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EPANonrulemakingEPA-HQ-OA-2011-0155

Improving Regulations: Air

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Association of Metropolitan Water Agencies filings
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Association of Metropolitan Water Agencies filed 1 comment on this docket between Apr 8, 2011 and Apr 8, 2011. 35 other organizations filed here. The comment window closed 5594d ago.

What Association of Metropolitan Water Agencies filed (1)

Apr 8, 2011· Comment submitted by Diane VanDe Hei, Association of Metropolitan Water Agencies· EPA-HQ-OA-2011-0155-0057

Reciprocating Internal Combustion Engine (RICE) Regulations 40 CFR § 60.331(e) Under the RICE regulations, the ability of drinking water and wastewater utilities to use emergency generators is hampered in two ways. First, the usage time limit requirements for RICE do not allow water utilities to use emergency generators for more than 15 hours per year for peak shaving. Some utilities support the investment of large capacity emergency generators that would be necessary to sustain critical water supply operations through peak shaving. This requirement is a disincentive for utilities to properly size standby generators to be able to achieve the needed power load in an emergency. Second, defining an emergency situation only as a loss of power prevents a water utility from being proactive and using its generator(s) to stay online when the utility knows that a power failure is imminent, such as in the event of an oncoming hurricane or when the power company has advised of a blackout or brownout due to a heat emergency or other disaster. The utilities' ability to operate emergency generators in advance of these situations not only reduces the likelihood that community water service would be interrupted but also reduces the chance of voltage fluctuations that have the potential to damage large motors and pumps at water treatment facilities. The Association of Metropolitan Water Agencies (AMWA) recommends that EPA revise the standards to allow water and wastewater utilities to operate RICE or gas turbine emergency generators if the utility has reason to believe that there would be imminent loss of power. AMWA also recommends that EPA consider allowing water utilities to utilize more than 15 hours per year for peak shaving if it is necessary to defray the cost for utilities to properly size the emergency generators. Such changes would improve water utility resilience in an emergency and protect public health.

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Abstract

This docket contains public suggestions that EPA evaluate its rules by subject matter, or program area, specifically: Air.

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Co-filers (35)

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