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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.
For the last decade, EPA has been revising, updating, fixing bugs, and introducing beta options in the AERMOD Model with the goal of offering a dispersion modeling tool that is dependable, accurate, and reflective of the best current science. »
On October 12, the Wyoming Air Quality Division began operating a mobile ambient monitoring station in Laramie County, Wyoming, between Cheyenne and Carpenter south of Highway 80. The objective for the station is to monitor impacts from oil and gas »
Although Trinity has supported Alabama clients for many years with environmental permitting and compliance challenges, we recently opened an office in Birmingham, our first in the state. The office is led by Trinity veterans including Managing »
With many technology options available on the market today for managing Environmental Health and Safety (EHS) information, the process of selecting the right tool has become overwhelmingly complex and risky. This article describes a proven approach »
Leak Detection and Repair (LDAR) involves finding facility components that are leaking and fixing them. The U.S. Environmental Protection Agency (EPA) has a long history of regulating industries (such as petroleum refining and chemical »
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.
Effective September 1, 2018, several permitting actions for the Stormwater Construction General Permit (TXR150000) are required to be submitted electronically using the Texas Commission on »
The Air Permits Division of the Texas Commission on Environmental Quality (TCEQ) published a revised technical guidance document for Chemical Source Fugitive (APDG 6422) in June of 2018. This »
The United States Environmental Protection Agency (U.S. EPA) is implementing the national ambient air quality standards (NAAQS) for ozone. Ground-level ozone is a gas that is formed by the »
The graphic below provides a brief outline of Federal PSM/RMP Elements that may apply to your facility based on your facility's PSM and RMP applicability level. OSHA's Process Safety Management »
Beginning September 1, 2018, MSGP DMRs need to be submitted electronically through United States Environmental Protection Agency (U.S. EPA) Central Data Exchange (CDX) NetDMR system. Only sites »
The United States Environmental Protection Agency (U.S. EPA) is implementing the national ambient air quality standards (NAAQS) for ozone that were issued in 2015. Ground-level ozone is a »
The U.S. EPA published the final rule revisions, "Protection of Stratospheric Ozone: Update to the Refrigerant Management Requirements under the Clean Air Act" in the Federal Register (81 FR »
The United States Environmental Protection Agency (U.S. EPA) is implementing the national ambient air quality standards (NAAQS) for ozone that were issued in 2015.Ground-level ozone is a gas that is formed by the reaction of volatile organic »
The U.S. EPA published the final rule revisions, "Protection of Stratospheric Ozone: Update to the Refrigerant Management Requirements under the Clean Air Act" in the Federal Register (81 FR 82272) on November 18, 2016. These revisions represent a »
On May 5, 2018, the Texas Commission of Environmental Quality (TCEQ) approved the proposal of HB 4181: Update to Applicable Requirements for New Source Review and Operating Permits which provides an option for the TCEQ to use an electronic method of »
On April 30, 2018, this rule established initial air quality designations for all the remaining areas in USA, except for 8 counties in San Antonio, Texas area. Those areas will be designated by July 17, 2018. These final designations will take »
Beginning February 1, 2018, TCEQ required that all Permit by Rule (PBR) and Standard Permit (SP) Registrations be submitted through the ePermits program online via TCEQ STEERS. However, confidential information was not accepted through ePermits and »
On February 13, 2018 the TCEQ held a public forum at the Portland Community Center to discuss air quality issues in San Patricio County. While the meeting was specifically in response to recent industrial growth and an uptick in public interest in »
Sand is used in hydraulic fracturing operations (commonly known as "fracking") associated with oil and gas exploration and production operations. With the increase in demand for fracking sand (or frac sand), there is a significant increase in frac »
In case you missed the announcement from TCEQ... the State of Texas Environmental Electronic Reporting System (STEERS) will not be available for ePermit submission this weekend for system upgrades. The ePermits system will be unavailable from »
