Trinity has a long history of assisting facilities in the agricultural processing industry with their regulatory compliance and environmental management systems. Backed by 40 years of experience and expertise amassed by completing more than 600 projects for agricultural processing clients, we are able to help facilities meet their environmental compliance objectives. In addition, our active participation in agricultural trade associations, such as the Grain Elevator and Processing Society (GEAPS), National Grain and Feed Association (NGFA), etc., keeps us informed about timely regulatory concerns for your facility.
"(Trinity) has performed in an outstandingly professional manner and completed two difficult projects under challenging timeframes within our requirements."
Regulatory Round Up
- On September 16, 2014, EPA issued proposed changes to 40 CFR 60 Subpart DD, New Source Performance Standards for Grain Elevators in 2014. As part of this proposal, EPA introduced a new subpart DDa for affected facilities that commence construction, modification or reconstruction after July 9, 2014.
- U.S. EPA has issued emission standards for non-road diesel engines, including those used in agricultural operations. These standards are intended to reduce emissions of particulate and sulfur dioxide emissions from non-road diesel engines.
- Several National Emission Standards for Hazardous Air Pollutants (NESHAP) / Maximum Achievable Control Technology (MACT) standards may affect agricultural sources. Among those are the Miscellaneous Metal Parts & Products MACT (40 CFR 63 Subpart MMMM) that was signed in August 2003 and the MACT for Surface Coating of Plastic Parts and Products (40 CFR 63 Subpart PPPP). Vegetable oil extraction facilities are typically subject to the Vegetable Oil MACT (40 CFR 63 GGGG).
- MACT and NSPS standards with broad applicability for agriculture facilities include the Stationary Reciprocating Internal Combustion Engines MACT (40 CFR 63 Subpart ZZZZ, 40 CFR 60 Subpart IIII and 40 CFR 60 Subpart JJJJ)) and the Industrial, Commercial, & Institutional Boilers and Process Heaters MACT (40 CFR 63 Subpart DDDDD for major sources and 40 CFR 63 JJJJJJ for area sources).
- Biodiesel and ethanol plants have an agricultural connection and can lead to unexpected synthetic organic chemical manufacturing industry (SOCMI) rules such as NSPS NNN (SOCMI distillation), NSPS RRR (SOCMI reactors), NSPS VV (equipment leaks), NSPS Kb (methanol storage).
- U.S. EPA, USDA, and the U.S. Department of Energy are jointly sponsoring the AgSTAR Program, a voluntary effort designed to encourage the use of biogas recovery technologies to reduce greenhouse gas (methane) emissions at concentrated animal feeding operations (CAFOs) that manage manure as liquids or slurries while achieving other environmental benefits. .
- An oil mill company’s cottonseed processing facility qualified as a major source under the Title V operating permit program primarily as a result of VOC emissions from solvent extraction processes. Trinity prepared a Title V operating permit application for the facility, addressing all mill emissions units, emissions of all regulated pollutants, all applicable federal and state requirements, and the compliance status with respect to all applicable requirements.
- Trinity Consultants installed and operates an ambient monitoring station for a grain handling and receiving facility. The station monitors real time PM-10 concentrations, temperature, incoming solar radiation, wind direction, and wind speed. Trinity has also performed air dispersion modeling for PM-10 at the site.
- Trinity conducted numerous projects for a regional oil mill company, including environmental audits, comprehensive emissions inventories, state and federal permitting, air quality dispersion modeling, and compliance/strategic planning. Trinity also determined the feasibility of modifying one of the company’s facilities to install new equipment and completed related air permitting tasks.
- Trinity has permitted multiple biodiesel operations which range in size from area/minor sources to Title V/major sources.