11-20-2008 02:37 PM
EPA says any Tier 1 unit built prior to 1/1/07 must be installed by no later than 12/31/08. What is the EPA's definition of "install" or "installation"?
All I have found is a State of Delaware regulation stating "date upon which emplacement of a generator is commenced" or "date upon which binding agreements are entered into to undertake a program of actual emplacement".
03-24-2009 06:36 AM - edited 03-24-2009 07:10 AM
You bring up a very good question. The EPA currently does not have a good definition of install. The EMA (Engine Manufacturer's Association) is working to submit a request to the EPA that would define installation as the generator set being placed in its final location... but I do not know when, or if, this will be adopted by the EPA.
But, this does not help you with your situation. Have you discussed this with your local generator set dealer? The local dealer should be able to draw on a wider base of projects, and may have already encountered this situation on another project. Another option would be to discuss this with your local air board. I am not familiar with the specifics in Delaware, but typically the state has the ultimate responsibility for air quality. You may find that, if the site emissions permits have been issued, your project satisfies the second part of the Delaware regulation ("date upon which binding agreements are entered into to undertake a program of actual emplacement".
Here is a link I found to help locate your local air board contact.
Hope this helps. Good luck.
Product & Application Consultant
07-10-2009 03:43 PM
I can not find any reference in either state or federal law that states an engine must be installed before a certain date if it were manufactured after a specific date. If you could site your source, that would be nice.
After looking over the requirements regarding installation, it would appear that one would infer that the implication is upon statrup. It seems impracticle to suggest that an engine would start emitting upon signing some papers.
I agree with doziece, I would check with your local air board. I checked the Delaware area and it seems there is not a local air board there. You may try to contact someone in Mayrland or New Jersey.
Field Service Technician
Natural Gas Compression and Production