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For more than 20 years, Trinity Consultants has assisted facilities in the aerospace industry with regulatory compliance and environmental management issues.
Trinity has a long history of assisting facilities with their regulatory compliance and environmental management systems.
Trinity helps chemical and pharmaceutical manufacturers to achieve regulatory and environmental compliance.
Trinity has assisted clients with nearly 500 power-related projects, offering an array of services.
Due to their nature, “general manufacturing” facilities are often faced with reviewing a wide range of regulations to determine applicability.
Trinity provides a variety of services to government entities, including environmental permitting and compliance management.
Trinity Consultants has long been committed to assisting lime and aggregates facilities with their regulatory compliance needs.
Trinity takes pride in understanding the regulatory issues affecting our clients’ facilities and their industry.
Oil and gas facilities must contend with a variety of regulatory compliance and environmental management demands.
Trinity helps petroleum refineries to achieve compliance with complex environmental regulatory requirements.
Trinity Consultants has long been committed to assisting cement facilities with their regulatory compliance and environmental management needs.
Trinity has extensive experience assisting the pulp and paper industry with its regulatory compliance and environmental management requirements.
Railroads are faced with rapidly evolving state, regional, and federal regulatory framework in the United States.
For more than 25 years, Trinity Consultants has assisted facilities in the semiconductor industry.
Trinity Consultants has performed nearly 800 environmental permitting and compliance projects for clients with terminal operations, providing cost-effective, timely solutions that enhance compliance while maintaining operational flexibility.
For nearly 30 years, Trinity Consultants has assisted facilities such as those in the highly regulated wood products industry.
There has been another change in the effective date of the Risk Management Program (RMP) rule revisions and several other actions taken to delay, modify, or eliminate the RMP rule revisions. On March 13, U.S. EPA Administrator Scott Pruitt »
The Nebraska Department of Environmental Quality (NDEQ) has recently completed an internal draft of proposed revisions to the air quality regulations located in Title 129 of the Nebraska Administrative Code. The revisions to Title 129 include »
MMEX Resources Corp. (OTCPK: MMEX), a development stage company focusing on the acquisition, development and financing of oil, gas, refining and infrastructure projects in Texas and South America, today announced a strategic relationship with »
Acquisitions, divestitures, and mergers can trigger potentially serious environmental concerns for buyers and sellers. Companies of all sizes can assess and mitigate environmental liabilities through appropriate due diligence activities. This »
We are excited to bring you 3 updates to your air dispersion modeling software. The new enhancements and features in these updates include the latest U.S. EPA executables as well as improved options to expedite model run time.BREEZE AERMOD Version »
Trinity's Environmental Quarterly (EQ) magazine covers environmental regulatory developments as well as topics related to corporate environmental performance.
all issues from 2009
These papers, presentations, and articles were authored by the staff of Trinity Consultants for presentation at various conferences.
all papers & presentations
Since its founding in 1974, Trinity has expanded its geographic footprint and breadth of services. We attribute our continued growth to a focus on cornerstone values of top-notch technical performance and excellence in client service.
Proposed revisions to the Regional Haze Rule (40 CFR Parts 51 and 52) were published in the Federal Register on May 4, 2016. A full copy of the federal register can be found here. This rule directly impacts state, local, and tribal governments as »
On April 6, 2016, the Environmental Protection Agency (EPA) published to the Federal Register the final rule to 40 CFR Part 60 Subpart Da ("Utility NSPS") and 40 CFR Part 63 Subpart UUUUU ("Utility MATS"). These revisions were proposed on February »
The Oklahoma Department of Environmental Quality (ODEQ) recently proposed a revised Minor Source General Permit for Oil and Gas Facilities (GP-OGF). The GP-OGF was developed to authorize construction and/or operation of oil and gas facilities with »
Revisions to the Prevention of Significant Deterioration (PSD) and Title V Greenhouse Gas (GHG) Permitting Regulations and Establishment of a GHG Significant Emissions Rate, was recently sent to the Office of Management and Budget (OMB) for »
Two proposed rules, NSPS Subpart OOOOa (Oil and Natural Gas Sector: Emission Standards for New and Modified Sources) and Source Determination for Certain Emissions Units in the Oil and Natural Gas Sector, were recently sent to the Office of »
