Air Quality Permitting and Compliance Support


Air Dispersion Modeling

For more than 40 years, Trinity Consultants has performed air dispersion modeling for industrial facilities, utilities, and government agencies. Trinity is recognized nationally and internationally for our skills and advanced modeling software/infrastructure, enabling Trinity to formulate and conduct dispersion modeling studies for numerous applications.    With the implementation of new, state-of-the-science dispersion models, and more companies realizing the value of dispersion modeling as a planning tool to assess the feasibility of major capital projects, optimize operations, and mitigate risk, Trinity provides unparalleled expertise and service for regulatory situations as well as specialized, often technically challenging scenarios:    Assessing impacts of air emissions from a single site or cumulative sites to demonstrate compliance with ambient air quality standards and other air quality-related values (acid deposition, visibility, regional haze, etc.) utilizing U.S. EPA preferred models (e.g., AERMOD) and beta-version AERCOARE (the marine environment version of AERMOD) Assessing impacts of offshore emissions on the air quality of coastal regions using the Offshore and Coastal Dispersion (OCD) model Assessing visible plumes, icing, and fogging impacts due to high water-content air emissions using specialized models such as FOG, SACTI, and CALPUFF  Performing off-site consequence analyses for risk management planning and meeting state and local air toxic modeling requirements using EPA dispersion, fire, and explosion models included in BREEZE Incident Analyst Evaluating individual and cumulative human and ecological risk, and performing probabilistic risk analyses using various modeling tools including BREEZE Risk Analyst and other risk modeling tools Conducting off-site impact and deposition studies to support litigation activities Performing fatal flaw analyses for siting considerations  Predicting the impact of roadway air emissions with MOVES and AERMOD (EPA is proposing to replace CALINE as a preferred roadway model) Conducting regional modeling studies with the Community Multi-scale Air Quality (CMAQ) model and the Comprehensive Air-quality Model with extensions (CAMx, a photochemical model) for regional haze analyses, control strategy evaluations, ozone/PM2.5 impact assessments, and inter-pollutant credit demonstrations in support of nonattainment new source review permitting Conducting odor concentration modeling and predicting the effect of different abatement strategies using SCREEN3, AERSCREEN, AERMOD, and CALPUFF Analyzing potential risks associated with release of liquefied fuel gas (LFG) and liquefied natural gas (LNG) using BREEZE LFG Fire/Risk and Incident Analyst Predicting structural damage and personnel injury from the detonation of high explosives and vapor cloud explosions with BREEZE ExDAM, and illustrating setup and results in powerful 3D graphs and animations  Processing model-ready meteorological data from surface/upper air observations as well as prognostic meso-scale meteorological models (WRF/MM5) to support to various dispersion models (AERMOD, CALPUFF, CMAQ, CAMx, OCD, etc.)    Air Dispersion Modeling Services Trinity provides a wide range of air quality modeling consulting services for regulatory applications, emergency planning, and human health assessments. Regulatory Air Dispersion Modeling Trinity is a global provider of air dispersion modeling, air quality compliance services, and software solutions to regulated air emissions sources of all varieties. Trinity is a leader in the practical use of AERMOD, CALPUFF, and other dispersion models, and has developed numerous tools to aid in identifying subtle anomalies in modeled results that can often be challenged in a regulatory context. Trinity is also the only provider of true high performance computing (HPC) solutions for models such as AERMOD, CALPUFF, and SCIPUFF. Trinity's high performance software solutions and high-speed cluster modeling infrastructure save incalculable computer processing hours, enabling more in-depth analyses and faster project completion. Class I Area PSD Impact and Regional Haze Analyses Trinity has performed numerous Class I area analyses in support of Prevention of Significant Deterioration (PSD) permit applications including PSD Class I Increment and Air Quality Related Value (AQRV) analyses, i.e., visibility