Page 264 - Sustainable On-Site CHP Systems Design, Construction, and Operations

Operating Permits and Compliance Management Pr ograms 237

The CEMS is also dependent upon the operation of a data acquisition system. The
submittal should include a summary of how data will be managed and reported and
should be supported by a data flow diagram. Applicable equations used to calculate emis-
sions should be identified along with references to applicable regulations. A description of
the computer that will run the CEMS software should be included in the submittal.
Quality Assurance Plan
The ongoing accuracy of a CEMS is greatly dependent upon adherence to effective
maintenance and operating procedures. The developer will be required to compile a
quality assurance plan for delivery to the operator. The plan may also have to be
reviewed and approved by the regulatory agency. The plan should outline steps for
ensuring system reliability and data accuracy. These steps include daily system cali-
brations, periodic calibration gas audits, and periodic relative accuracy test audits.
Procedures for completing these tasks should be supplemented with an operator’s
compliance schedule.
The quality assurance plan should include preventative maintenance procedures
and corrective actions. Maintenance procedures should be supplemented with an
activity schedule and a spare-parts list. Corrective actions should include applicable
procedures for notifying facility management and regulators of system malfunctions
that may affect data availability or accuracy. Contact information (support contractors,
plant management, and regulatory agency) should also be identified in the plan.

Initial Reliability and Accuracy Demonstration
To commission the CEMS, the developer will have to demonstrate its reliability and
accuracy. This is done through a series of tests that occur over several weeks. The first
test is intended to demonstrate that the CEMS can be operated continuously and reli-
ably without intervention or adjustment. This “hands off” test typically lasts for a
period of at least 7 days. During the second test the CEMS must demonstrate the ability
to maintain acceptable calibration over a second 7-day period. During this test, daily
calibration checks of the system must consistently be within specified tolerances. If the
CEMS fails either reliability test, conditions leading to the failure must be corrected and
the test must be reinitiated.
Upon completing the system reliability demonstrations, the developer can proceed
to demonstrate the system’s relative accuracy. The accuracy test can be effectively con-
ducted in conjunction with other emissions testing programs that may be specified in
the construction permit. These programs are discussed in the following section of this
chapter. During the relative accuracy test audit (RATA), CEMS measurements are
compared to results of a simultaneous emissions test conducted by an independent
laboratory over multiple 30-minute test runs. A minimum of nine test runs are typically
required to ensure data validity. When compared, the results from the CEMS and the
independent laboratory must be within specified tolerance and also be statistically
significant. Upon successful completion of all commissioning tests, data from the CEMS
will be acceptable for demonstrating compliance with emission standards.
Initial Emissions Test
Emissions compliance tests are often required upon system start-up, especially if issu-
ance of the construction permit is dependent upon the installation of emissions control
systems or if the permitted operating schedule is dependent upon assumptions
regarding the impacts of a specific pollutant. Emissions tests will most often be required