Project Overview

As LLP’s Trusted Advisor, NTH has been providing environmental compliance services to Lowell Light and Power since 2017, including providing internal audits of various EHS program areas, updating environmental permits and plans, and providing environmental design and due care support.

Project Approach

Lowell Light and Power operates two (2) combustion turbine generators (CTGs) that were recently incorporated into their fleet in Lowell, MI. The municipality has also performed several site improvement projects and is under environmental due care obligations. At LLP’s request, NTH provided environmental permitting and compliance support.

Our tasks have included:

Task 1: EHS Audit and Air Permit Revision
NTH performed a review of air quality and health and safety requirements and provided a summary of recommended improvements to maintain compliance with the EHS program areas. Following the air quality audit, NTH assisted LLP in a revision to federal New Source Performance Standard (NSPS) limit for a gas combustion turbine generator (CTG) listed in the permit in anticipation of stack sampling. Following the permit revision, LLP was able to perform and pass testing at the revised emission limit.

Task 2: SPCC/PIP Plan Update and Certification
NTH participated in a site visit and review of LLP’s Spill Prevention, Control, and Countermeasure (SPCC) and Pollution Incident Prevention (PIP) Plan requirements. NTH assisted LLP in updating the SPCC/PIP Plan to incorporate current operations and anticipated containment area improvements. We also incorporated appropriate inspection procedures and worked closely with the plant to ensure regulatory compliance.

Task 3: Design for Transformer Containment Area
NTH provided LLP assistance for the site-civil engineering and design for proposed secondary containment improvements at an outdoor transformer storage area to comply with SPCC requirements and best management practices. NTH provided a design including required containment storage, drainage upgrades, and accessibility in order to meet LLP’s needs and satisfy SPCC/PIPP regulatory requirements.

Task 4: Due Care and Vapor Intrusion Assistance
LLP’s property contains an office/garage building surrounded by paved parking and storage areas. Previous environmental studies identified chlorinated volatile organic compounds on the adjacent property at concentrations above volatilization to indoor air inhalation criteria. EGLE identified a potential for soil gas to enter LLP’s building through the floor slab (infiltration) and result in indoor air concentrations that could pose an unacceptable risk to the building occupants. To assist LLP with their due care obligations.

NTH provided following services:

  • Reviewed environmental reports provided by LLP and EGLE.
  • Evaluate vapor intrusion risk by conducting soil gas surveys inside the building.
  • Designed vapor mitigation plan and submitted for approval to EGLE.
  • Conducted indoor air sampling and analysis to evaluate the effectiveness of the vapor mitigation system.
Client Benefit

Over four years, we have been a trusted advisor to Lowell Light & Power (LLP), providing environmental compliance services and support.