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 provides dispersion modeling, permitting, and compliance support for coastal operations in the Outer Continental Shelf, Deepwater Ports, and liquefied natural gas terminals.
Trinity has assisted clients with nearly 500 power-related projects, offering an array of services.
Trinity Consultants assists food and beverage manufacturers with a wide variety of environmental permitting and compliance needs including Dust Hazards Analysis and refrigerant management.
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 prepares hundreds of air quality compliance reports for landfills and industrial facilities across the United States on an annual basis.
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.
On July 8, EPA Administrator Andrew R. Wheeler signed proposed amendments to 40 CFR 63 Subpart DDDDD (the Boiler MACT). These amendments are being proposed in response to a U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit) »
On July 31, 2020, the Maryland Department of the Environment (MDE) proposed new regulations to reduce vented and fugitive emissions of methane from new and existing natural gas facilities within the state of Maryland. The proposed regulations will »
The Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) was enacted by Congress in 1980 and amended in 1986. Also referred to as the Superfund law, CERCLA's major emphasis is on cleaning up inactive hazardous waste sites »
Last year, Trinity Consultants gave a fresh branding to the Trinity Technology Team (formerly known as T3) and is now known as EHS Digital Solutions. This re-branding does not change our focus on delivering information solutions uncommonly well; »
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.
Here at the Salt Lake City (SLC) office, our multi-disciplined team delivers the highest quality solutions, enhancing regulatory compliance while maximizing operational flexibility. Trinity's approach combines regulatory expertise, technical proficiency, responsiveness, and creative thinking within an ISO 9001 certified Quality Management System that ensures high quality products and services. Trinity's SLC team has developed excellent working relationships with Utah Department of Air Quality (UDAQ) and U.S. EPA Region 8. Our local staff can provide expert assistance in the following areas:
On October 1, 2015, the U.S. Environmental Protection Agency (EPA) promulgated revised primary and secondary ozone National Ambient Air Quality Standards (NAAQS) (80 FR 65292; October 26, 2015). The EPA strengthened both standards to a level of »
UDAQ has proposed changes to air permitting and emission inventories rules in the past few months. A public hearing is scheduled for these rule revisions which are summarized below:R307-150. Emission Inventories. Rule revisions: Annual emission »
Utah's Inland Port consists of 16,000 acres of land in the northwest quadrant of the Salt Lake Valley which has been set aside to centralize transportation for receiving and distributing goods intended for national and international distribution.In »
U.S. EPA published UDAQ's Determination of Attainment by the December 31, 2019 attainment date for Salt Lake City and Provo, Utah for the 2006 24-Hour PM2.5 National Ambient Air Quality Standards (NAAQS) in the federal register (85 FR 350330). This »
UDAQ is proposing changes to R307-401 to include the requirement that the sources that must have a permit and cannot operate without first having obtained such a permit. In other words, operation without a permit-and not merely a failure to obtain a »
UDAQ is proposing for final adoption the repeal and reenactment of R307-165 which outlines the requirements for notifying, conducting, and reporting stack tests. The rule was updated to align with current stack testing practices, rule formatting, »
During the May 6, 2020 Air Quality Board meeting, the Utah Division of Air Quality (UDAQ) proposed significant rule amendments to emission offsets and emission impact analysis (i.e., air dispersion modeling).R307-422. Emission Offset Requirements in »
The Utah Division of Air Quality (UDAQ) is proposing two major changes to the Emission Inventory Rule (R307-150):Changing the reporting frequency of sources located in Ozone Nonattainment areasRequiring detailed reporting for all sourcesOn August 3, »
The Safer Affordable Fuel-Efficient ( SAFE) Vehicles Rule is a collaboration between the National Highway Safety Administration and the Environmental Protection Agency (EPA) to amend portions of existing Corporate Average Fuel Economy (CAFE) and »