After four years serving as the Executive Director for the Texas Commission on Environmental Quality (TCEQ), Richard A. Hyde, P.E., will be retiring in April."It has been a privilege to work for the people of this great state, but now it's time for »
The Texas Commission on Environmental Quality (TCEQ) held its annual Emissions Inventory (EI) Workshop on January 24, 2018. The following is a summary of updates for the 2017 reporting cycle.DeadlineAs March 31, 2018, falls on a Saturday, the due »
TCEQ indicated that they have begun incorporating several of the most recent RCRA federal updates into Texas regulations, including the Hazardous Waste Generator Rule Improvements rule. TCEQ is currently still identifying which of the optional »
As a reminder, beginning February 1, 2018, all Permit by Rule (PBR) and Standard Permit (SP) Registrations must be submitted through the ePermits program online through TCEQ STEERS. TCEQ published a new document in December 2017 providing guidance »
On October 1, 2015, the Environmental Protection Agency (EPA) established the 2015 8-hour ozone National Ambient Air Quality Standard (NAAQS) at a level of 70 parts per billion (ppb), down from the 2008 8-hour ozone NAAQS of 75 ppb. Per the »
Earlier this month, TCEQ held a meeting for Emissions Banking and Trading (EBT) stakeholders to discuss the online application and reporting system accessible in STEERS. The slides from this meeting contain detailed information on how to access »
If TCEQ recently published proposed changes to public notice rules for initial and amendment application under the New Source Review (NSR) program (30 TAC Chapters 116, Subchapters B or G).The proposed rulemaking includes the potential for one »
As of February 1, 2018, TCEQ is requiring that permit by rule (PBR) and standard permit (STDP) registration applications be submitted online via ePermits. The Air Permits Division (APD) is revising the process to become more efficient, effective, »
Due to ongoing Hurricane Harvey response and recovery efforts, the Texas Commission on Environmental Quality (TCEQ) decided to postpone the rollout of the new Tier II Online reporting system that was previously going to be required for 2017 »
The current Texas Stormwater Construction General Permit Number TXR150000 will expire on March 5, 2018. The Texas Commission on Environmental Quality (TCEQ) held a public hearing on the new version of the General Construction Permit on September 18, »
On August 24, 2017, the Executive Director of the Texas Commission on Environmental Quality (TCEQ) issued regulatory guidance relating to activities during and immediately following Hurricane Harvey. Texas Governor Greg Abbot has issued suspension »
The Texas Commission on Environmental Quality (TCEQ) recently provided new information regarding the transition of the Texas Tier II Reporting Program to an online web-based reporting system. Please note the following dates and updates to the »
Multi-Sector General Permit (MSGP) Electronic Reporting WaiverIn 2015, the United States Environmental Protection Agency (U.S. EPA) signed a rule requiring National Pollutant Discharge Elimination System (NPDES) regulated entities to submit all »
On July 14, 2017, revisions to the Oil and Gas General Operating Permits (GOPs) 511 and 514 were issued by the TCEQ to address the applicability status of Wise County. Oil and Gas sites located in Wise County are now covered under GOP 511 instead of »
In July 2016, TCEQ added a footnote to the PBR checklists for 30 TAC 106.261 and 106.262 clarifying FNSR applicability review requirements for affected upstream/downstream units for PBRs. TCEQ has been requesting that all actual emissions increases »
The final Refinery Sector Rule (RSR) was published in the Federal Register on December 1, 2015 and became effective on February 1, 2016. The RSR amended 40 Code of Federal Regulations (CFR) 63, Subpart CC (Refinery MACT I), and Subpart UUU (Refinery »
When working on a new construction permit (New Source Review [NSR] permit) or NSR permit amendment, it is important to ask whether or not the project will require refined atmospheric dispersion modeling or effects review (i.e., Health Effects »
On May 23, 2017, a stakeholder meeting was held by the Texas Commission on Environmental Quality (TCEQ) to solicit informal input on the adoption of the United States Environmental Protection Agency's (U.S. EPA) 2015 Underground Storage Tank (UST) »
For a Title V Federal Operating Permits, Deviation Reports and Permit Compliance Certifications for any six-month period must be submitted at least annually regardless if a deviation has occurred or not. Deviation must be reported during the period »
