Project Overview
NTH was selected by the NSCE environmental team to provide compliance assistance regarding monitoring for multiple pollutants for their seven (7) fossil and biomass-fueled electricity generation facilities located in two (2) states. NTH was selected due to experience in air permitting, and a long-term relationship with NSCE. The seven (7) facilities each have unique monitoring requirements for comprehensive monitoring of emissions.
Project Scope
Clean Air Act (CAA) and Michigan Air Pollution Control Rules require each power plant to monitor certain emissions, depending on combustor type and fuel mix. Maintaining compliance requires NSCE and NTH to understand several types of monitors, including Continuous Emissions Monitoring Systems (CEMS), Predictive Emissions Monitoring Systems (PEMS), Continuous Opacity Monitors (COMS), and nearby Federal Reference Method (FRM) and Federal Equivalent Method (FEM) monitors.
NTH’s role is to understand how to operate, maintain, evaluate data, and conduct Quality Assurance and Quality Control (QA/QC) for NSCE’s monitors, to ensure that data meets regulatory quality standards and demonstrates compliance with permits, rules, and regulations. NTH coordinates test audits and other regulatory QA/QC activities for NSCE’s monitors. NTH provides QA/QC for the reports generated by such audits.
NTH routinely reviews data generated by the monitors, looking at annual, monthly, daily, and in certain instances hourly data to verify that they are functioning properly. NTH works to verify that data matches anticipated ranges, operating data are recorded properly, emissions averages are computed correctly, and data gets reported to federal and state reporting agencies in a timely and correct manner.
NTH prepares, evaluates, and maintains various monitoring plans, continuous compliance plans, and preventative maintenance plans for NSCE. NTH also provides audits to ensure that NSCE follows these plans, Standard Operating Procedures (SOP), and other air permit requirements. NTH is heavily involved in planning updates to monitoring methodology as permits, emissions equipment, and monitor technology evolve.
During air permitting, NTH rigorously evaluates data from emissions monitors to determine past and potential emissions profiles. NTH also evaluates data from off-site ambient and meteorological monitors to determine impacts on dispersion modeling results. Verification of the applicability and quality of monitored data is critical to ensuring that dispersion modeling provides the most accurate representation of local air possible to the client and state regulators.
NTH regularly attends stakeholder meetings held by local, state, and federal agencies regarding monitoring on behalf of NSCE. Among other ongoing activities, NTH is currently evaluating how new EGLE-operated PM2.5 FEM monitors compare with older FRM monitors, as U.S. EPA’s recent changes to the PM2.5 National Ambient Air Quality Standards (NAAQS) have made compliance margins tighter. NTH strives to keep NSCE briefed on the most up-to-date information regarding monitoring.
Client Benefit
With NTH’s extensive experience regarding air permitting, NTH provided an understanding of the operation, maintenance, evaluation, and QA/QC of NSCE’s monitors, resulting in the data meeting quality standards and demonstrating compliance overall.
