Page 265 - Sustainable On-Site CHP Systems Design, Construction, and Operations

238 C o ns truction

to confirm emission rates of criteria pollutants such as NO , CO, ROG, SO , and PM
x x
(see Chap. 7). In some cases, tests for specific hazardous air pollutants will also be
required. Fuel analyses and fuel meter accuracy tests may also be required. The con-
struction permit will most likely specify test methods to follow and time frames for
completing the tests. Established test methods have been developed by various organi-
zations including U.S. EPA, ISO, and ASTM International. Local environmental agen-
cies may also develop test methods to be incorporated for projects in their jurisdiction.

Coordinating the Emissions Test
In some cases, the owner or developer will have full discretion in selecting a contractor
to conduct the tests. In other cases, contractors may have to be certified by the regula-
tory agency. Finally, in a few cases the regulatory agency will conduct the emissions
tests themselves. If the agency is not responsible for conducting the test, the test
contractor will submit a test plan for agency approval. The test plan identifies field test
personnel, pollutants to be measured, test methods, sample repetition, and sample
period duration. The plan also identifies CHP operating conditions, stack configuration
(including sample port location) and anticipated emission concentrations. Once the test
plan is approved, the contractor can proceed with the test program, but may be required
to notify the agency several days in advance. Notification is intended to allow regu-
latory agency personnel to witness the test and failure to notify the agency of an
upcoming test could result in the test being disqualified.
The developer will likely be responsible for coordinating various contractors, regu-
lators, and the system operator to ensure that the CHP system will be operated for an
adequate amount of time to complete the tests. Depending upon the test methods speci-
fied by the regulatory agency, a test program may require from 1 to 10 (or more) hours
to complete. The developer will have to ensure that the plant is capable of uninter-
rupted operations to complete the test. It may also be necessary to operate the CHP
system at various loads to complete the test. The developer may also encounter other
logistical responsibilities such as providing adequate test facilities and ensuring that
the emissions test does not interfere with other commissioning and start-up activities at
the facility.

Resolving Unacceptable Test Results
Ideally, an emissions test will demonstrate that the new CHP system meets permitted
emission limits. In these cases, the developer and permit holder can proceed to finalize
operating permits and turn over the system to the operator. Unfortunately, start-up
emissions tests sometimes do not demonstrate compliance with permit conditions and
corrective actions must be initiated. Corrective action may include obtaining temporary
relief from permit conditions or regulatory requirements while the conditions that cause
excess emissions are resolved. At this point in commissioning, the developer must
involve the permit holder because only the permit holder will be able to commit to any
compliance agreements with the regulatory agency.
To resolve unacceptable test results, the developer must understand what permit
conditions or regulatory requirements may be violated. In some cases, a violation due
to excess emissions may not occur until after the end of a period of 30 to 365 days. In
these cases the developer may have time to correct the conditions that cause excess
emissions and retest for emissions without ever being in violation. For example, a
permit may limit PM emissions to a specified number of pounds per month, based