W H ITE PA PE R

Permitting Considerations for

Natural Gas Generator Solutions
BY JOHN SHARPE
Power Solutions Manager at Generac Power Systems

INTRODUCTION
A commercial or industrial generator is a large investment that
not only requires service and routine maintenance but also takes
up valuable real estate. During the generator sizing process,
there are several factors to consider regarding permitting and
application requirements as they apply to the needs of the end
user and local code demands. After identifying the primary need
for a generator and the solution’s intended use, it is imperative
that specifying parties also consider location requirements and
environmental factors as well as the operation and maintenance
needs of the purchasing party. This paper will explore preliminary
questions that must be asked during generator sizing
assessments and their potential impact on product installation
and permitting requirements.

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Permitting Considerations for Natural Gas Generator Solutions
LOCATION
The space provided for generator installation can play a major role
in not only the size of generator that is specified but also the
configuration in which the generator is placed. It is important to
first identify whether the generator will be installed indoors or
outdoors, as regional climates, building codes and/or owner
preference can dictate the site of installation.
While indoor installations provide greater security for the generator
and overall aesthetics of the facility, these types of configurations
also come with a higher price tag, as a dedicated one-hour fire
rated room is required for most installations (NEC 700.12; NFPA 37
4.1.2). Indoor fuel storage needs should also be taken into
consideration, as NFPA 110 7.9.5 limits tank capacities to 660
gallons for diesel fuel applications, which may not be consistent
with the needs of the facility. Such limitations will require the
addition of an external fuel tank, supply and return pumps, shutoff
or isolation valves, and controls to maintain an adequate fuel
supply. If a natural gas fuel supply can be used, these on-site
storage concerns can be eliminated.
If the natural gas supplier demonstrates a reliable natural gas
supply that is approved by the Authority Having Jurisdiction (AHJ),
all installations are acceptable within NEC 700 12.B.3. The natural
gas supply must be connected up stream of the main facility shut
off valve per NFPA 110 7.9.7. Also, if a natural gas supply already
exists on site, verifying whether or not adequate pressure and
volume is available to meet the demands of the generator will also
help determine the anticipated cost of configuring a dedicated
fuel line.
Other factors to consider for indoor installations include
combustion and cooling air flow (NFPA110 4.1.2.1) as well as
exhaust discharge (NFPA 37).
As for outdoor installations, identifying the space allotted for the
generator should be the primary objective. Whether the end user
wants the configuration installed in a parking lot, on a roof, or
simply in the back of their building, each of these configurations
will still need to abide by certain guidelines to ensure safe
operation and permit approval.
While most owners prefer to place the generator on the side of
their building near the incoming transformer, an important rule to
follow is ensuring the generator is no closer than five feet from a
combustible wall or wall opening. For large diesel generator
installations, a structural analysis may need to be completed, as
generator size, pad type and on-site fuel tank may exceed 50 tons
in weight. Fuel treatment requirements should also be taken into
consideration, as warm areas present an issue with water and
bacteria in diesel fuel while fuel gelling is of significant concern in
colder climates (NFPA110 5.1.1(1)).
Rooftop Installations
For applications in which a limited footprint is available for
generator placement, end users may request a rooftop installation.
In addition to the five-foot rule, a non-combustible surface must
also be placed under the generator when it is set atop the roof of a
building. Configurations featuring diesel generators also face the
issue of refueling and spill containment as well as the additional
weight of the fuel itself. Because of this, most rooftop installations
lend themselves to natural gas applications, where refueling is not
an issue and liquid containment is limited to engine oil and
antifreeze capacities (NFPA37 4.1.3.2).
Parking Garages
For a generator placed in a parking garage, the separate fire-rated
room requirement does not apply (NFPA 37 4.1.2.1). Adequate
air-flow for cooling is still required for these types of installations. It
is important to consider the fact that overhead clearance
limitations will impact generator size and access to diesel tanks for
refueling purposes as well.
ENVIRONMENTAL CONSIDERATIONS
All stationary generator sets that are installed in the United States
must meet emissions standards set forth by the Environmental
Protection Agency (EPA). These standards are known as the
Reciprocating Internal Combustion Engine (RICE) and New
Emissions Standards for Hazardous Air Pollutants (NESHAP). They
are broken down into subcategories of diesel compressions,
ignition and spark-ignited. Manufacturers are aware of these rules
and make products to ensure compliance. However, as rules are
locally enforced, adherence is the responsibility of the owner.
