What are the reporting EPA requirements for my diesel generator in Florida?

Initial Rice neshap generator compliance emissions testing
EPA generator compliance can be complicated… with the wrong contractor.

We get a lot of questions about your future reporting and retesting requirements under EPA 40 CFR part 63 ZZZZ – commonly know as RICE NESHAP, from diesel generator owners.

Typically this information would be provided by your compliance contractor, as part of the required Site-Specific Monitoring Plan – NOTE: many aren’t aware of the requirements for this… we are and can provide you with this information if you don’t have it.

 

Reporting is only required for RICE (diesel engines) over 500HP/ >200kW generators. RICE between 300 and 499HP only requires the initial compliance Performance test – no additional reporting or testing 🙂

Here are the regulations verbatim from the EPA’s website:

4.0 Reporting and Recordkeeping Requirements

References: 40 CFR 63.6650

40 CFR 63.6655

40 CFR 63.6660

Table 7 to Subpart ZZZZ of Part 63 (40 CFR 63, subpart ZZZZ, Table 7)

4.1 General Information

Owners and operators must submit the following reports to the permitting authority by the dates outlined below. Records must be maintained as outlined to demonstrate compliance.
4.2 Initial Notification of Applicability

RICE NESHAP requires facility owners or operators to report to their regional EPA office if their facility falls under the provisions stated in 40 CFR Part 63 Subpart ZZZZ (applies to both CI and SI RICE).
This notification should have been submitted in writing by February 16, 2011 for spark-ignited engines and / or August 31, 2010 for compression-ignition engines, or 120 days after you become subject to the relevant standard.
Initial notification is the responsibility of the owner/operator of the source.
A sample form is included in Appendix A.

4.3 Semi-Annual Compliance Reports (For RICE operated 100 hours per year or more)

Semi-Annual Report I
Reporting period covers the first calendar half (January 1 – June 30)
Postmarked or delivered to the permitting authority no later than July 31

Semi-Annual Report II
Reporting period covers the second calendar half (July 1 – December 31)
Postmarked or delivered to the permitting authority no later than January 31

Note: If you already submit semi-annual reports as part of a compliance program with your current air quality permit, you may submit the first and subsequent semi-annual compliance reports according to the dates established by the permitting authority instead of those outlined above.

4.4 Annual Compliance Report (For RICE operated less than 100 hours per year)

Annual Compliance Report
Reporting period covers the entire calendar year (January 1 – December 31)
Postmarked or delivered to the permitting authority no later than January 31

Note: If you experienced a deviation from any emission limitation or operating limitation, a period during which the CPMS was out-of-control, the compliance report shall be submitted semiannually.

4.2 Minimum Requirements of a Compliance Report

Company name and address.
Statement by a responsible official, with that official’s name, title, and signature, certifying the accuracy of the content of the report.
Date of report and beginning and ending dates of the reporting period.
If you had a malfunction during the reporting period, the compliance report must include the number, duration, and a brief description for each type of malfunction which occurred during the reporting period and which caused or may have caused any applicable emission limitation to be exceeded. The report must also include a description of actions taken by an owner or operator during a malfunction of an affected source to minimize emissions, including actions taken to correct a malfunction. For more information, please refer to 40 CFR 63.6650.

If there are no deviations from any emission or operating limitations that apply to you, a statement that there were no deviations from the emission or operating limitations during the reporting period.

If there were no periods during which the continuous monitoring system (CMS), was out-of-control, a statement that there were no periods during which the CMS was out-of-control during the reporting period.

4.6 Recordkeeping Requirements

Maintain a copy of each notification and report that was submitted to comply with this subpart, including all documentation supporting any Initial Notification or Notification of Compliance Status.

Maintain records of performance tests and performance evaluations

Maintain and generate records of all required maintenance performed on the engine generator, air pollution control and monitoring equipment, including all calibration checks and adjustments. Examples of equipment include:
Stationary internal combustion engine, including on-board emission control equipment (if any)
Oxidation catalyst
Continuous parameter monitoring system or continuous emission monitoring system
Open or closed crankcase ventilation systems, including element replacement

Maintain records of the occurrence and duration of each malfunction (including inoperative or out-of-control periods) of operation on the air pollution control and monitoring equipment.

Maintain records of actions taken during periods of malfunction to minimize emissions, including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation.

Maintain records of all required measurements needed to demonstrate compliance with a relevant standard (including, but not limited to, averages of CMS data, raw performance testing measurements, and raw performance evaluation measurements, that support data that the source is required to report).

Purchase and maintain records that indicate ultra low sulfur diesel meeting the following requirements is burned at the facility (For existing, non-emergency, compression ignition engines greater than 300 horsepower).

4.7 Record Retention

Records must be kept for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record.

Records must be in a form suitable and readily available for expeditious review upon request by the permitting authority. A printed ‘hard copy’ or electronic form is acceptable.

NOTE: Your Site-Specific Monitoring Plan will be the first thing an EPA compliance officer requests, when doing an audit of your diesel engine generator. So you can understand how critical it is that this plan is maintained and up-to-date at all times.

More questions? Call John Macgowan 727-432-5335

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