SVMG Energy Committee Members...

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SVMG Energy Committee members,

GE-San Jose recently took delivery of four mobile generators
(provided by GE Rental Energy.) These units will be used to provide partial
power for our operations during rotating block outages affecting GE's site.
Each generator is 800 KWs in size and uses diesel fuel. The fuel tank is an
integral part of the generator, located underneath the engine itself. These
mobile generators were permitted for air emissions under a statewide program
and are referred to generically, for that reason, as Statewide Registered
Portable Generators.

The San Jose fire department, which must grant a permit in order for
these generators to operate, inspected the units last week and then refused
to grant the approval. The reason given was that the fuel tanks constitute
storage tanks containing a hazardous material (Class III-A combustible
liquid) and therefore should meet special requirements for permanent tanks,
including the possibility that the tanks be stored underground. Our own
reading of the California fire code does not lead to this conclusion and
seems to be, in fact, silent on the issue.

Furthermore, we think rented portable generators permitted to
operate in the Statewide Mobile Equipment Program should not require local
fire permits. In any case, we believe the mobile generators are presently
installed and widely used across the San Jose Fire Department jurisdiction,
if not the whole State and that most companies haven't identified their use
to the City.

Given the perilous state of electricity supplies, we would obviously
like to get past this and start using the generators.

So....a heads up....if your facility is storing diesel fuel in
"non-permanent" tanks, you may be subject to a cease and desist order down
the road.

My question for the group is...does anyone have any experience in
this matter and can, therefore, offer some insight or advice? I would be
particularly interested to know if you are using any portable emergency
generators in your San Joes operations.

Regards,

John Redding