Over the past decade, Trinity Consultants has performed nearly 800 environmental permitting and compliance projects for clients with terminal operations. Our industry experts have deep expertise in the environmental challenges facing these facilities and are able to provide cost-effective, timely solutions that enable them to enhance compliance and maintain operational flexibility.
Terminals operators planning plant construction or expansion, operational changes, and/or maintenance, startup, shutdown, and malfunction (SSM) activities must ensure completion of the proper air quality permitting activities. Determining applicability and demonstrating compliance with standards such as New Source Performance Standards (NSPS) Dc, Kb, IIII, and JJJJ and National Emission Standards for Hazardous Air Pollutants (NESHAP) R, Y, EEEE, ZZZZ, DDDDD, and GGGGG is also critical, including the preparation of various notifications and emissions reports and developing and auditing operation and maintenance (O&M) plans and SSM plans.
With respect to transportation fuel compliance, facilities must ensure that appropriate fuel handling, recordkeeping, and reporting procedures are being followed by terminal staff, consistent with the requirements of 40 CFR Parts 79 and 80. Implementation of appropriate standard operating procedures and quality assurance techniques for handling transportation fuels is key to maintaining fuel integrity and meeting certain specification limits such as those that apply to distillation properties, sulfur, and benzene. Examples include proper pipeline and manifold flushing, tank cleaning, and handling of transmix.
Additional environmental requirements applicable to terminals include:
- Proper control of fugitive emissions through implementation of Leak Detection and Repair (LDAR) programs and audits
- Calculation and reporting associated with emission events such as flaring, spills/releases, and unit trip
- Development of proper program elements under the EPA Risk Management Program and OSHA’s Process Safety Management requirements
- Determination of complex regulatory jurisdictional requirements planning, inspection, and testing under applicable PHMSA/DOT/RRC, EPA, and U.S. Coast Guard regulations
- MSGP stormwater permits and SWPPPs, NDPES stormwater discharge permits, hydrostatic test water discharge permits, waste generator notifications and reporting, waste contingency plans, and SPCC/FRPs
Trinity Consultants has long-standing partnerships with many terminal operators to whom we provide a wide range of environmental support. Typical projects include the following:
- Strategy development regarding new construction, operational changes, release reporting procedures,
- Permitting assistance
- Construction permitting for new facilities and expansions
- Minor source applications to authorize new fugitive piping components, tanks, flares, emergency generators, diesel railcar loading,
- Title V, FESOP renewals
- Stormwater permitting
- Emissions calculations and reporting
- Preparation of annual TRI, EI, GHG, Form R, and Chemical Data reports
- Preparation of annual compliance certification, Title V monitoring reports, NESHAP semi-annual reports, and annual emission reports
- Preparation of STAR EA demonstrations
- Tracking tool for flares
- Compliance audits with respect to federal and state requirements
- Stack testing oversight and support
- CEMS program audit and compliance support
- Water sampling at new storm/hydrotest water outfalls
- Energy assessment under the Boiler rules
- Due diligence and acquisition support - Phase I/II ESA, multi-media permitting, and regulatory requirements
- Staff training on environmental regulations and requirements
Trinity provides training on critical air quality requirements to environmental staff at terminals facilities. Its Clean Air Act Workshop for Liquid Terminals is offered several times annually at convenient locations and onsite to meet individual client needs.
Trinity is also a member of the International Liquid Terminals Association (ILTA) and provides educational presentations at the annual conference and other meetings. Upcoming presentations include:
- Workshop: CEMS – Industry Standards and Best Practices for Compliance – April 25, 2017 – New Orleans, LA
- Conference presentation: Increasing Challenges in Obtaining Air Permits – Brian Burdorf and Vineet Masuraha – June 12, 2017 – Houston, TX