Page 269 - Sustainable On-Site CHP Systems Design, Construction, and Operations

242 C o ns truction

they are resolved can lead to direct enforcement consequences. Many environmental
regulations include provisions for equipment malfunction that protect the facility
operator from enforcement action if prescribed steps are taken to curtail operations,
correct the malfunction, and appropriately notify the regulatory agency. Facility operating
procedures should include provisions for responding to equipment malfunction and
identify specific channels of communication between operators, supervisors, and the
regulatory agency. Deadlines for corrective action, agency notification, and potential
equipment shutdown should also be included in formal operating procedures.

Compliance Monitoring
The facility operator must develop and implement a monitoring plan that ensures com-
pliance with permit conditions and regulatory standards. An effective monitoring
program ensures that operating staff will take uniform steps on a regular basis to pro-
mote environmental compliance. If the plan is adhered to, it can help to prevent envi-
ronmental upsets and can also demonstrate to regulators that the facility operator is
diligent in managing environmental compliance. This demonstration may lessen the
impact of enforcement actions, should an upset occur.

Emissions Monitoring
The use of CEMS is discussed in the preceding section of this chapter, but not all CHP
facilities are subject to CEMS requirements. Compliance for many smaller systems can
be adequately managed by monitoring various engine operating parameters on a daily
basis. The operating permit will likely identify those parameters that help to demon-
strate that systems are functioning properly and that compliance with emission limits
can be expected. For reciprocating internal combustion engines, monitoring parameters
often include air-to-fuel controller malfunction sensors, exhaust O levels, accumulated
2
operating hours and fuel flow rates (or accumulated flow). These parameters indicate if
the engine is operating as specified, and also if operating throughput limits may be
exceeded. If the engine operates in conjunction with a post-combustion emissions con-
trol device, the operator may also be required to monitor inlet catalyst temperature, and
catalyst inlet/outlet pressure differentials. If the control system relies upon the use of
ammonia or urea, the flow rates of these reactants may be monitored. These parameters
help to demonstrate if the emission control system is functioning and if catalyst fouling
may occur. In some cases, permits include power output based emission limits
(lb/MW-h or kg/MW-h), and permits sometimes allow for more lenient emission
limits when heat is recovered. In these cases, it may be necessary to monitor power
output and heat recovery rates. If the CHP system is based upon the use of a gas turbine,
the monitoring parameters will not differ significantly than those that are applicable to
reciprocating internal combustion engines, except that there is no need to monitor oxygen
or air-to-fuel characteristics.
In the absence of a CEMS, it may be necessary to monitor CO and NO emissions on
x
a periodic basis using a handheld analyzer. Handheld monitoring devices are proven to
be reliable and accurate indicators of emissions concentrations, but their use as an
official compliance determination is dependent upon adherence to a stringent quality
assurance program. Because of this practical limitation, periodic emissions monitoring
programs are commonly used only to supplement, rather than replace, parametric
monitoring and official source tests. If a periodic monitoring program is implemented,
the operator must develop formal procedures for conducting tests and responding to