On March 3rd, just weeks after the Supreme Court of the United States stayed the Clean Power Plan, Chief Justice John G. Roberts Jr. made a different ruling on the Mercury and Air Toxics Standards – deciding not to stay the regulation despite the »
According to United States Coast Guard data from the last ten years, there are thousands of hazardous substance spills each year from industrial facilities that are not subject to any hazardous substance spill prevention rules. EPA has agreed to »
In a letter dated February 11, 2016, EPA released Round 2 of its Intended Designations for the 2010 Primary 1-hour SO2 National Ambient Air Quality Standard, pursuant to a March 2, 2015, court-ordered schedule. Of primary concern is the proposed »
The BLM is proposing new regulations for drilling, completions, and related operations at onshore Federal and Indian leases. The proposed rule would require operators to take various actions to reduce waste of gas, establish clear criteria for when »
On February 9, 2016, the U.S. Supreme Court granted a stay of the final Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units (Clean Power Plan) until the applicants' petitions for review in the »
On January 29, 2016, the Environmental Protection Agency (EPA) proposed an amendment to the greenhouse gas reporting rule (40 CFR Part 98 Subpart W) to align leak detection monitoring methods with the method in the proposed New Source Performance »
The oil and natural gas industry operating in Osage County has been finding it more and more difficult to operate since the Bureau of Indian Affairs (BIA) recently made it more difficult and time-consuming to get drilling permits. Now a new ruling »
On December 8, 2015, the Air Quality Department (AQD) implemented the new General Permit (GP) for Air Curtain Incinerators. The GP is to authorize the construction and/or operation of air curtain incinerator (ACI) facilities with actual emissions »
On January 21, 2016, the D.C. Circuit Court of Appeals denied requests from industry and dozens of states to halt the rule while litigation proceeds. The court also announced key case dates: initial briefs are to be filed April 15 and final briefs »
On January 5, 2016, EPA finalized its partial disapproval of a February 19, 2010 revision to the Oklahoma SIP that addressed the Clean Air Act regional haze requirement to establish reasonable progress goals for the Wichita Mountains Class I area. »
January 14, 2016 - EPA has extended the deadline for responding to a request for additional data and information on emissions of hazardous air pollutants (air toxics) that were not available in 2012 when EPA updated its major source air toxics »
Despite some dissenting comments from the Oklahoma Sierra Club, the Air Quality Council voted unanimously to approve the revisions to OAC 252:100-9, Excess Emission Reporting Requirements, after a holdover for further discussion from the October »
On December 7, 2015, the United States Environmental Protection Agency (EPA) published in the Federal Register the final version of the amendments to the Aerospace Maximum Achievable Control Technology (MACT) found in 40 CFR Part 63, Subpart GG »
On July 13, 2015 new EPA regulations on the "Definition of Solid Waste" came in effective. DEQ is proposing amendments to its rules in OAC 252: Chapter 205 - Hazardous Waste Management. The amendments will incorporate by reference the new federal »
In 2012, EPA revised NESHAP regulations for Oil and Natural Gas Production Facilities and Natural Gas Transmission and Storage Facilities. EPA is now requesting additional data that was not available at that time, specifically:HAP Emissions from »
The Environmental Protection Agency (EPA) has proposed a rule that would update the requirements to 40 CFR Part 82 Refrigerant Management Requirements under the Clean Air Act. The current regulations require that persons servicing or disposing of »
On October 24, 2012, the Environmental Integrity Project (EIP), together with 16 other organizations, submitted a petition to the USEPA to add the Oil and Gas Extraction sector (SIC 13) to the list of sectors covered by section 313 of Emergency »
On May 22, 2015, EPA Administrator Gina McCarthy signed the final "SSM SIP Call" rule. The rule contains EPA's response to a 2011 Petition for Rulemaking regarding the treatment of startup, shutdown, and malfunction (SSM) excess emissions in state »
In addition to the Excess Emissions Reporting Requirements discussed above, the Air Quality Advisory Council also discussed the following amendments:The first amendment discussed was the proposed new Permit by Rule (PBR) for emergency engine »
On January 1, 2016, the Environmental Protection Agency (EPA) is finalizing 2015 revisions and confidentiality determinations for petroleum and natural gas systems source category of the Greenhouse Gas Reporting Rule (GHGRR). Entities affected by »
On October 1, 2015, the U.S. Environmental Protection Agency (EPA) announced the new National Ambient Air Quality Standards (NAAQS) for ground-level ozone. Originally proposed as one of the six criteria air pollutants under the Clean Air Act, »
