Page 263 - Sustainable On-Site CHP Systems Design, Construction, and Operations

236 C o ns truction

quality permit will generally dominate the environmental management tasks that must be
undertaken during plant commissioning by specifying a test program to determine
emission levels or to certify emissions monitoring equipment. These demonstrations will
likely occur in conjunction with other plant start-up and commissioning activities. The
permit will also specify the basic components of a compliance monitoring and manage-
ment program that must be implemented as the CHP system is commissioned.

Continuous Emissions Monitoring System Certification
Construction permits that are issued by air quality agencies may specify the installation
and certification of a continuous emissions monitoring system (CEMS). Certification of
the CEMS includes steps to demonstrate system reliability and accuracy. These steps, as
well as system performance specifications, are often identified in environmental regula-
tions, or in independent agency standard documents. The U.S. Environmental Protec-
tion Agency (EPA) regulates CEMS design, accuracy standards, and quality assurance
practices through the Code of Federal Regulations (40 CFR 60 and 40 CFR 75). Local
regulatory agencies in the United States may also enforce additional CEMS standards.
Various CEMS design and management standards exist outside the United States
and certification to these programs is required in most foreign applications. For instance,
the Environment Agency of the United Kingdom enforces CEMS through method
implementation documents and the European Union issues directives that specify how
emissions are to be monitored for variety of sources. When CEMS are called for in these
directives, standards for design, installation, and maintenance are also specified.
Independent organizations such as American Society for Testing and Materials (ASTM),
International Organization for Standardization (ISO), and TUV Rheinland also specify
standards for CEMS or certify performance of CEMS components. Regulatory agencies
may defer to these standards when authorizing the installation of a CEMS.

System Specification Submittal
CEMS certification is dependent upon the developer delivering complete specifications
of the system and committing to quality assurance procedures. The developer must
provide the regulatory agency with data demonstrating that the monitoring system is
designed to meet all technical requirements specified by the agency. If submittal of the
data is not part of the initial CHP application process, it will likely occur at another
point just prior to construction and operation of the CHP system. The submittal should
specify which parameters of the exhaust stream will be monitored. Most CEMS are
installed to monitor NO and CO concentrations. Because concentrations are specified
x
at standard conditions, the monitoring system will also include components to measure
exhaust diluents such as O or CO . If the construction permit specifies mass emission
2 2
rates, then the CEMS may also include components to measure exhaust flow, or to
calculate exhaust flow based upon measured fuel flow. Efficiency-based emission stan-
dards (lb/MW-h or kg/MW-h) will also require the integration of power output data
from the CHP system with output data from the CEMS.
The developer should also identify the model number of all major system compo-
nents such as analyzers, sample conditioning systems, and metering systems. It may
also be necessary to identify the serial numbers of critical system components.
Measures taken to control the monitoring system and operating environment should be
identified, and all technical data should be supplemented with vendor specifications
and installation drawings.