September 6, 1995

MEMORANDUM

SUBJECT: Calculating Potential to Emit (PTE) for Emergency
Generators

FROM: John S. Seitz, Director Office of Air Quality Planning and Standards (MD-10)

TO: Director, Air, Pesticides and Toxics Management Division, Regions I and IV Director, Air and Waste Management Division, Region II Director, Air, Radiation and Toxics Division, Region III Director, Air and Radiation Division, Region V Director, Air, Pesticides and Toxics Division, Region VI Director, Air and Toxics Division, Regions VII, VIII, IX, and X

The purpose of this guidance is to address the determination of PTE for emergency electrical generators.

Background

In amemorandum dated January 25, 1995, the Environmental Protection Agency (EPA) addressed a number of issues related to the determination of a source's PTE under section 112 and title V of the Clean Air Act (Act). One of the issues discussed in the memorandum was the term "maximum capacity of a stationary source to emit under its physical and operational design," which is part of the definition of "potential to emit." The memorandum clarified that inherent physical limitations, and operational design features which restrict the potential emissions of individual emission units, can be taken into account. This clarification was intended to address facilities for which the theoretical use of equipment is much higher than could ever actually occur in practice. For such facilities, if theirphysical limitations or operational design features are not taken

into account, the potential emissions could be overestimated and consequently the source owner could be subject to the Act requirements affecting major sources. Although such source owners could in most cases readily accept enforceable limitations restricting the operation to its designed level, EPA believes this administrative requirement for such sources to be unnecessary and burdensome.

On the topic of "physical and operational design," the January 25 memorandum provided a general discussion. In addition, EPA committed to providing technical assistance on the type of inherent physical and operational design features that may be considered acceptable in determining the potential to emit for certain individual small source categories. The EPA is currently conducting category-specific analyses in support of this effort, and hopes as a result of these analyses to generate more general guidance on this issue as well.

The purpose of this memorandum is to address the issue of PTE as it relates specifically to emergency generators. There is a significant level of interest in this source category because there are many thousands of locations for which an emergency generator is the only emitting source. Moreover, based on a review of this source category, there exists a readily identifiable constraint on the operational design of emergency generators. Hence, the EPA believes it would be useful to provide today's guidance before the entire effort is complete.

The policies set forth in this memorandum are intended solely as guidance, do not represent final Agency action, and cannot be relied upon to create any rights enforceable by any party.

Guidance for Emergency Generators

For purposes of today's guidance, an "emergency generator" means a generator whose sole function is to provide back-up power when electric power from the local utility is interrupted. The emission source for such generators is typically a gasoline or diesel-fired engine, but can in some cases include a small gas turbine. Emissions consist primarily of carbon monoxide and nitrogen oxides. Other criteria pollutants, and hazardous air pollutants, are also emitted, but at much lower levels. Emissions occur only during emergency situations (i.e., where electric power from the local utility is interrupted), and for a very short time to perform maintenance checks and operator training.3

The EPA believes that generators devoted to emergency uses are clearly constrained in their operation, in the sense that, by definition and design, they are used only during periods where electric power from public utilities is unavailable. Two factors indicate that this constraint is in fact "inherent." First, while the combined period for such power outages during any one year will vary somewhat, an upper bound can be estimated which would never be expected to be exceeded absent extraordinary circumstances. Second, the duration of these outages are entirely beyond the control of the source, and when they do occur (except in the case of a major catastrophe) rarely last more than a day.

For emergency generators, EPA has determined that a reasonable and realistic "worst-case" estimate of the number of hours that power would be expected to be unavailable from the local utility may be considered in identifying the "maximum capacity" of such generators for the purpose of estimating their
PTE. Consequently, EPA does not recommend the use of 8760 hours per year (i.e., full-year operation) for calculating the PTE for emergency generators. Instead, EPA recommends that the potential to emit be determined based upon an estimate of the maximum amount of hours the generator could operate, taking into account (1) the number of hours power would be expected to be unavailable and (2) the number of hours for maintenance activities.

The EPA believes that 500 hours is an appropriate default assumption for estimating the number of hours that an emergency generator could be expected to operate under worst-case conditions. Alternative estimates can be made on a case-by-case basis where justified by the source owner or permitting authority (for example, if historical data on local power outages indicate that a larger or smaller number would be appropriate). Using the 500 hour default assumption, EPA has performed a number of calculations for some typically-sized emergency generators. These calculations indicate that these generators, in and of themselves, rarely emit at major source levels. (Of course, there may be unusual circumstances where these calculations would not be representative, for example where many generators are present that could operate simultaneously).

Cautions

Today's guidance is only meant to address emergency generators as described. Specifically, the guidance does not address: (1) peaking units at electric utilities; (2) generators at industrial facilities that typically operate at low rates, but are not confined to emergency purposes; and (3) any standby4

generator that is used during time periods when power is available from the utility. This guidance is also not intended to discourage permitting authorities from establishing operational limitations in construction permits when such limitations are deemed appropriate or necessary. Additionally, this memorandum is not intended to be used as the basis to rescind any such restrictions already in place.

Distribution/Further Information

The Regional Offices should send this memorandum to States within their jurisdiction. Questions concerning specific issues and cases should be directed to the appropriate Regional Office. Regional Office staff may contact Tim Smith of the Integrated Implementation Group at 919-541-4718. The document is also available on the technology transfer network (TTN) bulletin board, under "Clean Air Act" - "Title V" - "Policy Guidance
Memos". (Readers unfamiliar with this bulletin board may obtain access by calling the TTN help line at 919-541-5384).

cc:Air Branch Chief, Region I-X Regional Air Counsels, Region I-X Adan Schwartz (2344) Tim Smith (MD-12)