BS MUNICIPAL EBMUD A UPPER SAN CIABRIFI VAII FY MUNICIPAL ER. RICT ?0 Ma SOUTHERN u? EAUFURHM WATER q?t EUALITIUH MesaWater CALIV-UQNM MUNICIPJEL A 5 5 I: hi 296% WATER DISTRICT 2?5: - {5 an Inland Empire Utilities Agency A MUNICIPAL WATER DISTRICT Dublin San Ramon Services District Warm; WGEIEWCJIEF, rerycirzd water Irvine Ranch WATER DISTRICT EASTERN MUNICIPAL WATER DISTRICT THREE VALLEYS min Lin Santa Manganita Waten Distrzict 3.31? iI 1 i (ATV BA o? 1v ?5 Water and Power 5' ?5 ince 1?91 WW 6?nee 1927' Quality Since 1952 WESTERN MUNICIPAL WATER DISTRICT 581-. 191?- Public Water Agencies Group a? ?n COMPTON WATER ENERGY LIFE EWERSIDE PUBLIC UTILITIES 495% A 5 A A ?if: 325 gm Water Power SERVING SINCE 906 Submitted via email and U.S. Mail April 18, 2019 Mr. Richard Corey, Executive Officer California Air Resources Board 1001 I Street Sacramento, CA 95814 RE: Additional Flexibility for Testing and Maintenance of Emergency Backup Generators Designated for Critical Water System Facilities for Fire Protection Dear Mr. Corey: The undersigned water agencies request your assistance to evaluate opportunities to provide additional flexibility for testing and maintenance of emergency backup generators designed to provide backup power to critical water system facilities for fire protection. In 2018, California experienced one of the most devastating wildfire seasons on record. The Woolsey Fire in Southern California burned nearly 100,000 acres, destroyed 1,643 buildings and resulted in three fatalities. In the early morning hours of November 9, 2018, Las Virgenes Municipal Water District (LVMWD) lost power to nearly all of its facilities due to the fire. Emergency backup generators were deployed to restore the operation of critical pump stations to refill water storage tanks that were being depleted due to firefighting. Nevertheless, a sequence of events ultimately lead to a loss of water system pressure and issuance of boil water notice for a portion of LVMWD's service area. Among the challenges faced by LVMWD during the fire was the failure of emergency generators when placed under load conditions for an extended period of time. Amendments to the Airborne Toxic Control Measure (ATCM) for Stationary Compression Ignition Engines, Section 93115.3(n), recognize the importance of National Fire Protection Association (NFPA) standards for testing fire protection systems and appropriately exempts in-use emergency fire pump assemblies from the requirements of Section 93115.6(b)(3), provided they are only operated the number of hours necessary to comply with NFPA 25. Unfortunately, there is not a similar provision for emergency backup generators that are designated to provide emergency power to critical public water system facilities required for fire protection. We recommend that such a provision be added for these specified emergency backup generators. Mr. Richard Corey, Executive Officer April 18, 2019 Page 2 NFPA 110, Standard for Emergency and Standby Power System, outlines rigorous The maintenance and testing procedures for emergency backup generators. requirements of the standard are cited as necessary to obtain a minimum level of reliability and performance, particularly where life safety electrical power needs are involved. However, the ATCM limits the annual maintenance and testing of the diesel-fueled compression ignitions engines that power these emergency backup generators to as little as 20 hours based on the age of the unit and emission rate of diesel particulate matter. The prescribed NFPA 110 maintenance and testing procedures, including monthly exercising and periodic load tests, cannot be effectively performed while adhering to the strict operating limits established by these regulations. To ensure the reliability of fire protection water systems, there is an interest by water utilities, specifically in Southern California but more broadly throughout California, for the California Air Resources Board (CARB) to recognize the operational requirements for emergency backup generators that are designated to provide emergency power to critical public water system facilities required for fire protection. Most of these generator engines are over 50 horsepower and regulated by regional air agency permits, which require compliance with local air rules that cannot be less stringent than the ATCM. Therefore, even if a local air agency were to consider the merits of allowing an exemption to operating requirements for designated emergency power to critical public water system facilities, it could not offer this important flexibility to water agencies or