Similar to other economic- and health-related challenging periods in history, we are in a time of change. This time we are responding to COVID-19 precautions and market and economic reactions are occurring at lightning speed. As my father taught me »
Due to the COVID-19 virus outbreak, the Utah Division of Air Quality (UDAQ) is adjusting its day-to-day operations as many non-essential government staff transition to work from home. Industry personnel should be aware of changes to air district »
The Utah Roadmap - Utah's Focus on Continuous Air Quality ImprovementLast year, the Utah Legislature provided $200,000 of funding to the Kem C. Gardner Policy Institute at the University of Utah. This funding helped to complete a study of climate »
On January 8, 2020, the Utah Attorney General's Office discussed compliance and enforcement with the Utah Air Quality Board. They presented on R307-130, General Penalty Policy. Given the State's trend of increased focus on compliance and »
Each fiscal year, the State of Utah includes a fee as part of its Operating Permit Program, which is required by Title V of the Clean Air Act Amendments of 1990. This fee funds all direct and indirect costs associated with administering the program, »
On June 5, 2019, the EPA proposed a Clean Data Determination (CDD) for the Salt Lake City 2006 24-hour PM2.5 Nonattainment Area (NAA) of the National Ambient Air Quality Standards (NAAQS). Additionally, they finalized the CDDs for the Logan and »
In order to develop Infrastructure State Implementation Plans (ISIPs) for ozone standards that the U.S. Environmental Protection Agency (EPA) would approve, the Utah Department of Environmental Quality (DEQ) is applying the EPA's January 2017 »
States are currently working with their Regional Planning Organizations (RPOs), such as the Western Regional Air Partnership (WRAP), to complete the analyses needed as part of the second implementation period for regional haze. The analysis requires »
On May 1, 2019, the Utah Air Quality Board (AQB) discussed the upcoming rulemaking schedule through calendar year 2019, as presented by Thomas Gunter of the Utah Division of Air Quality (UDAQ). The following table contains some of the upcoming »
On June 5, 2019 the Environmental Protection Agency (EPA) proposed in the Federal Register (FR) (84 FR26053) to make a clean data determination (CDD) for the 2006 24-hour fine particulate matter (PM2.5) Salt Lake City, Utah, (UT) Nonattainment Area. »
In September of 2018 a new consortium was formed by UDAQ to develop scientific solutions to Utah's unique air quality problems with others in the local research and regulatory spheres. The initiative is identified as the Air Quality Research Roadmap »
Utah Administrative Code (UAC) R307-401 currently requires a source with the potential to exceed the small source exemption thresholds described in UAC R307-401-9 to submit a notice-of-intent (NOI) air quality application and receive an approval »
The Utah Physicians for a Healthy Environment presented air quality considerations to the Utah Air Quality Board (AQB) in its February 6, 2019 meeting related to the Utah's inland port approved in last year's legislative session. The Utah Physicians »
After almost two years of development of the Salt Lake Area PM2.5 Serious Non-Attainment State Implementation Plan (SIP), the Utah Air Quality Board (AQB) approved the Utah Division of Air Quality's (UDAQ) proposal for Part S of the plan. This »
The Utah Air Quality Board held a working lunch meeting related to UDAQ's approach to enforcement and its penalty policy. This lunch meeting was a follow-up to the September 2018 AQB meeting, where the board had to vote on an enforcement case with a »
Utah currently has three PM2.5 nonattainment areas with separate State Implementation Plans (SIPs). Each SIP is being developed and/or revised based on its attainment classification and area status. A summary of the status of each PM2.5 »
The Utah Division of Air Quality (UDAQ) has been focusing on the Printing and Graphic Arts Industry; as a result of recent nonattainment air quality designations. On October 4, 2017, UDAQ adopted a revised Graphic Arts Rule (R307-351) which »
Last year the Environmental Protection Agency reclassified two of Utah's three PM2.5 Non-attainment areas from Moderate to Serious, which requires UDAQ to prepare a revised PM2.5 State Implementation Plan (SIPs) as a result of this reclassification. »
On April 30, 2018, the United States Environmental Protection Agency (EPA) signed the final notice to designate all remaining counties that were not previously designated in the November 16, 2017 final rulemaking as non-attainment, »
