Page 267 - Sustainable On-Site CHP Systems Design, Construction, and Operations

240 C o ns truction

The Permit Conversion Process
Issuance of a final operating permit is generally initiated when the permit holder noti-
fies the regulatory agency that construction is complete, but little action will be taken to
convert the permit until after commissioning activities are complete and the regulatory
agency has reviewed and approved test results. The regulatory agency may also wish
to inspect the CHP facility prior to issuing the final operating permit to ensure compli-
ance with permit conditions and applicable regulations. In some cases the operating
permit will be subjected to additional review periods that will delay final issuance.
During the conversion process, the construction permit will generally continue to serve
as a temporary operating permit as long as all necessary applications have been submitted
in accordance with regulations.

Final Permit Language
In most cases, the operator should expect the operating permit to contain the same
conditions, other than commissioning conditions, which are contained in the con-
struction permit. In a few cases, however, the operator may have an opportunity to
fine-tune permit conditions based on the emissions test results. The most common
of these cases occurs when operating schedules specified in the permit reflect
assumed emission rates that differ significantly from the rates demonstrated dur-
ing emissions tests. For example, the developer may have accepted a construction
permit limit on the number of allowable operating hours per year, or the amount
of fuel consumed per year, based on conservative default emission factors. If the
emissions test demonstrates that the CHP system emits at a much lower rate than
initially assumed, and if the operator is willing to commit to meeting lower rates,
it may be possible to modify the operating condition to specify the lower emission
rate and a higher operating limit. In some cases, permit modifications may also be
made to increase the allowable emission rate, with complementary conditions that
further restrict the annual operating limit, should the emissions test show higher
than expected emission rates.

Implementing a Compliance Management Program
Many environmental permits do not warrant any type of commission test, but the
developer may have to notify permitting agencies of system start-up and may also have
to develop and implement compliance management program. In almost all cases, the
installation of a CHP system will result in the need for internal processes to ensure
compliance with operating permits and applicable regulations. In some cases, the oper-
ator must also submit compliance and risk management plans to regulatory agencies
prior to, or shortly after, taking control of the facility.

Potential Plan Submittals
Various environmental management plans are typically required for a new facility, but
the integration of a CHP with a new or existing facility warrants only minimal post-
permit plan submittals. Plans that may be required, due to the added environmental
or safety risks attributed specifically to the CHP system, include hazardous material
emergency response plans and risk management plans for accidental chemical releases.
These plans must be submitted prior to, or shortly after, initiating operation of the
CHP system.