechanical work during an emergency situation

˃ Examples:

 Power generation during normal supply

int errupt ions

 Pumping water for fire suppression or flood

control

˃ Operational limitations in 63.6640(f)

63.6675

Emergency Use Requirements

˃ No time limit on emergency operation ˃ 100 hrs/yr* of non-emergency operation for:



Maintenance checks and readiness testing



Emergency demand response (DR)

♦ For NERC-declared Energy

Emergency Alert Level 2 periods



During voltage or frequency deviations of ≥ 5%

˃ 50 hrs/yr* of the 100 hrs/yr* can be used for…



Any situation as long as there is no financial arrangement



For existing area source emergency RICE,

♦Local reliability under specific dispatch conditions

63.6640(f)

Vacated on May 2, 2016 by D.C. Circuit Court. * Calendar year basis

Emergency Engine Records & Reporting

˃ Non-resettable hour meter

 Software (e.g., a PLC) is okay if tamper-proof /

non-resettable (unofficial determination)

˃ BMP = Log of each operational period with

categorization (emer. or non-emer.) and reason

˃ Reporting for emergency RICE > 100 HP if…

 Operated or contractually obligated to be available >

15 hours per year in emergency demand response

 Operated for periods where there is deviation of

voltage or frequency ≥ 5%

 Operated for local grid system reliability  No longer applicable due to 5/2/2016 vacatur

63.6650(h)

Questions?

Bill Bruscino

Trinity – Columbus (614) 433-0733 bbruscino@trinityconsultants.com

Mike Hopkins

Ohio EPA – Central Office (614) 644-3611 Michael.Hopkins@epa.ohio.gov

Permit-by-Rule Notification Form Emergency Generator/Pump/Compressor

Division of Air Pollution Control

Submission of this form constitutes notice that the party identified in Section I of this form intends to be authorized to install/operate a source of air pollution according to the permit-by-rule provisions of OAC 3745-31-03(A)(4)(b). By submitting this form, the applicant agrees to operate and maintain the facility and equipment in accordance with the applicable permit-by-rule provisions. An original signature is needed and forms transmitted by fax will not be accepted. Complete all information as indicated by the instructions.

I. Applicant Information / Mailing Address Company (Applicant) Name:______________________________________________________________________________ Mailing (Applicant) Address:______________________________________________________________________________ City:______________________________________ State:______________________ Zip Code: ______________________ Contact Person:______________________ Phone:______________ Fax:______________ E-mail:_____________________ II. Facility / Site Location Information Facility Name:_________________________________________________________________________________________ Facility Address / Location:_______________________________________________________________________________ City:______________________________________ State:______________________ Zip Code_______________________ Facility Contact:______________________ Phone:______________ Fax:______________ E-mail:_____________________ Ohio EPA Facility ID Number (10-digit) – if known; see Instructions_______________________________________________ III. Reason for Submitting Notification: Initial request

Equipment modification Ownership change

Request for revocation of current permit - complete additional information below Permit to install (PTI) Number Emission Unit ID (4-digit) _______________________ ___________________ _______________________ ___________________ IV. Type of Unit for Emergency Use Electrical generator

Water pump Air compressor

Manufacturer’s engine output rating: __________________ horsepower (HP) or _________________ Kilowatts Company identification or name of unit: _________________________________________________________ V. Type of fuel burned (check all that apply) Natural gas

Propane/LPG Gasoline

Distillate oil (less than 0.5% wt. sulfur)

I certify under penalty of law that all statements or assertions of fact made in this notification are true and complete, and shall subject the signatory to liability under state laws forbidding false or misleading statements. Applicant Name (Print):___________________________________________________ Title:_____________________________________________ Applicant Signature:______________________________________________________ Date:____________________________________________

RETAIN A COPY OF THIS FORM FOR YOUR RECORDS Mail the original, signed form to the appropriate Air Permit Review Agency (District Office/Local Air Agency) for your county. (Please refer to the Agency map in the attached instructions for mailing addresses).