During the March 7, 2018 Utah Air Quality Board meeting, the Utah Division of Air Quality (UDAQ) proposed revising rules in Utah Administrative Code (UAC) R307-101 and R307-403 to incorporate ammonia as a precursor to PM2.5. With Utah's PM2.5 »
The Utah Division of Air Quality (UDAQ) is implementing an online method of emissions inventory submittals for the 2017 reporting year. The emissions inventories are due by April 15, 2018. UDAQ is using the State and Local Emissions Inventory System »
The Utah Division of Air Quality (UDAQ) is progressing with the development of the Provo, Salt Lake, and Logan PM2.5 Serious Non-attainment State Implementation Plans (SIPs). In December 2017, UDAQ decided to split the Provo and Salt Lake »
On Thursday, November 16, 2017, the United States Environmental Protection Agency (EPA) finalized the designations of 2,646 counties in the United States as attainment/unclassifiable; or unclassifiable in regards to the 2015 ozone NAAQS of 0.070 »
On September 6, 2017, the Utah Air Quality Board (AQB) held a board meeting and proposed several new rules and amendments to existing rules that regulate oil and gas sources. The intent of the proposed rules and amendments are to streamline the »
The Utah Division of Air Quality (UDAQ) is progressing with the development of the Provo, Salt Lake, and Logan PM2.5 Serious Nonattainment State Implementation Plans (SIPs). It is currently determining through regional modeling, if the National »
The Utah Division of Air Quality (UDAQ) is progressing with the development of the Provo, Salt Lake, and Logan PM2.5 Serious Nonattainment State Implementation Plans (SIPs). It is currently determining through regional modeling, if the National »
The Utah Air Quality Board (AQB) held a public hearing on July 27 to discuss proposed new amendments to the Utah State Implementation Plan (SIP), which provides additional requirements to Utah's severe PM2.5 non-attainment areas. The Utah AQB stated »
The Utah Division of Air Quality (UDAQ) has proposed revisions to a number of Area Source Rules to achieve Best Available Control Measures (BACM)/Best Available Control Technology (BACT) in the development of a control plan for the PM2.5 Serious »
The Utah Division of Air Quality (UDAQ) is in the process of developing a control plan for the PM2.5 Serious Nonattainment State Implementation Plan (SIP). This evaluation includes assessing emissions and control strategies from the following:Major »
With the reclassification of Utah's three PM2.5 nonattainment areas to serious nonattainment, the Utah Division of Air Quality (UDAQ) is in the process of developing area source rules as a control measure to be included in the new serious »
In an effort to prepare for upcoming PM2.5 and Ozone State Implementation Plan (SIP) development and further understand dynamic air pollution components, the Utah Division of Air Quality (UDAQ) conducted the most extensive air quality study to date »
On November 2, 2016, the Utah Division of Air Quality (UDAQ) held a meeting to discuss the PM2.5 Serious Non-Attainment Area Designation and potential impacts to sources. UDAQ staff provided information regarding the new applicable regulations, and »
As the Salt Lake, Provo, and Logan State Implementation Plan (SIP) areas failed to meet attainment for PM2.5 by the December 31, 2015 attainment deadline, EPA will reclassify these areas as serious non-attainment. EPA was required to reclassify »
On October 1, 2015 EPA reduced the ozone standard from 75 parts per billion (ppb) to 70 ppb. The 70 ppb is calculated as the fourth-highest daily maximum, averaged across three consecutive years. Salt Lake, Davis, Weber, Utah, and Duchesne »
On Wednesday September 7, 2016 the Utah Air Quality Board (AQB) proposed for public comment revisions to the particulate matter under 2.5 microns in diameter (PM2.5) State Implementation Plan (SIP) for Subparts H. 11, 12, and 13. The proposed »
During July 2016, harmful algal blooms were a significant presence in Utah Lake. The Utah Department of Water Quality (UDWQ) and a team of other environmental and health professionals have been monitoring the water quality. Due to the severity of »
On June 10, 2016 the Utah Department of Water Quality (UDWQ) released the Draft 2016 Integrated Report (IR) for a 60 day public comment period. As part of the 2016 IR, UDWQ adopted a new framework for implementing the Clean Water Act (CWA) Section »
On June 1, 2016 Utah Department of Air Quality (UDAQ) provided an update on the Ozone status for the Unita Basin. After conducting a multi-winter study researchers have concluded that formaldehyde and other aldehydes are the major chemical »