As a follow-up to the proposed rules summarized in our last eNews, EPA recently announced that it will be holding public hearings for three of the recently proposed rules affecting the oil and gas industry. The proposed rules include updates to »
In June 2014, the EPA issued proposed rules that will affect petroleum refineries currently subject to the Refinery MACTs (40 CFR Part 63, Subparts CC and UUU). The new rules contain additional requirements for storage tanks, flares, and coking »
On September 15, 2015 the Environmental Protection Agency (EPA) proposed its National Enforcement Initiatives (NEIs) for 2017-2019. The EPA is soliciting public comments and recommendations on the proposed NEIs by no later than October 14, 2015 »
Often an acquisition in the Oil & Gas Industry may involve either a large number of previously operated well locations or the rights to explore on large undeveloped parcels of land. In order to protect oneself from unwarranted risk it is »
On August 18, 2015, EPA issued a suite of new proposed rules and guidance affecting the oil and gas industry, including:Minor revisions to NSPS Subpart OOOO designed to streamline certain monitoring and continuous compliance demonstration »
The U.S. Environmental Protection Agency (USEPA) published a final rule in the Federal Register on July 13, 2015 (80 FR 39961) finding that 24 states failed to submit State Implementation Plans (SIPs) to satisfy requirements of the Clean Air Act »
In June and July 2015, OSHA published significant OSHA logo changes to its enforcement policies on the Process Safety Management (PSM) standard in the form of guidance documents. These changes reflect items listed in the PSM RFI (December 9, 2013) »
EFO sponsored their annual regulatory update seminar at the Oklahoma City Zoo on June 26th. Among the speakers were ODEQ Executive Director Scott Thompson, who remarked about his desire for ODEQ to practice open communication with regulated »
On July 15, 2015 the Environmental Protection Agency (EPA or the Agency) published in the Federal Register the Final Rule to 40 CFR Parts 280 and 281 Revising Underground Storage Tank Regulations. EPA is making revisions to the existing requirements »
On June 23, 2015, EPA sent its proposed methane leak rule to the White House Office of Management and Budget for final review. The proposed regulations are aimed at minimizing methane leaks from the oil and natural gas sector as part of the »
The ODEQ Air Quality Advisory Council met on Wednesday, June 10, 2015 in Owasso. The Council discussed the following rule changes:Subchapter 5 (Emission Inventory): proposed amendment that would lower the inventory reporting threshold for lead to »
On May 22, 2015 EPA Administrator Gina McCarthy signed the final "SSM SIP Call" rule. The rule contains EPA's response to a 2011 Petition for Rulemaking regarding the treatment of startup, shutdown, and malfunction (SSM) excess emissions in state »
Three major elements of Oklahoma State government have taken actions to resist the Clean Power Plan (CPP). CPP has been proposed to limit carbon emissions from coal-fired electric generating plants. U.S. EPA is relying on Section 111(d) of the »
The Air Quality Division (AQD) of DEQ is in the final stages of preparing for the release of two air permit application options. For incinerators the legal notices of an opportunity for public review of the draft General Permit were published on May »
Air Quality Division (AQD) of DEQ is in the process of updating the forms used to apply for renewal of a Title V (Part 70) operating permit. One of the expected changes will be deletion of the requirement to submit a copy of the previous year »
Most AERMOD dispersion modeling is conducted using meteorological data from a nearby airport. As long as the airport is reasonably representative of your source location, there is nothing wrong with that: airports are often a source of high »
At the April 1, 2015 Oklahoma Oil and Gas Association (OKOGA) meeting, U.S Environmental Protection Agency (EPA) Region 6 Director Ron Curry and newly appointed Principal Advisor to EPA Administrator, Teresa Marks, laid out Ms. Marks' first priority »
On April 21, 2015 the U.S. EPA withdrew a direct final rule that had been published February 24, 2015. The rule that was published in February delegated authority of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for all »
DEQ has announced that Rick Groshong has been promoted to be the head of the Compliance/Enforcement Sections of Air Quality Division. Mr. Groshong has been in this Section for about 18 years and is replacing Ms. Kendal Stegmann. He stated that »
On January 14, 2015, the President released a new goal to cut methane emissions from the oil and gas sector by 40 - 45 percent from 2012 levels by 2025. Methane emissions accounted for nearly 10 percent of U.S. greenhouse gas emissions in 2012, of »
On January 7, 2015, the EPA will require all states to comply with a federal "model rule," if a state does not submit a custom plan under the new climate change regulations. The regulations are based on the Clean Air Act, and each state may »
Nov. 26, 2014 - EPA is proposing to tighten air quality standards for ground-level ozone, or smog, within a range of 65 to 70 parts per billion (ppb), while taking comments on a level as low as 60 ppb. The Clean Air Act requires EPA to review the »
