INSIGHTS

Fourth of July, 1998

Advanced
Environmental General Permits
Interface, Inc. for Emergency Engines
8 Old Indian Trail
Middlefield, CT 06455
(860) 349-3559

This issue of Insights deals with emergency engines, and requirements to

register them with the Department of Environmental Protection (DEP)
under a new general permit.
• Site investigation An emergency engine is simply one that
drives:
• Remediation
• an emergency electrical power
• Permits
generator; or
• Compliance audits
• an emergency pump for a fire
• Hydrogeology protection or water supply system; or
• Risk assessment • an emergency compressor or any
• Property transfers other engine-driven device that is
designed to operate only in an
• Underground tanks
emergency, not routinely.
• Air quality A typical engine is about the same size as found in a moving van. A
typical electrical output is that sufficient to power a medium-size apartment
• Litigation support
building. Last year, DEP published a general permit (called the GPEE
• Management systems permit) requiring registration of any existing or planned emergency
• Hazardous wastes engines above a minimum size threshold. There is a significant number of
• Emergency planning such engines in Connecticut. Hospitals, schools and municipal buildings,
as well as certain industrial and commercial facilities, require emergency
• Bioreclamation
electrical or mechanical power in the event of a power outage by the
• Regulation tracking electric utility service.
• Constructed wetlands
• Process qualification DEP is not interested in limiting the use of engines for emergency power
purposes. The general permit carries a simple restriction on the number of
hours per year that the generator is allowed to operate. The operating
INSIGHTS is published
on an as-needed basis to
hours allowed are generally far greater than your need for emergency
inform our clients and power or periodic system testing. The permit does not impose any
friends in the industrial emission control requirements on existing systems, except for burning low
community about sulfur fuel. (Also, please note that the information in this Insights applies
environmental topics of
high current interest. only to reciprocating engines, not to jet engines (such as used by electric
utilities for backup power).

Insights 98-2 / Emergency Engine Permit

Fourth of July, 1998 Page 1 of 4
© AEI 1998
This material describes emergency engines and provides some useful calculation tools and
reference information to clarify the registration process under the GPEE permit. The tables and
diagrams are intended to help facility managers who want to do the registration, but don't know
much about engines or air emissions. The information offered below is for background and
reference; it stops short of explaining in detail how to register an engine. That is covered very well
in the DEP GPEE instruction package. Registration is not difficult, but if you don't want to try it,
please give us a call.
Figure 1: An example of a small emergency electrical power generator, showing the power balance, for you to
use as reference and comparison to your own situation.

Engine Side Generator Side

Heat Loss via Combustion Exhaust = 127 kW Mechanical Power Transferred from
Engine to Generator = 157 kW
Heat Rejected to Room Air = 28 kW
Generator Heat Rejected
Heat Rejected to Cooling System = 92 kW to Room Air = 13 kW
Power Loss to Fan = 5 kW

Fuel Feed at Full Power Rating = 10.2 gal/hr diesel fuel Electrical Power Output
(Equivalent to 408 kW or 1.39 MMBTU/hr) from Generator = 143 kW

Efficiencies for This Example Useful Conversion Factors

Engine: (157 kW / 408 kW) = 38% 1 kW = 3410 BTU/hr
Generator: (143 kW / 157 kW) = 91% 1 kW = 1.34 hp (brake)
System: (143 kW / 408 kW) = 35% 1 kW-hr = 0.00341 MMBTU
1 hp-hr = 0.00254 MMBTU

Table 1: Some sources of useful information about emergency engines and generators.
Mfr Phone E-Mail Internet
Caterpillar (309) 675-1000 [email protected] http://www.cat.com
Cummins 1-800-343-7357 [email protected] http://www.cummins.com
Kohler (920) 544-2444 [email protected] http://www.kohlerco.com
Onan (804) 589-2415 [email protected] http://www.genset.com/onan.htm
Waukesha (414) 547-3311 [email protected] http://www.waukeshaengine.com

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Fourth of July, 1998 Page 2 of 4
© AEI 1998
 Table 2: A process for estimating fuel consumption, heat input, and NOx potential emissions based on engine or
generator nameplate information. You need these parameters to fill out the GPEE registration form.
See Figure 2 on the next page for quick estimation.