Utah Department of Water Quality plans to release a final draft of the 2016 Integrated Report regarding reclassification of waters of the state mid-May 2016. In preparing this updated report priority was given to impaired waters and pollutants »
The 2016 Utah Legislative Session finalized on March 10, 2016. This year two bills addressing air quality were passed which may affect sources in Utah.Senate Bill (SB) 186 – Air Quality IncentivesThis bill authorizes the use of funds from the »
On February 24, 2016, the U.S. Environmental Protection Agency (EPA) amended the Indian Country Minor New Source Review (NSR) rule to extend the minor source permitting deadline for true minor sources in the oil and gas sector. The revised deadline »
Trinity has been tracking Healthy Environment Alliance (HEAL) Utah, Western Resource Advocates, and the Physicians for a Healthy Environment pursuit of a rulemaking petition with the Utah Air Quality Board (AQB), which was originally introduced to »
On August 25, 2015, the EPA proposed conditional approval of sections of Utah's PM2.5 State Implementation Plan (SIP). As a condition for approving the SIP, the EPA is requiring the State to amend R307-328-4 (Gasoline Transfer and Storage - Loading »
The Utah Waste Management and Radiation Control Board recently approved the Division of Waste Management and Radiation to proceed with issuing for public comment the modification of Utah's Hazardous Waste Rules in its January 14, 2016 board »
The 2016 Utah's Legislative General Session begins on January 25, 2016 and will last through March 10, 2016. There are already a few environmental bills in front of the legislature this year that stakeholders should be aware of, which include the »
In both the October and December Air Quality Board (AQB) Meetings, Healthy Environment Alliance (HEAL) Utah, Western Resource Advocates, and the Physicians for a Healthy Environment requested consideration of four (4) new air quality rules. In »
On August 3, 2015, USEPA finalized historic rulemaking, the Clean Power Plan (CPP). Although the key objective of the CPP is to reduce carbon dioxide emissions by 32% from existing power plants by 2030 versus 2005 baseline levels, it will likely »
Salt Lake, Provo, and Logan non-attainment areas have been a been a source of continued discussion since January 2013 when the D.C. Circuit Court of Appeals instituted the "Deadlines Rule" which required Utah Division of Air Quality (UDAQ) to »
In the October Air Quality Board (AQB) meeting, the Utah Department of Air Quality (UDAQ) proposed a fee of $74.37 per ton of emissions released into the atmosphere for fiscal year 2017. This represents a $4.76 increase or an increase of 6.84%. The »
In the October Air Quality Board (AQB) Meeting, Healthy Environment Alliance (HEAL) Utah, Western Resource Advocates, and the Physicians for a Healthy Environment requested consideration of four (4) new air quality rules. Their petition was »
In the October Air Quality Board (AQB) meeting a motion for the board to propose for public comment to Repeal Existing SIP Subsection IX. Part H. 1, 2, 3, and 4 and Reenact with SIP Subsection IX. Part H. 1, 2, 3, and 4 was approved unanimously by »
In the Air Quality Board (AQB) meeting on September 2, 2015, Utah Division of Air Quality (UDAQ) proposed to the board to repeal its existing PM10 State Implementation Plan (SIP) Section IX.A.10 and replace it with proposed SIP Subsection IX.A.10: »
The Utah Division of Air Quality (UDAQ) has amended its Regional Haze (RH) State Implementation Plan (SIP) (Section XX.D.6 and Section IX.H.21 and 22), which is currently in public comment until May 1, 2015. Utah's 2003 RH SIP included SO2 emission »
In accordance with Section 111 of the Federal Clean Air Act, the Environmental Protection Agency (USEPA) promulgates standards for groups of stationary sources that have been identified as significant contributors to air pollution, referred to as »
The 2015 Utah’s Legislative General Session ended with 528 bills passed through congress. House Bill (HB) 0226 Air Quality Revisions, sponsored by Representative Rebecca Edwards addresses air quality rulemaking which could be significant to Utah »
The U.S. Environmental Protection Agency (USEPA) released its long anticipated ozone national ambient air quality standard (NAAQS) proposal on November 25, 2014. The standard has been proposed as an 8-hour standard within the range of 65 and 70 »
