Industrial Risk Management

Trinity helps facilities comply with applicable regulations and minimize the risks to the community and the environment associated with industrial operations. We are particularly adept at employing computer models to predict the impact of accidental release scenarios as is required under EPA’s Section 112(r) Risk Management Program and to assess the residual risk that remains following compliance with the Section 112 National Emissions Standards for Hazardous Air Pollutants (NESHAPs).

Risk Management Planning

The Risk Management Program (RMP) developed under Section 112(r) of the 1990 Clean Air Act Amendments regulates the storage and/or processing of toxic and flammable substances. It requires affected facilities to develop and submit risk management plans that include a hazard assessment, prevention program, and emergency response program. The RMP is based on a three-tiered (program) approach that is designed to link the degree of risk associated with the facility to the required analysis and planning.

The first step of the RMP planning process is to determine if any of the listed chemicals are used at a facility in quantities that exceed the regulatory threshold. If so, Trinity can help you evaluate options for modifying your processes in order to opt out of the program or step down to a less rigorous level. Once the appropriate program level is determined for each affected process, we can you develop a comprehensive Risk Management Plan and communicate about potential hazards with stakeholder groups.

In June 2004, or five years after their original submittal date, approximately 6,000 facilities that have submitted RMP plans will be required to update their original plans with information about significant process changes, updated impact analyses taking into account the 2000 census, and other data. Trinity can assist in preparing these plan updates regardless of whether we developed your initial plan.

Hazard Identification and Modeling

Trinity has performed hundreds of health effects impact studies for actual and potential releases of hazardous air pollutants. These studies have included emissions estimations, acute toxicity evaluations for comparison to threshold limit value-based concentration limits, cancer risk assessment modeling using the GEMS database, and ambient monitoring studies. Our staff has considerable experience in modeling emissions from accidental releases of liquid spills and spills of liquefied gases using dense gas and EPA-approved puff models. Trinity also has senior staff who are skilled at preparing analyses for use by industry in class-action litigation and providing expert testimony on the results.