Step Action Comment

1. Find the engine mechanical power rating. This is expressed as horsepower (hp) or sometimes
(Example from Figure 1 , opposite page: 211 hp) as brake horsepower (bhp) on the engine nameplate
or in the operations manual specs.
2. Find the electrical power output rating on the This is expressed as kilowatts (kW) or sometimes
generator side of the equipment. as kilovolt-amps (kVA) on the generator nameplate
(Example: 143 kW) or in the operations manual specs. If kVA, multiply
by the stated power factor (typically 0.8) to get kW.
3. Use the manufacturer's specs for fuel consumption If you use the specification given in the operations
if available. If not, multiply the mechanical power manual, make sure it is not the max pumping
rating (hp) from Step 1, or the electrical rating (kW) capacity of the fuel pump, which may be a lot higher
from Step 2, by one of the following conversion than the engine actually can consume.
factors to get fuel consumption, as follows:
multiply multiply The conversion factors at left give maximum fuel
hp by: kW by to get consumption of consumption at the rated engine power or generator
electrical output (based on typical engine efficiency
0.0476 0.0711 diesel fuel (gal/hr)
of 38%, generator efficiency of 91% and system
0.0502 0.0749 gasoline (gal/hr)
(engine + generator) efficiency of 35%).
0.0720 0.107 propane liquid (gal/hr)
2.61 3.90 propane gas (cf/hr)
gal = gallon
6.53 9.75 natural gas (cf/hr)
cf = cubic foot
(Example: 143 kW x 0.0711 = 10.2 gal/hr) hr = hour
4. Multiply the result in Step 3 by the appropriate mmBTU/hr is a million British Thermal Units (a
conversion factor to get maximum heat input (in measure of energy) per hour. The conversion
mmBTU/hr), as follows: factors are based on average energy content
gal/hr diesel fuel x 0.137 = mmBTU/hr values and fuel densities as follows:
gal/hr gasoline x 0.130 = mmBTU/hr Fuel Energy Content Density
gal/hr propane liquid x 0.091 = mmBTU/hr diesel fuel 137,000 BTU/gal 7.05 lb/gal
cf/hr propane gas x 0.0025 = mmBTU/hr gasoline 130,000 BTU/gal 6.17 lb/gal
cf/hr natural gas x 0.001 = mmBTU/hr propane liquid 91,000 BTU/gal 4.24 lb/gal
(If the engine burns #2 heating oil or kerosene, use propane gas 2500 BTU/cf 0.105 lb/cf
the factor for diesel fuel.) natural gas 1025 BTU/cf 0.042 lb/cf
(Example: 10.2 gal/hr x 0.137 = 1.39 mmBTU/hr)
5. Compare the number calculated above to the If greater than 5.0 mmBTU/hr, check with DEP,
regulatory threshold criterion for maximum heat since other permitting requirements possibly may
input of 5.0 mmBTU/hr. apply to this emergency engine.
(Example: 1.39 < 5.0 ; no other requirements)
6. Multiply the result in Step 3 by one of the following Based on the current EPA AIRS, FIRE and AP-42
conversion factors to get maximum potential NOx emission factors, as listed in the GPEE instruction
emissions (in tons/yr): package, multiplied by 8760 hrs/yr and divided by
gal/hr diesel fuel x 2.65 = NOx (tons/yr) 2000 lbs/ton. If you have a different, verifiable NOx
gal/hr gasoline x 2.05 = NOx (tons/yr) emission factor specified by the manufacturer, use
gal/hr propane liquid x 1.37 = NOx (tons/yr) that instead. (These are frequently found in tables
cf/hr propane gas x 0.0378 = NOx (tons/yr) of test data of the engine at different power levels in
cf/hr natural gas x 0.0127 = NOx (tons/yr) the engine operations manual; make sure you pick
the factor for the full rated power level.)
(Example: 10.2 gal/hr x 2.65 = 27.0 tons/yr of NOx)
7. Compare the number calculated above to the permit If greater than 5.0 tons/yr potential NOx emissions,
threshold criterion for potential NOx emissions of a GPEE registration is required for new or existing
5.0 tons/yr. units. Engines smaller than 40 hp, or generators
(Example: 27.0 > 5.0; need to register this engine) smaller than 27 kW, are not regulated under current
DEP rules.

