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

 
Quality Certificate and Checklist document inspecting target

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

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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.