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New USEPA Mandates to Impact Backup Generators Enrolled in Peak Shaving Programs in 2013EPA

New U.S. Environmental Protection Agency (USEPA) mandates go into effect this year that will require all engines built prior to June 12, 2006 to complete exhaust upgrades to reduce the emission of greenhouse gases.  In order to be compliant with the new National Emissions Standards for Hazardous Air Pollutants (NESHAP) for stationary Reciprocating Internal Combustion Engines (RICE), upgrades to non-emergency standby diesel powered generators, including units providing backup power to water and wastewater treatment plants, must be completed by May 13, 2013.  Upgrades to non-emergency gas powered generators must be upgraded by October 13, 2013.  

In general, the engines that need to be retrofitted are diesel generators that are greater than 300 horsepower (about 200 kilowatts) that are used for peak shaving or storm avoidance applications, which are considered non-emergency use.  The retrofits will likely consist of diesel oxidation catalysts (DOC) or crankcase ventilation systems.  Testing of hazardous air pollutant emission control equipment must be performed within 180 days of activation.  Also, the use of ultra-low sulfur diesel fuel is required. 

For emergency use generators, the new RICE NESHAP regulation requires the oil and filter to be changed, and hoses and belts to be inspected every 500 hours of operation or annually, whichever comes first.  Also, the air cleaner needs to be inspected every 1,000 hours of operation or annually, whichever comes first. 

How RICE NESHAP mandates affect you:

If you have a generator that meets the selection criterion that is listed above, the exhaust upgrades have to be fully operational by May 13, 2013 or the generator will have to be removed from any peak shaving or storm avoidance program. AE2S Electrical Engineer Adam Wahler recommends having a professional analyze your backup generation system on a case-by-case basis.  Wahler says, “There isn’t a one-size-fits-all solution to this issue.”

Things to consider when deciding how to proceed with RICE NESHAP compliance:

Lead time and cost of exhaust upgrades: It is not uncommon for the exhaust upgrades to range in cost from $30,000 to $100,000 depending on generator configuration, installed accessories, and age.

Peak Shaving Program Analysis:  The economic benefit and risk exposure of each peak shaving program offered by various serving electric utility companies vary drastically between programs.  A detailed analysis should be performed to determine the payback schedule when analyzing the cost of exhaust upgrades; economic risk in the form of penalties if the generator fails to run; penalties for forfeiting enrollment in a peak shaving program without proper cancellation notice, which can be as long as 3 years; and savings from being enrolled in the program itself.

For more information regarding the new mandates and the specific impacts to your system, contact Adam Wahler at Adam.Wahler@ae2s.com.



If you have any questions concerning the content of this newsletter,
please contact Heather Syverson at 701-364-9111 or Heather.Syverson@ae2s.com.
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