Project Overview
Consumers Energy (CE) initially retained NTH to assist in developing an air permitting strategy and an air use permit to install (PTI) application and supporting documentation for proposed changes to various permit conditions (emission limits and operational restrictions) for its combined-cycle CTG/HRSGs at the Covert Generating Station. Through NTH’s excellent reputation and quality work on the PTI application project, CE identified staffing needs based on upcoming and immediate regulatory permitting and reporting requirements such as support on updating the Renewable Operating Permit (ROP) for Covert Generating Station, navigating MiEnviro submittals, updates to malfunction abatement plan and compliance documents, Joint Permit applications, and requested NTH to provide staff to assist as an extension of the CE team on as-needed environmental compliance projects and tasks.
Project Scope
NTH was retained to provide staff augmentation services to CE involving environmental regulatory compliance support for various air quality permitting and compliance related tasks, as well as land and water permitting assistance across their fleet of power generation assets and transmission/linear facilities. Having a PTI application in progress, annual emissions reporting due during that project, a required ROP renewal during this period, and receiving additional compliance questions from Michigan Department of Environment, Great Lakes and Energy (EGLE) mid-project regarding previous quarterly emissions reports proved to be extremely complicated and time consuming for CE to sort out. NTH’s environmental department provided a variety of skillsets that complimented and expanded the capabilities of the CE team. We provided additional personnel and flexibility to pick up highly specialized work that very few people in the state are able to complete while meeting demanding schedule constraints.
NTH is also providing air quality consulting services in the development and approval an air PTI for Covert Generating Station proposed upgrades. Our services include development of an air permit strategy, preparation of an air use PTI application for submittal to Michigan EGLE, negotiation of draft permit conditions, support in responding to questions from EGLE Air Quality Division permitting or district staff, and support for a public comment period and/or response to public comments (if required). NTH has worked on air quality permits for dozens of electric generation facilities over the years and has the bench to navigate a variety of expansions to scope as the project progressed. Our history of working with EGLE to negotiate permit conditions, compliance questions, and other tough regulatory issues made us a crucial partner to move the Covert PTI, ROP, and related projects forward.
Project Challenge:
CE needed a cohesive air permitting strategy, PTI application, and supporting documentation for proposed permit changes at the Covert Generating Station to improve operational flexibility and reduce the risk of potential future noncompliance with permit requirements.
NTH Solutions:
NTH helped CE manage and complete work on multiple large-scale projects simultaneously including permitting and compliance at Covert Generating Station, preparations for the retirement of a coal power plant, major overhaul of an existing natural gas-fired combustion turbine plant, and evaluation of potential upgrades to a natural gas compressor station.
Client Benefit:
CE will have reduced environmental compliance liability and improved operational flexibility at Covert Generating Station through NTH’s permit improvements.