other fire response organizations as the action could be considered a relaxation of the ATCM. On March 6, 2019, we sent the enclosed letter to Mr. Wayne Nastri, Executive Officer of the South Coast Air Quality Management District (SCAQMD), and requested consideration of a proposed amendment to Rule 1470 to address the concern. A meeting is scheduled with Mr. Nastri and key SCAQMD staff members on April 25th at 9:00 a.m. to discuss the concern and proposal in more detail. However, in the course of initial discussions with SCQAMD staff, it became apparent that we should bring the concern to your attention given the application of CARB's ATCM. As a result, we would like to request that you consider a similar amendment to the ACTM for this purpose. Enclosed for your review is a proposed amendment to ATCM Section 93115.3(n) to ensure that emergency backup generators used to power critical water system facilities can be adequately maintained and tested, in accordance with NFPA standards, for reliable operation during emergencies. Thank you for considering this important proposal. If you or your staff have questions about the proposal, please do not hesitate to contact David W. Pedersen, General Manager of Las Virgenes Municipal Water District, at (818) 251-2122 or dpedersen@lvmwd.com. Mr. Richard Corey, Executive Officer April 18, 2019 Page 3 Sincerely, David W. Pedersen, P.E. General Manager Las Virgenes Municipal Water District Barry Moline Executive Director California Municipal Utilities Association Paul A. Cook General Manager Irvine Ranch Water District Lisa Ohlund General Manager East Orange County Water District Charles Wilson Executive Director Southern California Water Coalition Paul D. Jones II, P.E. General Manager Eastern Municipal Water District Nina Jazmadarian General Manager Foothill Municipal Water District Paul E. Shoenberger, P.E. General Manager Mesa Water District Robert J. Hunter General Manager Municipal Water District of Orange County Matthew Litchfield, P.E. General Manager/Chief Engineer Three Valleys Municipal Water District Mr. Richard Corey, Executive Officer April 18, 2019 Page 4 Tom A. Love General Manager Upper San Gabriel Valley Municipal Water District Daniel R. Ferons General Manager Santa Margarita Water District Robert Beste Public Works Director City of Torrance Michael Moore Assistant General Manager, Water Serv. City of Anaheim Chris Berch, P.E. Executive Manager of Engineering/ Assistant General Manager Inland Empire Utilities Agency Richard H. Wilson, P.E. Assistant General Manager, Water Systems Burbank Water and Power Jim Barrett General Manager Coachella Valley Water District Craig Miller General Manager Western Municipal Water District Mr. Richard Corey, Executive Officer April 18, 2019 Page 5 Alberto Corrales General Manager South Montebello Irrigation District Mr. Richard Corey, Executive Officer April 18, 2019 Page 6 Brian A. Dickinson General Manager – Water City of Compton Daniel McIntyre General Manager Dublin San Ramon Services District Todd M. Corbin General Manager Riverside Public Utilities Alexander R. Coate General Manager East Bay Municipal Utility District Mitchell S. Dion Assistant General Manager Pasadena Water and Power PROPOSED AMENDMENT TO ATCM SECTION 93115.3(n) Existing Language (n) The requirements of section 93115.6(b)(3) do not apply to in-use emergency fire pump assemblies that are driven directly by stationary diesel-fueled CI engines and only operated the number of hours necessary to comply with the testing requirements of National Fire Protection Association (NFPA) 25 "Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems," 2002 edition, which is incorporated herein by reference. Proposed Language (n) The requirements of section 93115.6(b)(3) do not apply to the following: (1) in-use emergency fire pump assemblies that are driven directly by stationary diesel-fueled CI engines and only operated the number of hours necessary to comply with the testing requirements of National Fire Protection Association (NFPA) 25 "Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems," 2002 edition, which is incorporated herein by reference; or (2) emergency backup generators driven directly by stationary dieselfueled CI engines, designated to provide emergency backup power to critical public water system facilities required for fire protection, and only operated the number of hours necessary to comply with the testing requirements of National Fire Protection Association (NFPA) 110 "Standard for Emergency and Standby Power Systems," 2019 edition, which is incorporated herein by reference.