Rev 12/10

For Ohio EPA Use Only: FAC ID: ____________________ Date received ________________

INSTRUCTIONS: Permit-by-Rule Supplemental Form Emergency Generator/Pump/Compressor

GENERAL INSTRUCTIONS: Provide complete responses to all applicable questions. Submittal of an incomplete form will delay review and processing. If you need assistance, contact your Ohio EPA District Office or Local Air Agency for assistance. Contact the Ohio EPA, Division of Air Pollution Control at (614) 644-2270 for more information on contacting your local district office or go to http://www.epa.ohio.gov/dapc and select the topic “District Offices and Local Air Agencies”. For more information on the permit-by-rule process, including online tracking of your notification form, go to http://www.epa.ohio.gov/dapc/pbr/permitbyrule.aspx This is a notification form for an emergency electrical generator, water pump, or air compressor powered by an internal combustion engine which is intended to be to installed and/or operated according the permit-by-rule provisions of OAC 3745-31-03(A)(4)(b). This permit-by-rule provision is intended for emergency use equipment greater than 50 horsepower (37.3 Kilowatt) which does not operate more than 500 hours per rolling 12-month period. Please note the permit-by-rule does not apply to equipment employed regularly for intermittent, but not emergency, uses, e.g., electrical peak-shaving generators. An emergency generator/pump/compressor less than or equal to 50 horsepower which burns gasoline, natural gas, liquid petroleum gas, or distillate oil (with less than or equal to 0.5 per cent by weight sulfur) is exempt from permit-to-install requirements by OAC 3745- 31-03(A)(1)(nn). For copies of this regulation, contact your Ohio EPA District Office or Local Air Agency. State regulations may also be viewed and downloaded from the Ohio EPA website http://www.epa.ohio.gov/dapc/regs/regs.aspx I. Check the appropriate box which describes the equipment. Specify the manufacturer, model number and the manufacturer’s rated output in either horsepower (HP) or Kilowatts (Kw) as appropriate. Specify the company’s identification number, name,

• r other designation, i.e., Generator #1, Pump Unit #3, etc., for the unit.

II. Check the appropriate box or boxes which describe all types of fuels the unit is capable of burning. Check “distillate oil” if burning diesel fuel. For distillate oils or diesel fuel, it is recommended the fuel supplier be consulted to assure the fuel sulfur content does not exceed 0.5 per cent by weight. Signature Requirements – This notification will be deemed incomplete if it is not signed by the appropriate signatory. Please see the following guidance at http://www.epa.ohio.gov/portals/27/title_v/respoff.pdf for more information on who is authorized to sign this form or contact your Ohio EPA District Office or Local Air Agency.

Permit-by-Rule Requirements: Emergency Generator/Pump/Compressor

Excerpts from applicable sections of Ohio Administrative Code 3745-31-03(A)(4) are included with these Instructions for convenience. An owner or operator of an emergency electrical generator, firefighting water pump, or air compressor powered by an internal combustion engine which intends to install and/or operate according to the permit-by-rule provisions must comply with all applicable requirements specified in paragraphs (A)(4)(a) – General Provisions, and (A)(4)(b) – Emergency electrical generator, emergency water pumps, or emergency air compressors. (4) Permit-by-rule exemptions The following air contaminant sources are exempt from the requirement to obtain a permit to install or permit-to-install and operate (PTIO). These exemptions are valid only as long as the owner or operator complies with all of the permit-by-rule general provisions, meets the qualifying criteria defined in the applicable permit-by-rule and complies with all of the requirements under the applicable permit-by-rule specific provisions. Upon request by the director, the owner or operator of a facility that has exceeded the permit-by-rule thresholds or that the director finds is causing or may cause a public nuisance in violation of rule 3745-15-07 of the Administrative Code shall submit an application for a permit to install or PTIO. These exemptions do not, however, exempt any air contaminant source from requirements of the federal Clean Air Act, including being considered for purposes of determining whether a facility constitutes a major source or is otherwise regulated under Chapter 3745-77 of the Administrative Code or any requirement to list insignificant activities and emission levels in a Title V permit application. In addition, this rule does not relieve the owner or operator from the requirement of including the emissions associated with the exempt sources into any major new source review permitting action. (a) General provisions These general provisions apply to all owner or operators who are utilizing one or more of the permit-by-rule exemptions listed in paragraphs (A)(4)(b) through (A)(4)(l). (i) Recordkeeping requirements