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Fourth of July, 1998 Page 3 of 4
© AEI 1998
Figure 2: Relationship estimator between power, fuel consumption and NOx emissions for different fuels.
Diesel Fuel Gasoline
02 7 0 00 . 2 6 01 . 9 01 . 1 0 03 4 0 0 0 01 . 1 0
40 5.0 51 0.33 2.4 5.0
100 10 100 10
100 1.00 20 100 1.00
200 5 200 10 20
10 5
30
200 300 2.00 200 300 2.00 30
40
10
400 50 400 20 40
20 10
300 3.00 300 3.00
60 50
500 500
15
70
400 600 400 600 30 60
4.00 30 4.00
80 15
700 20 700 70
90
500 765 5.00 36.5 22.1 96.7 500 765 5.00 38.5 18.0 78.9
513 800 100 513 800 40 80
40
25 110 20 90
600 900 600 900
6.00 6.00

Liquid Propane Gaseous Propane

0 0 0 0 0 0 0 0 0 0 0 0
34 50 0.32 3.6 1.1 5.0 34 50 0.32 132 1.1 5.0
100 10 100
10
100 1.00 10 100 1.00
200 20 200 500 20
5 5
300 20 300
200 2.00 30 200 2.00 30
400 40 400 1000
30 40
300 10 300 10
3.00 3.00
500 50 500
50
40
600 600 1500
400 4.00 60 400 4.00 60
15 15
700 50 70 700
5.00 54.9 17.3 75.6 17.3 70
500 765 500 765 5.00 2000 75.6
513 800 513 800
80 80
60
900 20 900 20
600 600
6.00 6.00

Natural Gas By setting a straight edge across any of these figures, you can estimate
the relationship between power, fuel consumption and NOx emissions,
0 0 0 0 0 0
40 60 0.39 393 1.1 5.0 within about 5%.
100
10 Power is energy per unit time and may be expressed as electrical (kW),
100 1.00 1000 mechanical (hp), or heat rate (mmBTU/hr). The above estimators assume
200
that an engine is 38% efficient and that an engine-generator combination
5 20
300 is 35% efficient. See Figure 1 for the power balance around a typical
200 2.00 2000 engine and generator.
400 30
The emission factors that are the basis for the NOx emission rates were
300 3.00 3000 taken from the DEP GPEE instruction package. NOx emission rate
500 40
10 (lbs/hr) assumes full rated engine power. NOx potential emissions
600 (tons/yr) assumes the engine runs continuously at its full rated power all
400 4.00 4000
50 year (8760 hours).
700
500 765 5.00 5000 14.5 60 The top dotted line with numbers in italics represents 5 tons/yr of
513 800 15 63.6 potential NOx emissions. If the hp or kW ratings are less than these
numbers, there is no need to register the engine. The bottom dotted
900 70 line with numbers in italics represents 5 mmBTU/hr heat input. If the hp or
600 6.00 6000 kW ratings are greater than those numbers, other requirements may
apply; check with DEP or call us.
Our Insights newsletters attempt to simplify complex environmental requirements and provide operationally useful tools, by looking at regulations from the
viewpoint of the average industrial plant manager. This tool may or may not be applicable to your facility. It is intended for informational purposes only, and
carries no express or implied warranty. It is not a legal advisory; we're not attorneys. The air regulations, the DEP, or your attorney should be consulted
regarding any legal implications.

Insights 98-2 / Emergency Engine Permit

Fourth of July, 1998 Page 4 of 4
© AEI 1998