Page 268 - Sustainable On-Site CHP Systems Design, Construction, and Operations

Operating Permits and Compliance Management Pr ograms 241

Hazardous Material Emergency Response
The operator must advise fire departments or other emergency responders of potential
hazards at the facility. This is often done through the submittal of a plan that is often
referred to as a Hazardous Materials Business Plan or a Business Emergency Plan. These
plans identify key facility contacts and include an inventory of hazardous materials
typically located at the facility, along with facility diagrams showing the locations
where material is stored or used. They allow emergency responders to better under-
stand the safety precautions that must be taken when entering the facility and the risks
to the community that may result from an emergency at the facility.
Accidental Release Risk Management
When ammonia is spilled, it can vaporize and expose people in proximity to acute
health risks. Regulatory agencies may require the operator to submit a plan to advise
regulators and the public of the risks associated with an accidental ammonia release.
Risk management plans typically identify the potential health risks attributed to a
worst-case spill. These plans also identify risk prevention measures to be taken by the
operator. These measures may include establishing delivery routes that bypass large
population centers, designing storage capacities that are not larger than necessary, inte-
grating features to prevent spills when transferring ammonia from a delivery truck to a
storage facility, using vapor recovery systems when filling a storage tank, and designing
secondary containment to minimize surface area and to allow for product recovery in
the event of a storage tank failure.

Compliance Management Program
Environmental permits that are issued for a CHP system may contain numerous oper-
ating conditions. Additional compliance requirements may be contained in applicable
regulations. Failure to comply with permit conditions and regulatory requirements can
be detrimental to the CHP operator and the host facility. Violations of these conditions
can lead to financial penalties and repetitive compliance failures result in increased
scrutiny of facility operations by regulatory inspectors. To ensure compliance with
permit conditions and regulatory requirements, the operator must develop and imple-
ment an effective compliance management program that includes established operating
and maintenance procedures aimed at preventing equipment failures that can lead to
noncompliance. The compliance management program should also include provisions
for monitoring, recording, and reporting environmental compliance.

Operations and Maintenance Procedures
Sound operating and maintenance practices help to ensure compliance with environ-
mental standards. The operator must develop and implement formal procedures to
ensure reliable operations of the CHP system, including those components that are
designed to reduce environmental impacts. Preventative maintenance procedures and
a schedule of maintenance activities should also be incorporated into the formal
procedures. These procedures are built upon those that are recommended by CHP
equipment vendors, but may also include additional provisions that are specified in
environmental permits and regulations.
Ideally, failures that may lead to an environmental upset or a violation of permit
conditions would never occur. In reality, such upsets do occur and the manner in which