Which Environmental Regulations Apply to Emergency Power Generators?
Emergency power generators can be critical pieces of equipment for any facility, especially in the stormy seasons of spring or winter or in disasters su...
Emergency power generators can be critical pieces of equipment for any facility. If you have one in your facility now, or are thinking about getting one, you need to be aware of the environmental regulations which are triggered by having one onsite.
⚡ In short: Emergency generators trigger air permits, SPCC plans, EPCRA reporting, tank registrations, and employee exposure assessments. A single generator without proper compliance can create five separate regulatory pathways.
⚠️ Why this matters: Facilities install backup generators without asking compliance questions. Then a spill happens, an inspection occurs, or someone gets sick from exhaust exposure — and suddenly there are missing permits, undisclosed storage, untested exposure levels, and no documentation. Each missing compliance element is a separate citation. Generators that were supposed to prevent downtime end up creating regulatory liability instead.
Air Emissions
Emergency generators can have the potential to emit various air pollutants. Depending on your state or local environmental regulations and the type of generator you have, you may need to prepare and file for an air permit. There are specific rules which govern the various types of generator engines: 40 CFR 60, Subpart IIII for stationary compression ignition generators, 40 CFR 60, Subpart JJJJ for stationary spark generators, and 40 CFR 63, Subpart ZZZZ for reciprocating internal combustion engines (RICE).
Spill Prevention, Control and Countermeasures (SPCC)
If the fuel which you store onsite is in a tank with aboveground storage above 1,320 gallons, you will need to prepare an SPCC plan.
Emergency Planning and Community Right to Know Act (EPCRA)
If your fuel storage is above certain amounts, you will be required to conduct EPCRA annual reporting, chemical inventorying, and notifications.
Tank Certifications and Registrations
Aboveground and underground fuel storage tanks may need to be registered, permitted, inspected, and certified per state and local regulations.
PCBs
A potential for the presence of polychlorinated biphenyls (PCBs) can be found in any transformers, capacitors, electrical equipment, thermal insulation and motor/hydraulic oils.
Employee Exposure Issues
Any backup generator which is brought into a facility could cause additional employee exposure issues. Noise monitoring and exhaust exposure assessments would need to be conducted.
Frequently Asked Questions
Q: What air emissions regulations apply to emergency power generators?
Emergency generators are regulated under EPA New Source Performance Standards (NSPS): 40 CFR Part 60 Subpart IIII (compression ignition engines), Subpart JJJJ (spark ignition engines), and 40 CFR Part 63 Subpart ZZZZ (reciprocating internal combustion engines). Facilities may need to obtain air permits depending on generator size, operating hours, and state/local regulations.
Q: When does a facility need an SPCC plan for generator fuel storage?
If emergency generator fuel is stored in aboveground tanks totaling more than 1,320 gallons, an SPCC (Spill Prevention, Control and Countermeasures) plan is required per EPA regulations. The SPCC must include secondary containment specifications, spill response procedures, and employee training. Facilities must maintain the plan on-site and update it within six months of any changes to storage configuration.
Q: What EPCRA reporting is required for emergency generator fuel?
If emergency generator fuel storage exceeds EPCRA Tier II reporting thresholds (10,000 pounds for most hazardous chemicals), facilities must report to state environmental agencies, local fire departments, and emergency planning committees. For diesel generators, facilities must track and report diesel fuel inventory. Reporting is due March 1 annually.
Q: Are employee exposure assessments required for emergency generators?
Yes, facilities must assess potential noise and exhaust exposure to employees near operating emergency generators. Noise monitoring determines if hearing conservation program requirements apply. Exhaust exposure assessment evaluates need for ventilation or respiratory protection. These assessments should be conducted before installation to ensure compliance with OSHA exposure standards.
Most facilities install a generator and document its operational schedule but forget the compliance prerequisites. If you’re planning a generator installation, run the regulatory applicability review BEFORE ordering the unit. A 4–6 week assessment cycle can identify permitting needs and save you from installation delays.
💰 What an un-permitted or misconfigured generator costs: EPA air permit violations can run $25,000+ per violation. SPCC violations for undisclosed fuel storage: $10,000–$55,000+ per day. A single generator compliance failure can exceed $100K in fines. Cost of a pre-installation compliance review: $2,000–$5,000.
Need help with generator compliance or EPA air permitting? Contact iSi Environmental for a same-day quote, or explore our environmental compliance services to see how we can help your facility install generators the right way.
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