Depending on the state and municipality, the owner may be
required to register the generator with the local air board and
report generator use on an annual basis.
In compliance with the EPA, emergency standby generators can
operate for 100 hours per year for testing and maintenance in
addition to operation during outage scenarios. But what if the
generator is going into an area sensitive to air pollution? In such
cases, a cleaner generator must be provided. A diesel generator
with the more-stringent, EPA tier 4 engine incurs approximately 50
percent in additional costs. This makes natural gas-powered
generators, which are inherently cleaner, an attractive alternative.
Other regulations regarding sound or ground water may need to
be addressed locally. For areas in which a significantly low sound
limit (50 dB(A)) is required at the property line, it can be difficult for
some installations to meet these requirements causing extreme
enclosure designs or a sound-friendly installation site (i.e. rooftop/
indoors) to be requested. Groundwater contamination concerns,
which are addressed through local codes, have pushed diesel
generator designs to require fuel spill containment, over-fill
prevention and additional fuel containment vaults as well.
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Permitting Considerations for Natural Gas Generator Solutions
OPERATION NEEDS
To offset generator capital cost, some owners enter into demand
response programs. Generally available among most utilities, site
owners should contact their local utility representative for
enrollment in such programs. For customer’s that prefer opt for a
demand response application, a cleaner generator must be
provided. A diesel engine compliant with EPA’s tier 4 limitations will
add approximately 50 percent to the overall cost of the project,
thereby eliminating the cost saving a demand response system
can provide. Comparatively, when specified, manufactured and
certified for non-emergency applications, natural gas engines can
operate more cleanly and only incur 5-10 percent additional cost
for demand response applications.
LOADS, CODES & MAINTENANCE NEEDS
When designing a generator, properly classifying the generator’s
dedicated loads is imperative. For commercial and industrial
properties, loads can be divided into three categories: NEC700
(Life Safety), NEC701 (Legally Required Loads), and NEC702
(Optional Standby).
Depending on each load’s classification, the NFPA 110 Standard
for Emergency and Standby Power Systems will dictate
application requirements. While not codified into law, most
municipalities and AHJs have adopted NFPA standards, which are
compulsory. As a part of electrical permitting, ensuring the
selected generator is applicable for the load based on NFPA
standards is a common stipulation.
GENERATOR SIZE
Once load designations are established, the requirements of the
applicable NEC section, along with the NFPA 110 guidelines, will
help determine the size of generator(s) specified for each project.
For assistance determining the ideal generator for a customer’s
needs, many designers will turn to their generator representative
for expert engineering assistance and analytical software to input
load requirements and determine the right power solution for the
customer’s needs.
Generac Power Systems, Inc.
S45 W29290 Hwy. 59, Waukesha, WI 53189 | 1-844-ASK-GNRC (1-888-275-4672) | 0204520
GENERACINDUSTRIALPOWER.COM
MAINTENANCE NEEDS
Consideration must also be given to whether or not maintenance
of the generator will be provided by the customer’s personnel or a
distributor in their local area. The standard for generator
maintenance (NFPA 110, Chapter 8) details the need for weekly,
monthly and annual procedures as well as exercising requirements
to ensure proper generator operation at all times. Comparatively,
natural gas units do not require a specific load level for exercising
as the building’s load is sufficient for testing purposes. It is
important to note that generator maintenance and testing may
include oil sampling and fuel polishing. For diesel generators,
supplemental load banks may be required for testing as well—
monthly testing at 30 percent load, annually at 50 percent load for
30 minutes, or annually at 75 percent load for one hour is
acceptable per NFPA 110. For natural gas applications, the
building load alone is sufficient for testing purposes. Regardless of
the fuel type utilized, each of these tests should be completed by a
local authorized generator distributor.
As natural gas eliminates fuel polishing requirements, and
provides a more eco-friendly fueling option as well as improved
reliability when compared to diesel, it is a viable fuel option that
is easier to maintain and acceptable for use in most generator
applications today.
SUMMARY
Generator applications can be beneficial to a variety of commercial
and industrial applications. By reviewing the personal needs of
each customer, ensuring the generator meets local codes as well
as the load requirements of each unique application is imperative
for each installation. From location and environmental regulations
to fuel requirements and budgeting limitations, a variety of factors
can impact the cost and performance of a commercial or industrial
generator. Working with a local generator representative is an
important step in ensuring the ideal products are specified to
meet the city, state and national codes as well as the needs of
the customer.
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