NTH’s Value Added NTH Consultants, Ltd. (NTH) has been providing environmental services, such as air quality services and water compliance assistance to Holland Board of Public Works (HBPW) since 2005.
Holland Board of Public Works Air Quality Services
Air Quality Services NTH has prepared two (2) major source permit applications for additional steam and electric generation.
Coal Boiler In 2005, NTH prepared an air permit application for a new MW circulating fluidized bed (CFB) boiler capable of firing multiple fuels, including a blend of coals, wood waste, tire derived fuel (TDF) and sewage sludge. The project was subject to the Prevention of Significant Deterioration (PSD) regulations and a netting demonstration was performed due to the shutdown and removal of an older pulverized coal boiler.
NTH conducted a dispersion modeling analysis of all expected pollutants for comparison to the national ambient air quality standards (NAAQS), PSD Class II increments, and toxic air contaminant (TAC) screening levels per Michigan Air Toxic Rules. Additionally, to address concerns for mercury and lead, NTH performed deposition modeling for use in a human health risk assessment.
This project resulted in regulatory and public interest; NTH assisted with negotiating permit conditions, and participated in public information meetings and public hearings. These steps were critical in obtaining approval of the permit application (issued on February 11, 2011) while maintaining operational flexibility.
Combined Heat and Power Plant In 2013, NTH prepared a permit application for a new 125 MW natural gas-fired combined heat and power (CHP) facility consisting of two combustion turbines and heat recovery steam generators equipped with duct burners and associated ancillary equipment.
The CHP project was subject to major PSD permitting and included an extensive dispersion modeling analysis as well as a BACT analysis for several regulated pollutants. The BACT analysis included an evaluation of technical and economic feasibility for carbon capture and sequestration as it pertains to greenhouse gas (GHG) emissions. NTH actively participated in all interactions with the MDEQ to ensure timely issuance of a permit and allowing for maximum operating flexibility for HBPW. The plant is set to be completed in November 2016. NTH continues to provide air quality consultation to HBPW as they complete the final design and engineering of the plant and begin construction activities.
Water Compliance Assistance NTH assisted HBPW with development and implementation of a groundwater monitoring program for their coal ash dewatering ponds as a requirement of their NPDES permit. Quarterly monitoring, including low level mercury, began in 2011 and is on-going. NTH is also assisting with development of the NPDES permit application for the new CHP plant.
Coal Combustion Residuals NTH was retained by BPW, as part of a team with E&E Solutions, to assist in closure of ash pond system and coal yard at the JDY Plant, pursuant to 40 CFR Parts 257 and 261 for disposal of coal combustion residuals from electric utilities. As part of this task, NTH will develop the written closure plan, complete construction design drawings and specifications for the closure of these areas, and provide oversite during on-site removal activities.