Fossil Fuel-Fired Electric Utility Steam Generating Units The Environmental Protection Agency (EPA) is taking final action on its reconsideration of the startup and shutdown provisions in the final rules titled, "National Emission Standards for »
The Environmental Protection Agency (EPA) published the final rule for the (Greenhouse Gases) GHG Mandatory Reporting Rule MRR 40 CFR Part 98 on October 24, 2014. In summary: "The Environmental Protection Agency (EPA) is amending the »
Nov. 4, 2014 - The EPA is proposing a rule (RIN 2060-AQ75) which will target emissions of hazardous air pollutants that come from petroleum refineries. The proposed rule, signed in May by EPA Administrator Gina McCarthy, would revise emissions »
Ms. Gerlach serves as a Consultant in Trinity's Oklahoma City office. She provides assistance with permitting, air dispersion modeling, emissions inventories, fugitive component studies, regulatory applicability and tasking studies, and »
Trinity's senior consultants can bring your staff concise, practical, and accurate information on compelling environmental issues. Management briefings can be delivered in a timeframe and format that is useful for you, such as:• One-hour briefing of »
Temporary workers are often at a higher risk for workplace injury and illness. This could be due, in part, to the unfamiliarity with the work site but can also be a result of inadequate health and safety training. The Occupational Safety and Health »
Facilities that are major sources of HAPs, and that operate affected boilers and process heaters need to comply with 40 CFR 63 Subpart DDDDD by January 31, 2016, or 180 days after startup of the source, if after the regulatory compliance date. This »
Each organization has a unique EHS culture. It is critical to understand and manage your organization’s EHS culture in order to maintain positive EHS performance. EHS performance is most often driven by employee actions and behaviors, which are »
On September 16, 2014 EPA announced that it will be extending the public comment period for its proposed rules on carbon dioxide emissions from power plants. The deadline for finalizing standards is June 2015. The Acting Assistant Administrator »
EPA Announces Steps to Reduce Greenhouse GasesOn September 19, 2014 EPA Administrator Gina McCarthy met at the White House with private and public sector leaders to discuss actions to curb emissions of hydrofluorocarbons (HFCs), greenhouse gases »
The EPA recently released a proposal that will change some of the emission factors for industrial flares The most notable change is for the nitrogen oxides (NOX) factor, which is approximately 43 times greater than the existing factor. This change »
Subchapter 2, Incorporation by ReferenceSeveral federal subparts have been incorporated by reference, view the full list Review.Subchapter 5, Emission InventoryThis rule revises the current emission inventory reporting schedule for all minor source »
SANGEA™ is a user-friendly software program owned by the American Petroleum Institute (API) and designed to assist petroleum and natural gas companies with estimating, managing and reporting greenhouse gas (GHG) emissions. In 2012, Trinity »
The Environmental Protection Agency has again extended the public comment period for proposed refinery regulations. The new date is October 28, 2014 for all comments to be submitted to the EPA. The EPA would like ensure the public has sufficient »
On August 18, 2014, the Environmental Protection Agency denied environmentalists a petition that would name almost 60 areas of the country out of compliance with the federal ozone standard. The agency told the Sierra Club and Earthjustice that it »
Trinity recently contributed to an article by EMIS provider Credit360 on best practices in deploying a successful EHS management system. The article, published in EHS Today, examines steps an organization can take to identify the best and »
On July 31, 2014 EPA issued a Request for Information (RFI) on the Risk Management Program (RMP) standard in response to Executive Order 13650 (EO 13650). Section 6(e)(ii) of EO 13650, , issued August 1, 2013, in response to industrial incidents »
USEPA has been performing several Risk and Technology Reviews (RTRs) throughout multiple industries. The Clean Air Act (CAA) requires that RTRs, a combined effort to evaluate both risk and technology, be performed within eight (8) years after »
Update: On August 19, 2014, in response to recommendations from state and tribal representatives, EPA sent letters outlining the areas that are intended for designation for the annual fine particle air quality standards set in 2012.On April 25, »
On June 23, 2014, the U.S. Supreme Court issued its decision in Utility Air Regulatory Group v. EPA (No. 12-1146). The Court said that EPA may not treat greenhouse gases as an air pollutant for purposes of determining whether a source is a major »
The Air Quality Division, in cooperation with the Oklahoma Secretary of Energy & Environment and the Oklahoma Corporation Commission, is working to involve the public, state electrical utilities, and other stakeholders during the development »