On April 11, 2016, the U.S. Environmental Protection Agency (EPA) disapproved of the Interstate Transport State Implementation Plan for maintenance of the 2008 Ozone National Ambient Air Quality Standard (NAAQS) in other states as submitted by the »
On April 13, 2016, the U.S. Environmental Protection Agency (EPA) approved the revisions to the State Implementation Plan (SIP) submitted on July 10, 2015 by the Texas Commission on Environmental Quality (TCEQ). EPA published a proposal for approval »
State Recommended Redesignation Substitute (RS) SIP Revision for the DFW One-Hour and 1997 Eight-Hour Ozone Standard Nonattainment Area.The 2008 ozone State Implementation Plan (SIP) requirements rule includes a mechanism, called a redesignation »
On June 10, 2016, the Texas Commission on Environmental Quality (TCEQ) issued a draft version of the Air Curtain Incinerator (ACI) General Operating Permit (GOP) 518, which is due for renewal before June 1, 2017. The draft permit is subject to a »
On May 25, 2016, the Texas Commission on Environmental Quality (TCEQ) adopted updates to the waste rules and implemented revisions to 30 Texas Administrative Code (TAC) Chapter 335 for Industrial Solid Waste and Municipal Hazardous Waste.The changes »
Trinity has experience in building a user-friendly Microsoft Excel spreadsheet-based tracking tool that identifies monitoring, testing, recordkeeping, and reporting obligations for a site from an air permitting standpoint. This tool assists in »
On July 6, 2016, TCEQ approved proposed rulemaking for Title 30 Texas Administrative Code (30 TAC) Chapter 101 General Air Quality Rules to add clarification of affirmative defense provisions for certain excess emissions. The proposed rulemaking is »
The following two pollutants/areas were successfully delisted from the Air Pollutant Watch List (APWL):Nickel in Dallas, Dallas County, Texas (APWL 0401); andPropionaldehyde in Texas City, Galveston County, Texas (APWL 1202).The Dallas/Nickel APWL »
On February 26, 2016, a petition was submitted to the Texas Commission on Environmental Quality (TCEQ) requesting that amendments be made to the public notice requirements associated with the Air Quality Standard Permit for Concrete Batch Plants. On »
On August 14, 2016, The Texas Commission on Environmental Quality (TCEQ) issued the renewed Texas Pollutant Discharge Elimination System (TPDES) Multi Sector General Permit (MSGP) Number TXR050000, which authorizes the discharge of stormwater »
On September 7, 2016, EPA finalized an update to the Cross-State Air Pollution Rule (CSAPR) for the 2008 ozone national ambient air quality standard (NAAQS). Under the final ruling, 22 states, including Texas, have revised power sector budgets »
TCEQ has renewed the Multi-Sector General Permit (MSGP) for Industrial Stormwater Discharge (TXR050000), effective August 14, 2016. Existing permittees have until November 14, 2016, to submit a Notice of Intent (NOI) or No Exposure Certification »
On May 25, 2016, the EPA published two proposed rules to approve the Texas Commission on Environmental Quality's (TCEQ's) proposed Clean Air Act (CAA) redesignation substitute rulemaking whereby a finding of attainment would be made for the »
Air Emissions Inventory Reports (AEIRs) for calendar year 2016 are due on March 31, 2017. As of the 2015 calendar year reporting period, paper form Emission Inventory Questionnaires (EIQs) are no longer accepted. The Texas Commission on »
On May 21, 2012, the eight-county HGB area, consisting of Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, and Waller Counties, was designated a marginal nonattainment area for the 2008 eight-hour ozone National Ambient Air »
On January 13, 2017, the Texas Commission on Environmental Quality (TCEQ) approved the adoption of updates to the applicable requirements for Operating permits. 30 Texas Administrative Code (TAC) Chapter 122 will be updated in order to reflect »
If your facility has been exempt from BWON TAB reporting in the past, now is a good opportunity to dust off the TAB calculation spreadsheet and verify the exempt status.The BWON requirements are codified under 40 CFR 61 Subpart FF. All subject »
On October 1, 2015, the Environmental Protection Agency (EPA) revised the National Ambient Air Quality Standard (NAAQS) for ground-level ozone from 75 parts per billion (ppb) to 70 ppb. As a result of this rulemaking, states are required to »
On January 11, 2016, U.S. Environmental Protection Agency (EPA) approved portions of the Infrastructure and Interstate Transport State Implementation Plan (infrastructure-SIP or i-SIP) for the 2010 Sulfur Dioxide (SO2) National Ambient Air Quality »