When the Utah Division of Air Quality (UDAQ) was developing the PM2.5 State Implementation Plan (SIP), it was not able to include banked PM2.5 or PM2.5 precursor Emission Reduction Credits (ERCs) in the attainment demonstration. Therefore, under »
On December 3, 2014, the Air Quality Board (AQB) adopted PM2.5 State Implementation Plan (SIP) Sections IX.H.11, 12, and 13 for control measures for Area and Point Sources, Emissions Limits and Operating Practices, and the replaced SIP Sections »
The Utah Division of Air Quality (UDAQ) recommended to the Air Quality Board (AQB) a proposed fee of $69.61 per ton for the operating permit program for fiscal year 2016. Title V of the Clean Air Act Amendments of 1990 (CAA) requires the State of »
The Utah Division of Air Quality's (UDAQ) General Approval Order (GAO) for crude oil and natural gas well sites was issued in June 2014. Recently, UDAQ discovered a limitation in rule R307-401-19 making the GAO unnecessarily restrictive. The »
In the Air Quality Board (AQB) meeting on October 1, 2014, Utah Division of Air Quality (UDAQ) proposed for public comment to repeal and replace State Implementation Plan (SIP) subsection IX,A.21, 22, and 23. These sections 21, 22, and 23 address »
In 2008, USEPA promulgated the current 8-hour national ambient air quality standard (NAAQS) for ozone of 75 ppb, which is based on the annual fourth-highest daily maximum averaged over three years. In 2010, USEPA proposed lowering the Ozone NAAQS »
In the September 3, 2014 Air Quality Board (AQB) Meeting, the Utah Division of Air Quality (UDAQ) presented the revised Salt Lake City, UT Nonattainment Area State Implementation Plan (SIP) in Section IX. Part A.21. UDAQ is on schedule to also »
Currently Utah Division of Air Quality (UDAQ) charges a fee to each Title V source a dollar per ton for each ton of emissions up to 4,000 tons per each pollutant. The restructured fee would allow for variable fees to be charged for different »
Currently, UDAQ charges the same fee for each pollutant (fee for FY2015 is $59.06 per ton), and there is a cap on the amount they can charge for each pollutant of 4,000 tons. UDAQ is proposing to amend the Operating Permit fee requirements in the »
In the June 2, 2014 Utah Air Quality Board (AQB) meeting, four (4) draft rules were proposed for Oil and Gas Operators. The State of Utah entered into the U.S. Evironmental Protection Agency’s (USEPA’s) Ozone Advance Program in 2012. As part of »
On March 27, 2104 UDAQ posted the results of the 2012 Regional SO2 Emissions and Milestone Report. Under Section 309 of the Federal Regional Haze Rule, western states and tribes within those states have the option of submitting plans to reduce »
On April 16, 2014, Utah Department of Air Quality (UDAQ) hosted the Western Regional Air Partnership (WRAP) to present a 3-state Air Quality Pilot Study/Data Warehouse, and Western Regional Modeling Framework. In this seminar WRAP and UDAQ »
For several years, the Utah Division of Air Quality (UDAQ) has been working to develop State Implementation Plans (SIPs) to address nonattainment of the 24-hour NAAQS for PM2.5 in both the Salt Lake City, Utah and the Provo, Utah PM2.5 nonattainment »
The Utah Division of Air Quality (UDAQ) has received permission from the board to develop a General Approval Order (GAO) for the oil and gas industry. The draft GAO is located here. Overall, the timeline associated with obtaining authorization »
On May 15, 2013, WildEarth Guardians filed a Clean Air Act citizen suit in the United States District Court in Colorado alleging that Idaho and Utah have failed to the submit the state implementation plans (SIPs) necessary to assure compliance »
On May 9, 2013, USEPA released a proposed rule approving changes to Utah’s rule R307-107, which pertains to source emissions during breakdowns. In April 2011, USEPA published a final rulemaking that explained the Utah SIP was inadequate to attain »
The EPA issued a partial disapproval of the Utah State Implementation Plant (SIP) for regional haze and said that Utah should make sure that further measures are not needed to guarantee coal-fired power plants do not contribute to regional haze in »
US Secretary of the Interior, Ken Salazar, approved a major natural gas drilling project in Utah on May 8, 2012. As part of the project, Texas based Anadarko Petroleum Corp will be allowed to develop up to 3,675 new gas wells over the next decade in »
The Utah Department of Air Quality is currently in the process of developing a PM2.5 SIP which is expected to become approved by late 2012 and will likely affect how emission offsets are handled for areas of PM2.5 non-attainment. Currently, the »