Later this year, the Environmental Protection Agency (EPA) will decide whether it should tighten the air-quality standard for ground-level ozone. In 2008, the EPA set ozone standards for air quality at 75 parts per billion (ppb). The EPA is now »
Many facility operations incorporate the use of oil/water separators. According to Chapter 5 of the EPA's revised SPCC Guidance for Regional Inspectors, the intended use of an oil/water separator determines whether the separator is subject to the »
Leak detection and repair (LDAR) programs live and die by their details. As years pass after the implementation of an LDAR program, and the staff involved either retire or move on to other assignments, it is easy for those details to start to lose »
As part of the President's Climate Action Plan - Strategy to Reduce Methane Emissions, the U.S. Environmental Protection Agency (EPA) is proposing updates to its air standards for new municipal solid waste (MSW) landfills. These updates would »
On June 26, 2014, the EPA asked the D.C. Circuit to re-instate Cross State Air Pollution Rule (CSAPR) following the Supreme Court decision upholding EPA's approach to addressing interstate air pollution. Bottom Line - If granted, EPA's motion will »
The Environmental Protection Agency is proposing general permits for use in Indian country pursuant to the Indian Country Minor New Source Review (NSR) rule for new or modified true minor sources in the following six source categories: Concrete »
The EPA has announced an extension of the comment period for a June 5, 2014, advance notice of proposed rulemaking (79 FR 32502) that would amend regulations under 40 CFR 49 to address the implementation of the Indian country minor new source review »
The Environmental Protection Agency (EPA) is proposing to amend the standards for gas well affected facilities to provide greater clarity concerning what owners and operators must do during well completion operations, especially the provisions for »
The Environmental Protection Agency (EPA) has announced a proposal for a new rule to improve control of toxic air emissions from petroleum refineries.The new rule would call on refineries to optimize emissions control with maximum achievable control »
According to the Verdantix Green Quadrant report for EH&S software, common EH&S function plays a leading role in selecting and funding EH&S software. The specific capabilities and areas of functionality that EH&S leaders look for »
On May 30, 2014 the United States Court of Appeals for the District of Columbia Circuit vacated an Environmental Protection Agency (EPA) Clean Air Act (CAA) directive that implemented a decision of the United States Court of Appeals for the Sixth »
The PC MACT was originally finalized in June 1999 with a compliance date of June 2002 for existing sources. Since then, the rule has been amended several times, most recently in September 2010 and February 2013. The February 2013 amendments set a »
Attorney General Scott Pruitt commented June 2, 2014 on the EPA's proposed rule to limit greenhouse gas emissions from existing power plants. "While the EPA says the new greenhouse gas emissions rule for existing power plants gives states »
On June 2, 2014, at the direction of President Obama and after an unprecedented outreach effort, the U.S. Environmental Protection Agency is releasing the Clean Power Plan proposal, which for the first time cuts carbon pollution from existing power »
More rulemaking could be on the way from the Environmental Protection Agency (EPA) for oil and gas facilities located in Indian Country. The agency has announced that they are seeking comments regarding the Advance Notice of Proposed Rulemaking »
Mr. Townley is a Senior Consultant in Trinity's Oklahoma City office. His experience includes assisting clients with air permit applications, environmental compliance analyses, emissions calculations, and air dispersion modeling. Mr. Townley has »
Mr. Lowther works at Trinity Consultants' operation in Tulsa, Oklahoma. He has over 24 years of experience in environmental compliance and consulting including regulatory compliance audits, construction and operating permitting, wastewater and »
On March 25, 2014 the U.S. Environmental Protection Agency (EPA) and U.S. Army Corps of Engineers (Army Corps) jointly released a proposed rule to clarify protection under the Clean Water Act for streams and wetlands that form the foundation of the »
On September 11, 2013, EPA proposed amending greenhouse gas (GHG) reporting and recordkeeping requirements under 40 CFR Part 98. Due to the public's concern of sensitive data being released, EPA deferred the reporting deadline for inputs to »
On April 15, 2014, the U.S. Environmental Protection Agency (EPA) released five technical white papers covering what it considers to be potentially significant sources of emissions in the oil and gas industry. The white papers focus on technical »
The Oklahoma Water Resources Board, working in partnership with the US Army Corps of Engineers under their Planning Assistance to States program, held a series of public meetings to share information and obtain feedback on water conservation »