On January 5, 2016, the U.S. Environmental Protection Agency (U.S. EPA) released its final action to partially approve and disapprove the Texas 2009 Regional Haze State Implementation Plan (SIP) and the Oklahoma 2010 Regional Haze SIP. You can view »
EPA recently released significant rulemaking for the oil and gas sector under proposed NSPS Subpart OOOOa, as well as amendments and updates to NSPS Subpart OOOO. The new rule and amendments will introduce new compliance requirements and »
Effective September 1, 2015, the Tier II Chemical Reporting program will transfer from the Texas Department of State Health and Services (DSHS) to the Texas Commission on Environmental Quality (TCEQ). The move is in response to House Bill 942 that »
The Texas Commission on Environmental Quality (TCEQ) Non-Rule Barnett Shale Standard Permit (6002 Non-Rule) has specific Best Available Control Technology (BACT) requirements included for stationary internal combustion engines (ICE) within Table 6 »
Chapter 101 On January 16, 2015, Texas Commission on Environmental Quality (TCEQ) issued an interoffice memorandum regarding the removal of Title 30 of the Texas Administrative Code (30 TAC) Chapter 101, General Air Quality Rules, sections »
The EPA's stance on Startup, Shutdown, or Malfunction (SSM) emissions has varied over the years. In 2013, EPA published a proposed rule about SSM in response to the 2011 Sierra Club petition that some State Implementation Plans (SIPs) violated »
On October 22, 2014, Subchapter J was adopted into Chapter 101 under Title 30 of the Texas Administrative Code (30 TAC), providing provisions for the Texas Commission on Environmental Quality (TCEQ) to implement an expedited permitting program. »
The 2015 TCEQ Emissions Inventory Workshop took place on January 14th and 15th in Austin, TX. The workshop stressed the importance of Emissions Inventory (EI) Web reporting and benefits associated with its use. Beginning in reporting year 2015 (due »
The Texas Commission on Environmental Quality (TCEQ) proposes amending Title 30 of the Texas Administrative Code (30 TAC) Chapter 101 to allow expedited processing of applications. The proposed rule will apply to owners and operators that filed »
In December 2005, the U.S. EPA first published their SPCC Guidance for Regional Inspectors as a tool for EPA inspectors, as well as owners and operators of facilities that may be subject to the requirements of the Spill Prevention, Control, and »
New air quality regulations focused on the oil and gas industry have challenged affected facilities to comply with the rigid regulatory framework of the Clean Air Act (CAA). Simply put, the CAA was not wired to address operations over wide »
In December 2011, the Texas Commission on Environmental Quality (TCEQ) adopted amendments to the Title 30 of the Texas Administrative Code (30 TAC) Chapter 115 (Control of Air Pollution from Volatile Organic Compounds [VOC]), Subchapter E (Solvent »
On July 26, 2013, Texas Commission on Environmental Quality (TCEQ) finalized a new Permit By Rule (PBR) under Title 30 of the Texas Administrative Code (TAC) Section (§) 106.359 for Oil and Gas Handling and Production Facilities, which specifically »
In 2011, the 82nd Legislative Session postponed reporting for planned maintenance, start-up, and shutdown (MSS) activities for specific Standard Industrial Classification (SIC) Codes in the Oil and Gas Industry. The extended deadline is the earlier »
On December 7, 2011, the TCEQ adopted revisions to rules for certain sources of VOC emissions located in the DFW Nonattainment and other affected areas. The anticipated effective date of this rule change is December 29, 2011. Affected owners or »
The Texas Commission of Environmental Quality (TCEQ) is requesting information from sites that reported > 10 tons per year (tpy) of sulfur dioxide (SO2) emissions in the 2009 TCEQ point source emissions inventory questionnaire (EIQ). This »
On January 19, 2011, the nine-county DFW nonattainment area was redesignated from "moderate" to "serious" nonattainment for the 1997 ozone standard. This redesignation lowers the New Source Review and Title V major source thresholds to 50 tpy for »
The TCEQ has finalized revisions to the Permit by Rule (PBR) and Standard Permit New Source Review (NSR) Authorization mechanisms for oil & gas operations. The new PBR and Standard Permit requirements will take effect on April 1, 2011 for new »
In a November 1, 2010 letter to the TCEQ, EPA stated its position that Permit Alterations under 30 TAC § 116.116 are not an appropriate mechanism to create SIP-approved permits from non SIP-approved Flexible Permits. TCEQ had previously presented »
