Understanding Air Permits for Emergency Generators in New Jersey

No business wants to lose money from unforeseen power outages. Unfortunately, this is what could happen when commercial or healthcare buildings lose power and do not have a backup plan to instantaneously restore services.

Emergency generators for commercial and healthcare settings enable a continuous stream of power for various business activities and sustain the health and safety of the occupants of the building. They can help avoid costly losses and dangerous scenarios if the grid is down for any length of time.

When planning on establishing an emergency generator system in their NJ facilities, owners should know that they may need a general air permit to use the equipment. Standards for the use of emergency generators are governed by the New Jersey Department of Environmental Protection (NJDEP).

Why do Emergency Generators Need an Air Permit in New Jersey?

Diesel and gasoline generators release various harmful pollutants

carbon monoxide (CO)
nitrogen oxides (NOx)
sulfur oxides (SOx)
particulate matter (PM)

These emissions contribute to air pollution, pose risks to human health, and play a role in climate change. Nitrogen oxide, in particular, is currently the most significant contributor to ozone depletion. It also contributes to acid rain and smog.

Diesel exhaust also comprises toxic contaminants that are known or suspected to be carcinogens, like:

benzene
arsenic
formaldehyde

While the use of emergency generators is critical for business operations, it is imperative to implement measures to mitigate its associated environmental and health risks. NJDEP does this through emergency generator air permitting.

When is an Air Permit for Emergency Generators Needed?

A facility needs an NJDEP air permit in accordance with N.J.A.C. 7:27-8 if the maximum rated heat input is 1,000,000 BTU/hr or greater. Guidance to assist in determining applicability is if the maximum fuel consumption of the emergency generator exceeds the following specific values:

Natural Gas: More than 980 ft³/hour (with a heat value of 1,020 Btu/ft³).

Propane (LP): More than 397 ft³/hour (with a heat value of 2,516 Btu/ft³).

#2 Fuel Oil: More than 7.04 gallons/hour (with a heat value of 142,000 Btu/gallon).

The use of emergency generators in NJ will often require a general air permit instead of a preconstruction air permit. However, emergency generators with a general permit should only be operated in the following cases:

During normal testing and maintenance procedures, as required by the manufacturer or regulations and in accordance with the annual hour limit established in the permit.
During power outages or when the primary energy source fails because of an emergency.
When Pennsylvania-NewJersey-Maryland (PJM) Interconnection issues a voltage reduction notice on its website under “emergency procedures.”
The emergency generator can only be operated on days when the air quality in the zip code or township of the facility is forecast to be Good or Moderate. Generators cannot be operated for routine testing if the air quality is Unhealthy for Sensitive Groups, Unhealthy, Very Unhealthy, or Hazardous. Air quality forecast should be checked prior to operation of the generator at the EPA website Air Now – https://www.airnow.gov/. This does not apply if the generator has to be operated due to an emergency outage.

Exceeding the limitations of a general permit would necessitate obtaining either a preconstruction or operating permit.

General Air Permits for Emergency Generators in New Jersey

There are various types of general air permits for emergency generators. Identifying which permit to apply for will help ease the process and help identify the unique compliance requirements for each category.

Minor Facilities:

GP-005A: Revised Emergency Generator Burning Distillate Fuels

Covers single or multiple emergency generators burning distillate fuel with a maximum rated heat input of less than 100 million MMBTU/hr.

GP-005B: Revised Emergency Generator Burning Gaseous Fuels

Covers single or multiple emergency generators burning gaseous fuel with a maximum rated heat input of less than 70 MMBTU/hr.

Major Facilities:

GOP-003for a single emergency generator with a maximum rated heat input of less than or equal to 30 MMBTU/hr.
GOP-004for a single emergency generator burning gaseous fuels.

GP-005A and GP-005B: New General Air Permits for Emergency Generators

GP-005A and GP-005B are an amendment to the previous air permit requirement, released in 2019. Emergency generators registered under the old GP-005 can continue operating until one of the following scenarios occurs:

Expiration of current general permit: Before this expiration, the owner must register for authorization under GP-005A or GP-005B, if applicable.
Replacement or modification of emergency generator equipment: Before using the new or modified generator, owners are required to register for authorization under GP-005A or GP-005B, if applicable.

Requirements to Achieve NJDEP Permit Compliance

To achieve NJDEP permit compliance, the business or facility needs to satisfy permit conditions, implement best practices, and adhere to reporting schedules.

Here are some of the standards the business needs to fulfill to attain compliance:

Emergency Generators Under GP-005A and GOP-003

Emergency generators manufactured in the model year 2007 and beyond must have a certified engine.
The Distillate fuel used should have a maximum sulfur content of 15 ppm.
For minor facilities with existing engines, pollution prevention measures that include inspections or oil changes must be applied to enhance engine efficiency.

Emergency Generators Under GP-005B and GOP-004

Emergency generators are required to have the Environmental Protection Agency (EPA) conformity certification.
Implement pollution prevention measures, including inspections and/or oil changes, to enhance engine efficiency.

Air Quality Testing

Regulatory agencies NJDEP and EPA mandate generator emission certification as part of the air permit approval process. In some cases, equipment may already come with certification from the generator supplier.

If an emergency generator is not certified by its supplier, it should be tested for air quality emissions. Facilities must demonstrate through testing that emissions from their generators do not exceed state and federal air quality limits. Air quality testing for emergency generators is crucial to confirm that the generator operates within acceptable emission limits and complies with environmental regulations.

It is best to consult with an NJDEP air permit consultant to execute the test based on methods approved by NJDEP and EPA.

Need Help Getting an Air Permit for Emergency Generator in New Jersey?

If determining whether your emergency generator requires an air permit in New Jersey seems overwhelming, you are not alone. Seek the help of those with NJDEP compliance expertise to help you get through this obstacle.

Lockatong Engineering specializes in understanding the intricacies of air permits for generators and addressing environmental concerns for your facility. We have the knowledge to guide you through compliance with environmental laws and regulations and make your business compliant with relevant laws.

Whether you are dealing with NJDEP permit compliance issues or need assistance in applying for an air permit, Lockatong Engineering is here to help. Reach out to us for consultation and support.