Authors: Chris Howard | November 9, 2022
Does a stationary engine support your operations?
Did you know that there are compliance obligations even when a permit might not be required? Have you reviewed the requirements to comply with the applicable regulations? If you haven’t assessed them recently, now is the time.
Periodically the Environmental Protection Agency (EPA) Office of Enforcement and Compliance Assurance (OECA) issues Compliance Advisories and Enforcement Alerts. The Advisories and Alerts identify Agency requirements and priorities at the time of publication.
EPA Violations
In August 2022, the OECA issued an Enforcement Alert titled Stationary Engines Cause Excess Emissions in Communities Across the Country. The purpose of the Alert was to note that the EPA has been identifying numerous violations of the applicable Clean Air Act requirements, and that the Agency has taken enforcement actions and assessed substantial penalties for facilities that have failed to comply. Some of the violations noted included failure to retrofit engines with required pollution controls; installation of pollution controls without conducting follow-up testing; and using engines for demand response programs run by electricity system operators, which now removes these engines from emergency status.
“Virtually all engines are subject to the Federal engine standards of NSPS Subpart IIII, NSPS Subpart JJJJ or NESHAP Subpart ZZZZ. Also, while some engines may be exempt from permitting, they still must comply with the applicable Federal standards.”
Chris Howard
Air Measurement Office Practice Lead
How TRC Can help?
TRC provides extensive experience with these Federal standards and can assist your facility in ensuring compliance. We can conduct an applicability review to determine which standards, if any, apply; review engine design and recordkeeping procedures to ensure compliance; prepare air permit applications; and conduct performance testing and prepare the associated reports.
Contact emissions expert Chris Howard to discuss what standards may be applicable to your stationary engine: CHoward@TRCcompanies.com
Sharing Our Perspectives
Our practitioners share their insights and perspectives on the trends and challenges shaping the market.
EPA Proposal Strengthens Air Quality Standards for Synthetic Organic Chemical Plants and Polymers and Resins Plants
September 20, 2023
Clean Air Act Bolstered with 10 New Proposed Standards and Rules
EPA Proposes Changes to Air Emissions Reporting Requirements (AERR)
August 30, 2023
The EPA is proposing updates to their Air Emissions Reporting Requirements (AERR) through amendments to 40 CFR Parts 2 and 51.
Consequences of a Lowered NAAQS for PM2.5
February 16, 2023
TRC breaks down the significance of EPA lowering the NAAQS for PM₂.₅
EPA Penalizing Stationary Engine Violations
November 9, 2022
The EPA is identifying violations of the Clean Air Act and has taken enforcement actions and assessed penalties.
TRC Acquires United Sciences Testing, Inc., Expanding Air Management Capabilities
February 23, 2022
TRC Companies (“TRC”), announced the expansion of its Air Management capabilities with the acquisition of United Sciences Testing, Inc. (USTI), who provides emissions testing services to utility and industrial clients within the Great Lakes and Midwest regions of the US.
Managing EHS & ESG Risks Through Integrated Systems Today and Beyond
July 22, 2021
It has been more than 50 years since the development and establishment of the federal Environmental Protection Agency (EPA) and the federal Occupational Safety & Health Administration (OSHA) which were formed to protect our environment and workplaces across the United States. Significant laws, policies and regulations followed to establish the “regulatory programs” that all applicable businesses and entities must address and meet to ensure these compliance-driven legislative programs would create a foundation to protect our society.
EPA Proposes New Emissions Limits for Combustion Turbines
May 22, 2021
After 15 years of legal limbo, combustion turbines could be facing new emissions standards under a proposal introduced by the EPA.
EPA Ramps Up Inspections and Enforcement Actions
May 14, 2021
EPA’s acting enforcement chief, Larry Starfield, directs agents to ramp up inspections in communities known to be afflicted by pollution
EPA Clean Air Act Rulemaking Announced December 2020
December 31, 2020
EPA announces Clean Air Act Rulemaking in the final month of the current administration and indicates more could be announced before the new administration comes into office.
New Jersey’s Landmark Environmental Justice Law
November 24, 2020
On April 19 the EPA published proposed revisions to the National Emissions Standard for Hazardous Air Pollutants (NESHAP) for stationary combustion turbines that would set limits on formaldehyde emissions and expand the category to include additional turbine types EPA had sought to delist. The proposed revisions would implement the emissions limits of the original 2004 NESHAP and expand the affected units to include gas-fired lean pre-mix and diffusion flame units. The revised standard reflects required Risk and Technology Review (RTR) of NESHAP. The turbine RTR, like the RTRs for a number of other categories, was years overdue. Due to the lateness of many RTR programs EPA is under court order to complete the RTRs for 33 source categories by 2021.
EPA Finalizes Reversal of “Once In Always In” Air Pollution Policy
November 18, 2020
On October 1, 2020, the EPA finalized a ruling that no longer enforces the “once in, always in” air emissions policy.
Chris Howard
Chris Howard, PE is the Air Measurement Office Practice Lead at TRC Companies for the Baton Rouge, Louisiana office. He received his Bachelor of Science Degree in Civil Engineering from Louisiana State University in 1993 and has over 25 years of experience in multi-media environmental compliance consulting with a primary focus in air compliance and permitting along with solid waste compliance, spill prevention planning and response, and project management. Contact Chris at choward@trccompanies.com.