Fire pumps represent a ubiquitous emission source at facilities of all types including data centers, oil refineries, residential buildings and manufacturing centers to name a few. These pumps function to provide pressurized water to sprinklers and standpipes in the event of a fire and often times are powered by a diesel engine. As such, these pumps can represent sources of criteria pollutants such as NOx, CO, SO2, and particulate matter, as well as Volatile Organic Compounds (VOCs) and Hazardous Air Pollutants (HAPs). The permitting path for fire pumps can be complicated, because even though they are emergency units, they do not fall under NMAC 220.127.116.11.B(3) as exempt units as they are not classified as emergency generators.
Previously, if fire pump emissions were less than one (1) pound per hour for any pollutant for which a National or New Mexico Ambient Air Quality Standard has been set or one (1) pound per hour for any VOC, the unit could be permitted under a technical permit revision Pursuant to New Mexico Administrative Code (NMAC) 18.104.22.168.B.(b). However, fire pump emissions can often be over this technical revision threshold. As a result, permitting fire engines with emissions greater than 1 pound per hour could mean that a facility might have to apply for a significant permit revision, pursuant to NMAC 22.214.171.124.D, often requiring air dispersion modeling and a much more extensive and time-intensive permitting process.
Recently, however, New Mexico Environment Department has approved the exemption of fire pumps pursuant to NMAC 126.96.36.199.A(4): the use of firefighting equipment and firefighting training, through an administrative revision (NMAC 188.8.131.52.A). This means that fire pump engines that are sources of criteria pollutants, or VOCs with emission rates greater than 1 pound per hour can be permitted through an administrative revision as exempt units thus representing a much shorter permitting path than either a technical or significant permit revision would allow.
It should also be noted that owners and operators of stationary compression ignition engines that are NFPA (National Fire Protection Association) certified fire pumps manufactured after July 1, 2006 are still subject to the requirements of 40 CFR (Code of Federal Regulations) 60 Subpart IIII and must maintain compliance with the emissions standards listed in this subpart.
For assistance in determining how any of these issues may affect your facility, contact the Albuquerque office by calling (505) 266-6611.