The owner or operator shall collect and maintain the records described for each air contaminant source exempted under paragraph (A)(4) of this rule and these records shall be retained in the owner or operator's files for a period of not less than five years, unless otherwise specified in each exemption. These records shall be made available to the director or any authorized representative of the director for review during normal business hours. (ii) Notification requirements for new installations For the purposes of this paragraph, a new permit-by-rule air contaminant source is an air contaminant source installed after the promulgation date of any new applicable permit-by-rule or July 29, 2005, whichever comes later. The owner or operator

• f a new permit-by-rule air contaminant source electing to use an applicable permit-by-rule exemption shall submit a written

notification in a form and manner prescribed by the director prior to installation of the air contaminant source. This notification, or form, shall be submitted to the appropriate Ohio environmental protection agency district office or local air agency, and shall contain the following information, at a minimum: (a) The owner or operator's and the facility contact's name; (b) The facility mailing address and telephone number; (c) The location of the air contaminant source(s); (d) A description of the air contaminant source, including any pollution control(s); and (e) A statement by the owner or operator that indicates which permit-by-rule applies to the air contaminant source. (iii) Notification requirements for existing permitted sources The owner or operator of an air contaminant source which is operating under an existing permit to install, PTIO and/or permit to operate may continue to operate in compliance with that permit or may submit a written request to the Ohio EPA to revoke any such individual permit or permits and to allow the air contaminant source to operate under the permit-by-rule provisions. The director may revoke a permit to install, PTIO and/or permit to operate if the permittee requests revocation, agrees to meet all permit-by-rule qualifying and operating conditions, and the director determines that the revocation will not result in the violation of any applicable laws. When a permittee requests a revocation pursuant to this paragraph, the director, without prior hearing, shall make a final determination on the request and inform the permittee in writing. If the director agrees with the request to operate under the permit-by-rule, then the permit-by-rule becomes applicable to the permittee on the date the existing permit to install, PTIO and/or permit to operate are revoked. (iv) Notification requirements for existing permit-by-rule sources The owner or operator of an air contaminant source that is operating under one of the permit-by-rules that existed prior to July 29, 2005 (emergency electrical generators, injection and compression molding, crushing and screening plants, soil-vapor extraction and soil-liquid extraction) and desires to continue operating under the permit-by-rule shall submit a written notification which contains all of the elements required in paragraph (A)(4)(a)(ii) of this rule. This notification shall be submitted to the appropriate Ohio environmental protection agency district office or local air agency and shall be submitted by July 29, 2006. (v) Records retention requirements Each record of any monitoring data, testing data, and support information required pursuant to a specific permit-by-rule shall be retained for a period of five years from the date the record was created. Support information shall include, but not be limited to, all calibration and maintenance records and all original strip-chart recordings for continuous monitoring instrumentation, and copies of all reports required by the specific permit-by-rule. Such records may be maintained in computerized form. (vi) Reporting requirements The owner or operator shall submit required reports in the following manner: (a) Reports of any monitoring and/or record keeping information required by a specific permit-by-rule shall be submitted to the appropriate Ohio environmental protection agency district office or local air agency. (b) Except as otherwise may be provided in a permit-by-rule specific reporting requirements paragraph of a specific permit- by-rule, a written report of any deviations (excursions) from emission limitations, operational restrictions, qualifying criteria, and control equipment operating parameter limitations that have been detected by the testing, monitoring, and record keeping requirements specified in the permit-by-rule shall be submitted to the appropriate Ohio environmental protection agency district office or local air agency within thirty days of the date the deviation occurred. The report shall describe the specific limitation and/or operational restriction exceeded, the probable cause of such deviation, and any corrective actions or preventive measures that have been or will be taken.

(vii) Scheduled maintenance/malfunction reporting Any scheduled maintenance of air pollution control equipment shall be performed in accordance with paragraph (A) of rule 3745-15-06 of the Administrative Code. The malfunction of any emissions units or any associated air pollution control system(s) shall be reported to the appropriate Ohio environmental protection agency district office or local air agency in accordance with paragraph (B) of rule 3745-15-06 of the Administrative Code. Except as provided in that rule, any scheduled maintenance or malfunction necessitating the shutdown or bypassing of any air pollution control system(s) shall be accompanied by the shutdown of the emissions unit(s) that is served by such control system(s). (viii) Definitions. For the purposes of the permit-by-rule exemption in paragraph (A)(4)(b) of this rule, the following definitions