and acidic deposition using CALPUFF. In addition, Trinity has completed visibility assessments using VISCREEN and PLUVUE and regional haze analyses for Best Available Retrofit Technology (BART) and Reasonable Progress evaluations in support of the Regional Haze Rule with CMAQ/CAMx. CALPUFF and CAMQ/CAMx modeling requires far more sophisticated analysis than typical near-field models. Because CALPUFF may soon be demoted by EPA as a preferred model, Trinity is increasingly using CMAQ/CAMx for BART and Reasonable Progress evaluations. CAMx has gained favor because of its superior consideration of chemical reactivity as well as other options. We are also versed in the use of SCICHEM, another possible alternative to CALPUFF. Photochemical Grid Modeling The U.S. Environmental Protection Agency (EPA) widely recognizes and routinely utilizes Photochemical Grid Modeling (PGM) for regulatory analysis and attainment demonstrations. PGM simulates the impacts from single and multi-source studies by estimating pollutant concentrations and deposition for chemically reactive pollutants over large spatial scales. Similar regional scale modeling can be performed for inert pollutants as well. Trinity provides comprehensive modeling for both PGM and regional air quality studies by offering such modeling services to our clients nationally and internationally. For more than 10 years, experts at Trinity have been supporting clients with PGM and regional scale modeling services. Learn more>> Multi-Pathway Risk Assessment Dispersion Modeling Trinity has assisted industry, regulatory agencies, and trade associations with technical and modeling support to conduct human health and ecological risk assessments. These projects have included National Environmental Policy Act (NEPA) projects such as coal-gasification plants, MACT residual risk assessments, risk assessments to support RCRA facility permitting for hazardous waste incineration or that utilize hazardous waste derived fuel, and other air quality assessment studies with both inhalation and ingestion pathway assessments. These specialized studies employ a combination of BREEZE AERMOD/ISC, BREEZE Risk Analyst, and other risk modeling tools to account for inhalation and ingestion pathways for maximum exposed individuals and overall population impacts.   Emergency Response Planning and Associated Acute Risks Trinity performs many health effects impact studies for actual and potential releases of toxic and hazardous air pollutants. These studies have included emissions estimations, acute toxicity evaluations for comparison to threshold limit value-based concentration limits, cancer risk assessment, and ambient monitoring studies. Trinity's staff has considerable experience modeling emissions from accidental releases of liquid spills and spills of liquefied gases using dense gas models including DEGADIS, SLAB, ExDAM, VASDIP, and HEXFRAG. Both BREEZE Incident Analyst and BREEZE ExDAM contain a suite of agency-recognized and industry-standard models that can be utilized in various scenarios.  High Performance Computing Solutions Trinity provides true high performance computing (HPC) solutions for models such as AERMOD and CALPUFF. The BREEZE Remote Modeling System (or BRMS), delivers runtimes up to 100 times faster (e.g., 8 hour runs reduced to 5 minutes) than standard desktop computing. The BRMS for AERMOD operates on a massively parallel computer cluster that harnesses the processing power of multiple multi-core computers. Users can submit data online, anytime, and receive email notification when model results are available. The BRMS utilizes the BREEZE AERMOD Parallel Fortran application, which produces identical results to EPA's public air dispersion model. Model Development and Training Since 1983, Trinity has provided market leading PC-based BREEZE® air dispersion modeling software to environmental professionals. Trinity also provides professional training courses in dispersion modeling, taught by senior-level consultants who are dispersion modeling experts. In addition, Trinity develops customized modeling applications and teaches custom courses to meet the needs of individual organizations. Why Choose Trinity In short, there's no better choice for your dispersion modeling needs. Our experience is multi-faceted and extensive. Our strategies are innovative, time saving, and cost-effective. Our staff and tools are the best in the business.

