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Regulatory Advisory

Proposed Rule for National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines

The EPA is soliciting comments for the above proposal. The proposal will potentially impact each hospital emergency generator but will not require any additional effort beyond what is typically already being done by hospital engineers and facility managers.

For emergency generators less than 500 HP, the proposal essentially requires “management practices” but does not require performance testing. For generators greater than 500 HP; in addition to the management practices, there is a proposed emission limit of 2 ppm formaldehyde, but no required performance testing.

Essentially the requirements for emergency generators as described under Management Practice are:

  1. Change oil  and filter every 500 hours
  2. Inspect air cleaner every 1000 hours
  3. Inspect all hoses and belts every 500 hours and replace as necessary
  4. Install a non-resettable hour meter on the generator

In addition, the yearly limit on use is 100 hours for maintenance/testing and emergency generators “may not engage in income-generating activities.” Operators can petition for more than 100 hours if necessary for maintenance/testing purposes. A petition is not required if longer hours are mandated by State or local requirements. There is no time limit for use during emergencies, but the length and reason for the operation must be documented. Documentation is also required for the management practices portion of the proposal.

The deadline for comments has been extended to June 3, 2009.

The actual document is rather long and is not intuitive.  It is separated into engines located near major sources of pollution and area sources of pollution. The requirements for those near major sources include performance standards and maximum levels of carbon monoxide or formaldehyde depending on the engine HP. The vast majority of hospitals will not fall in to the category of being near major sources of pollution. For the sake of this proposed rule ASHE recommends it is prudent to assume that each hospital is essentially an area source of pollution and should ensure that their current maintenance practices include the 4 items identified by EPA in the Management Practices.