• apply. These definitions are in addition to terms defined for this chapter in rule 3745-31-01 of the Administrative Code:

(a) "Emergency" means: (i) A public emergency caused by flooding, damaging winds or tornado, fire, or other natural disaster; or (ii) An electric power outage due to a failure of the electrical grid, local supply equipment failure, facility equipment failure; or (iii) Conditions where a regional transmission organization notifies electric distributors that an emergency exists

• r may occur and it is necessary to implement emergency procedures for voluntary load curtailments by customers

within Ohio, in response to unusually low frequency, equipment overload, capacity or energy deficiency, unacceptable voltage levels, or other emergency conditions leading to a potential electrical blackout; or (iv) Any situation that the director determines to be an immediate threat to human health, property, or the environment. (b) "Emergency electrical generator," "emergency water pump," or "emergency air compressor," means, respectively, an electrical generator, water pump, or air compressor powered by an emergency internal combustion engine. (c) "Emergency internal combustion engine" means a stationary reciprocating engine or stationary turbine engine, whose

• peration is limited to emergency situations and readiness testing and maintenance. An engine used for non emergency use (for

instance to produce peaking power or used in a non emergency energy assistance program is not an emergency internal combustion engine under this definition. (b) Emergency electrical generators, emergency firefighting water pumps, or emergency air compressors powered by internal combustion engines greater than fifty horsepower (37.3 Kilowatts) where each engine operates at any one facility for no more than five hundred hours per rolling twelve-month period and where such engine burns gasoline, natural gas, distillate oil (with less than or equal to 0.5 per cent by weight sulfur), or liquid petroleum gas and that maintains the following records: (i) Monthly records that contain the rolling twelve-month hours of operation; and (ii) Records that show the type of fuel used and the sulfur content (in per cent by weight) of any distillate oil used.

Director Portsmouth Local Air Agency 605 Washington St., Third Floor Portsmouth, Ohio 45662 (740) 353-5156 FAX (740) 353-3638

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Air Permit Review Agencies

District Offices

CDO APC Manager Central District Office 50 West Town Street, Suite 700 Columbus, OH 43215 (614) 728-3778 FAX (614) 728-3898 SEDO APC Manager Southeast District Office 2195 Front St. Logan, OH 43138 (740) 385-8501 FAX (740) 385-6490 NEDO APC Manager Northeast District Office 2110 E. Aurora Rd. Twinsburg, OH 44087 (330) 963-1161 FAX (330) 487-0769 NWDO APC Manager Northwest District Office 347 North Dunbridge Rd. Bowling Green, OH 43402 (419) 352-8461 FAX (419) 352-8468 SWDO APC Manager Southwest District Office 401 E. Fifth St. Dayton, OH 45402-2911 (937) 285-6357 FAX (937) 285-6249

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This map shows jurisdictional boundaries. Shaded areas represent local agencies within Ohio EPA districts.

Administrator Air Pollution Control Division Canton City Health Dept. 420 Market Ave. North Canton, Ohio 44702-1544 (330) 489-3385 FAX (330) 489-3335 Director

• Dept. of Environmental Services

Air Quality Programs 250 William Howard Taft Road Cincinnati, Ohio 45219-2660 (513) 946-7777 FAX (513) 946-7778 Administrator City of Toledo Division of Environmental Services 348 South Erie Street Toledo, Ohio 43604 (419) 936-3015 FAX (419) 936-3959 Cleveland Dept. of Public Health Division of Air Quality 75 Erieview Plaza, 2nd Floor Cleveland, Ohio 44114 (216) 664-2297 FAX (216) 420-8047 Commissioner Administrator Regional Air Pollution Control Agency Public Health Dayton and Montgomery Cnty. 117 South Main St. Dayton, Ohio 45422-1280 (937) 225-4435 FAX (937) 225-3486 Administrator Akron Regional Air Quality Management District 146 South High St, Room 904 Akron, Ohio 44308 (330) 375-2480 FAX (330) 375-2402 Division of Air Pollution Control Ohio EPA, Central Office (614) 644-2270 www.epa.ohio.gov/dapc/general/dolaa.aspx

Environmental Protection Agency