The following policy has been developed to ensure the University and Medical Center's emergency generator units are selected, installed, and maintained in accordance with applicable regulations. The United States Environmental Protection Agency (USEPA) sets performance standards for new generators, including emergency and non-emergency units. Currently, the University has only emergency generators.
Authority and Responsibility
Environmental Health and Safety shall be responsible for:
- Alerting the Environmental Consultant when the installation/renovation of an emergency generator is proposed by the University or Medical Center's project managers.
Environmental Consultant (Mostardi Platt) shall be responsible for:
- Assisting the Project Managers during the selection and installation of a new emergency generator. Creating permit application and/or notification to IEPA/EPA as applicable;
- Calculating the emissions based on the monthly fuel usage and hour usage submitted by the maintenance shop responsible for each unit;
- Conducting the annual emissions testing as outlined in the permit;
- Ensuring all permit conditions are listed and managed in the Compliance Management Platform hosted by Mostardi Platt;
- Uploading all documentation related to testing and periodic reports and linking the documents to the permit conditions listed in the Compliance Management Platform;
- Submitting the Annual Emissions Report (AER) to the Illinois Environmental Protection Agency (IEPA); and
- Retaining manufacturer certification of generator units as provided by Project Managers;
Facilities Services Capital Project Delivery and Medical Center - Facilities, Design, and Construction shall be responsible for:
- Informing Environmental Health and Safety when a generator will be installed or renovated. See the Project Planning and Design Review Checklist;
- Selecting a manufacturer certified emergency generator that complies with emission standards (see below);
- Selecting a generator with a non-resettable hour meter;
- Providing documentation of manufacturer certification to the consultant;
- Submitting a construction permit application and applicable fees to the Illinois Environmental Protection Agency (IEPA) to install a generator with an engine size greater than or equal to 1,118 kW or submitting a formal notification to the IEPA at least 7 working days before installation of units below 1,118 kW;
- Submitting an application to the City of Chicago to install any generator; and
- Ensuring the proper engineering shop participates in the commissioning process and the periodic maintenance tasks required by the manufacture and the Title V permit are assigned.
Facilities Services Operations and Maintenance and Physical Plant shall be responsible for:
- Ensuring compliance with the Title V Clean Air Act Permit;
- Maintaining records confirming the use of only ultra-low sulfur diesel in all generator
- Contacting Environmental Health and Safety or their direct supervisor to register for Mostardi Platt's web-based recordkeeping platform;
- Acting as the point of contact to coordinate testing with the consultant or participating in bi-annual inspections with regulatory agencies for regulated equipment;
- Ensuring the generator does not exceed annual operational limits for hours and fuel, including maintenance and readiness checks;
- Submitting the run time, load, and fuel usage on a monthly basis to the web-based compliance platform;
- Uploading any testing data required per the conditions of the permit and uploading documents to the web-based compliance platform;
- Ensuring all of the tasks listed in the Clean Air Act permit are linked to Maximo preventative maintenance tasks and also linked to the tasks within Mostardi Platt's Compliance Management Platform;
- Maintaining the owner's manual on-site, to ensure proper operation of each generator;
- Maintaining operator logs and service records from outside contractors (ex. Lionheart) to document hours of operation;
- Documenting run time (hours) and reason an emergency generator operates for any other reason than testing, maintenance, or readiness checks;
- Operating and maintaining the generator according to the manufacturer's written instructions; and
- Purchasing diesel fuel with a sulfur content of less than or equal to 15 parts per million (ppm), deemed ultra-low sulfur diesel.
Emission and performance standards for diesel generators, known as "compression-ignition internal combustion engines," are located in Title 40 of the Code of Federal Regulations (CFR) Part 60 (4200 - 4219). Under these regulations, diesel generators must meet the requirements of 40 CFR Parts 89, 94, or 1068, as applicable. The manufacturer must certify the generator meets the requirements and provide appropriate documentation.
The diesel storage tanks and/or belly tanks attached to the equipment must be registered with EHS to ensure a spill kit is provided and any other storage requirements comply with other state and federal regulations.
Natural Gas Generators
Emission and performance standards for natural gas generators, known as "spark-ignition internal combustion engines," are located in 40 CFR Part 60 (4230 - 4248). Under these regulations, natural gas generators must meet the requirements of 40 CFR Parts 90, 1048, or 1054, as applicable. The manufacturer must certify the generator meets the requirements and provide appropriate documentation.
Stationery generators (permanent or temporary) with an engine size greater than or equal to 1,118 kW are considered significant emission sources by Illinois Environmental Protection Agency (IEPA). Note that the power rating of the generator and the engine may vary.
All significant emission sources must submit an application to request a construction permit from the IEPA. The University and/or Medical Center cannot begin construction (e.g., pouring concrete pad) nor purchase the proposed generator until we have received a signed construction permit from the IEPA.
The Project Manager and the vendor installing the generator must complete the application and procure the assistance of the University's preferred vendor for Title V permitting. The cost for the permit and any required testing is considered a project cost.
NOTE: The IEPA application process takes several weeks (3 - 4 months) and the fees are dependent on the size of the generator, fuel type, and the potential emissions.
The construction permit application must include:
- Project Description;
- Site Layout;
- Process Flow Diagram;
- Engine Emission Calculations;
- IEPA Form 199-CAAPP "Construction Permit Application for a Proposed Project at a CAAPP Source";
- IEPA Form 197-CAAPP "Fee Determination for Construction Permit Application";
- Appropriate Fees; and
- IEPA Form 270-CAAPP "Stationary Internal Combustion Engine or Turbine Data and Information."
A construction permit must be submitted to the City of Chicago Pollution Control Board for every generator installed onsite regardless of size or fuel type. This policy does not cover the City of Chicago's Air Pollution Control Permits as those are handled by the project manager as part of the construction or installation process. The submittal of a permit requires the project manager to transfer responsibility to the responsible engineering shop to coordinate operational certifications and the payment of any applicable fees if deemed necessary by the City.
The operation of emergency generators for maintenance and readiness checks must stay below the operational thresholds outlined in the Title V permit. This Generator Hours Run Log may be used to record hours of operation.
Perform monthly, quarterly or annual inspections, testing, and observations as outlined in the Title V Permit and maintain records near the generator and also upload to the consultant's web-based platform.
If you would like a copy of the Title V Clean Air Act Permit, please contact Environmental Health and Safety or the Engineering and Utilities group within Facilities Services Operations.
Issued: December 2011
Revised: June 2021