Page 232 - Sustainable On-Site CHP Systems Design, Construction, and Operations

Obtaining a Construction Permit 205

also include detailed information about the host facility (location, size, existing emis-
sion sources, etc.) and an overview of the background or existing environmental condi-
tions. For example, if discussing air quality impacts one should provide an overview of
air quality in the region surrounding the facility. The assessment of existing conditions
should be as objective as possible and should rely upon measured and quantified con-
ditions, relative to official standards.

Project Proposal
The application package should contain a clear and detailed discussion of the proposed
project. Key considerations include the proposed equipment, operating schedules, fuel
consumption rates, and operator background information. The proposal should be sup-
plemented with facility plans and diagrams, process flowcharts, and manufacturer’s
equipment specifications. If the CHP system is replacing existing equipment at the facility,
an overview of that existing equipment should also be included in the proposal.
Applicable Environmental Standards and Regulations
The project engineer or developer should summarize laws, ordinances, and regulations
affecting the project. Such regulations typically specify minimal technology standards,
impact thresholds and limits, operating practices, and conditions for selecting an
appropriate project location. Applicable regulations may be written, implemented, and
enforced by local, regional, and/or federal agencies.

Project Impacts
The project engineer or developer should quantify and assess the project’s environmen-
tal impacts using established protocols. Impacts should reflect the facility’s typical and
potential maximum operations. If the project includes the replacement of existing
equipment and operations at the host facility, the impacts of those operations should be
assessed. If appropriate, the impacts of those operations should be netted against those
of the proposed CHP project. Often, the project engineer or developer will incorporate
specific technologies, operating schedules and other mitigating measures that will
lessen the environmental impacts of the project. When quantifying the project’s impacts,
it is prudent to reflect both the baseline project impacts, as well as the final impacts
considering any mitigating measures that will be incorporated.

Determination of Regulatory Compliance and Proposed Permit Conditions
Once the project engineer or developer has quantified the project’s environmental
impacts, he should then summarize how the project complies with the identified appli-
cable laws and regulations. Ensuring compliance with regulations will often necessitate
that the resulting construction permit stipulate operating conditions. It is prudent for
the project engineer or developer to identify necessary permit conditions and suggest
permit language that ensures compliance in a manner that also promotes operating
efficiency and flexibility.

Air Quality
By far, potential air quality impacts pose the greatest environmental concern attributed
to the development of most CHP systems. Combusting fossil fuels and biogases in CHP
systems results in emissions of criteria pollutants such as nitrogen oxides (NO ) and
x