Page 270 - Sustainable On-Site CHP Systems Design, Construction, and Operations

Operating Permits and Compliance Management Pr ograms 243

unfavorable results. Analyzer quality assurance procedures must also be developed.
To develop these procedures, the operator should be able to depend on guidance from
the regulatory agency and the analyzer manufacturer.

Other Compliance Monitoring Programs
The operator may be required to implement additional compliance monitoring pro-
grams that are unrelated to air quality. In some cases, existing compliance management
programs for the host facility simply need to be amended to reflect the new CHP oper-
ations. In other cases, the introduction of CHP operations may require the development
of new monitoring programs to manage environmental risks that did not previously
exist at the facility. If SCR is used to control NO emissions, the operator will likely be
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required to periodically inspect the storage devices to ensure that pressure relief valves
are operating appropriately, that and that leaks and spills have not occurred. Similar
monitoring programs will be required if fuel is stored on-site to accommodate the
CHP system.

Record-Keeping and Reporting
Record-keeping is a key component of any environmental compliance management
program. Records that are maintained over long periods of time demonstrate
compliance history and operating trends that may affect environmental impacts.
A well-developed record-keeping program demonstrates that compliance manage-
ment programs are in place and appropriately managed. Without access to compliance
records, the regulatory agency would be forced to assume that mandated compliance
management plans are not implemented, and that compliance with permit conditions
and applicable regulations is not assured.
Operations monitoring logs must be developed to aid plant personnel in main-
taining equipment and monitoring environmental compliance. Monitoring logs should
identify each component of the CHP process to be monitored. They should also be
designed to allow facility personnel to identify the date when monitoring is completed
along with findings of the monitoring event. If facility personnel are to confirm compli-
ance with specific operating parameters, the monitoring log should identify a range of
acceptable values that performance will be measured against. If a CEMS is installed, it
will be equipped with a data acquisition and handling system. This system logs key
data such as pollution concentration and mass emission rates, daily calibration results
and periods during which CEMS data are invalid or missing. This data is generally
available to the facility operator and should be reviewed on a periodic basis.
Many critical compliance records are generated by parties other than the CHP
operator. Records of contracted tests and inspections are also an important demonstration
of compliance and they should be collected and maintained by the CHP operator. Exam-
ples of third-party records include emissions test reports, fuel and SCR reactant analyses,
storage tank inspection reports, boiler inspection reports, and storm water analyses.
Not all compliance records need to be delivered to the regulatory agency. Many
records are simply retained on-site and made available to the agency upon request.
Record retention periods of 2 to 5 years are usually specified in applicable regulations.
Occasionally, periodic compliance reports must be submitted to regulatory agencies.
These reports may summarize the contents of facility compliance records, but do not
include the records themselves. It is the operator’s responsibility to understand which
environmental compliance records should be retained and which records should be