Federal PSD/Title V Stationary Source Permitting Exclusion of Nonroad Engines
The PSD and Title V programs derive their applicability based on the aggregate air emissions from on-site equipment at each facility. Many railyards operate small combustion equipment such as gasoline-powered welders, compressors, and generators. These units may qualify as nonroad engines. Air emissions from nonroad engines need not be included in a facility’s aggregate air emissions when determining applicability of the Federal PSD or Federal Title V programs. This paper discusses the definition of a nonroad engine and the application of the nonroad engine definition to portable or transportable internal combustion engines used in conjunction with units such as welders, compressors, etc. It details the negative applicability of the Federal PSD and Title V programs through regulatory citations, references, and guidance documents. Finally, the benefits to exclusion from Federal PSD and Title V permitting are discussed.