Even though significant improvements in ambient ozone concentrations have been realized in the past decade in Texas, TCEQ is pursuing additional emission reductions of NOX and VOC because U.S. EPA has continued to tighten the ozone National Ambient »
On June 30, 2010, EPA disapproved Texas’s request to incorporate the flexible permit program into the federally-approved Texas SIP. The Agency determined that the program did not meet the minimum federal Clean Air Act (CAA) requirements for NSR »
The TCEQ has proposed revisions to the Permit by Rule (PBR) and Standard Permit New Source Review (NSR) Authorization mechanisms for oil & gas operations. Driven largely by the increased public scrutiny of the natural gas exploration and production »
On August 2, 2010, Greg Abbott, the Attorney General of Texas, and Bryan Shaw, Chairman of the Texas Commission on Environmental Quality (TCEQ), responded to a request by the EPA to implement the PSD Tailoring Rule. They rejected any implementation »
The U.S. EPA has objected to several draft TCEQ Title V Operating Permits. Among the objections, EPA contends the TCEQ Federal Operating Permits lack enough information for the public or inspectors to monitor a plant's performance against the »
On June 30, 2010, the U.S. EPA announced final disapproval of the Texas Commission of Environmental Quality’s (TCEQ) Flexible Permit Program in the Federal Register stating it does not meet Federal Clean Air Act requirements. Within 60 days of »
On February 9, 2010, EPA established a new 1-hour National Ambient Air Quality Standard (NAAQS) for NO2. The new 1-hour standard is 100 parts per billion (ppb), and supplements the existing annual standard which remains in effect. This new standard »
On March 31, 2010, the EPA disapproved the qualified facilities exemption rule that the Texas Commission on Environmental Quality (TCEQ) had submitted for inclusion in its federally approved State Implementation Plan. This action finalizes EPA's »
If your site is located in a Texas ozone nonattainment area and emits more than 10 tons per year (tpy) of volatile organic compounds (VOC) or 25 tpy of nitrogen dioxide (NOx) in a calendar year, your site is required to submit an Annual Emissions »
On January 6, 2010, the Texas Commission on Environmental Quality (TCEQ) held a public meeting in Houston to accept final public comments on the new Section 185 fee program for the Houston-Galveston-Brazoria (HGB) ozone nonattainment area that was »
On January 6, 2010, EPA proposed to further lower the 8-hour primary ozone standard from 0.075 ppm, set in 2008, to a level within the range of 0.060 - 0.070 ppm to protect public health. EPA is also proposing a new cumulative, seasonal secondary »
On October 8, 2009, EPA promulgated amendments to the New Source Performance Standard (NSPS) for Coal Preparation and Processing Plants, 40 CFR Part 60 Subpart Y. Subpart Y regulates affected facilities located at coal preparation and processing »
On September 23, 2009, the TCEQ commissioners proposed a revision to the Texas State Implementation Plan (SIP) for the control of ozone in the Dallas-Fort Worth (DFW) Eight-Hour Ozone Nonattainment Area. This revision proposed several »
The U.S. Environmental Protection Agency (EPA) provided notice to the Texas Commission on Environmental Quality on September 8, 2009 that they plan to disapprove three Texas air permitting programs. EPA contends that these three programs fall short »
The Texas Commission on Environmental Quality (TCEQ) repealed and removed several Permit By Rules (PBRs), effective September 3, 2009, including the following: §106.101, Domestic Use Facilities; §106.103, Air Conditioning and Ventilation Systems; »
The Texas Commission on Environmental Quality (TCEQ) recently issued a memo on the vacaturs of several Maximum Achievable Control Technology (MACT) standards by the United States Court of Appeals for the District of Columbia Circuit (the D.C. »
The Texas Environmental, Health and Safety (EH&S) Audit Privilege Act (Audit Act) was enacted by the 74th Texas Legislature in 1995 and amended in 1997 by the 75th Legislature. The purpose of the Audit Act is to encourage voluntary compliance with »
The U.S. Environmental Protection Agency (EPA) has concerns with portions of the Texas Commission on Environmental Quality's (TCEQ's) air permitting program and is proposing to impose sanctions or a federal permitting plan on the state which would »
The TCEQ's emission specifications under Title 30 of the Texas Administrative Code (30 TAC) Chapter 117 for stationary, reciprocating internal combustion engines will soon become effective for owners and operators in the Dallas-Fort Worth eight-hour »