 

Air Quality Permitting

Whether constructing a new industrial facility, expanding production, or modifying operations, owners and operators may be subject to air quality permitting requirements. Industrial sources must be designed, constructed, and operated to comply with all applicable air quality regulations. Air quality permitting requirements exist within a range of regulatory programs, including state and local codes, and federal programs such as New Source Review and the Title V operating permit program. Each permitting program has associated technical requirements such as emissions quantification, control technology evaluations, air quality analyses (including regulatory dispersion modeling), ambient air and meteorological monitoring, emission standards applicability, and compliance assurance.    Trinity Consultants can assist with all phases of the air permitting process. We have completed thousands of   permitting projects and our experience translates into accurate, timely permit applications that are strategically crafted for maximum flexibility, and expert negotiations with regulatory agencies, streamlining the permitting process.   New Source Review The federal New Source Review (NSR) program requires that new and modified major sources undergo rigorous air quality analyses and receive a permit prior to commencing construction on any physical changes or changes in the method of operation. The analyses must demonstrate the implementation of appropriate pollution control technology and maintenance of air quality standards. NSR is a constantly evolving program, at both the state and federal levels. To determine NSR applicability, Trinity identifies and characterizes emissions from the equipment that comprise the regulated source. Using this information, along with U.S. EPA attainment designations, Trinity performs a thorough regulatory review to determine applicability and requirements of Nonattainment New Source Review (NNSR), Prevention of Significant Deterioration (PSD) regulations, and state construction permitting requirements. Trinity then works with its client to develop a permitting strategy that will enable the project to proceed in a timely manner, while optimizing operational flexibility and minimizing costs. Nonattainment NSR (NNSR) Requirements New or modified major sources in areas designated as nonattainment with National Ambient Air Quality Standards (NAAQS) may be subject to NNSR. If potential emissions from a modification exceed threshold quantities and the facility is a major source of emissions, Trinity's technical staff will conduct an emissions netting analysis. Emissions netting considers previous emissions changes (within a defined period) at an existing major source to determine if the proposed modification can avoid classification as a major modification. If NNSR is triggered by a project, Trinity will conduct the required Lowest Achievable Emission Rate (LAER) control technology assessment (or the less stringent Best Available Control Technology (BACT) assessment in certain limited circumstances). Other NNSR requirements include locating and purchasing emissions offsets from other permitted sources that have certified emissions reduction credits, as well as demonstrating that the benefits of the project significantly outweigh the environmental and social costs imposed as a result of the chosen location, size, or production processes. In addition to assisting with permitting requirements, Trinity also supports clients with identifying and negotiating the purchase of offsets. Prevention of Significant Deterioration (PSD) New or modified major sources located in areas designated as attainment with NAAQS are subject to PSD review if emissions or net emissions exceed certain threshold quantities. Assessing PSD applicability is a complex undertaking based on volumes of guidance and policy issued by EPA over the program's history. Trinity's depth of experience with the PSD program supplies our clients with the nuanced insights needed to develop the optimal permitting strategy. Like NNSR, PSD regulations allow major sources to “net” out of PSD review, should that be practicable. Projects triggering PSD review require a best available control technology (BACT) analysis and extensive air dispersion modeling  that addresses issues such as complex terrain, direction-specific building downwash, and visibility impairment and regional haze impacts in designated Class I areas. As a cornerstone of its technical skill set, Trinity has the specialized expertise to conduct the most challenging dispersion modeling analyses. Obtaining a PSD permit in a timely, cost-efficient manner requires a thorough understanding of the entire PSD program. Our extensive experience with the PSD program helps save clients thousands of dollars in permitting costs and opportunity costs that could result from delays in the start of construction.   Operating Permits   Client Services to Streamline Air Permitting Regulatory applicability analyses Permit strategy development Emissions quantification Emissions netting analyses Permit application development Compliance management tools Compliance certification assistance Control technology evaluations Emissions trading assistance   The Title V program is a federally enforceable operating permit program for significant sources of air emissions, as defined by certain annual threshold levels. Subject sources must submit permit renewal applications every five years to update regulatory applicability and address changes at emission units at the facility. In addition to renewal applications, facilities may also be required to submit Title V permit modification applications if they undertake new construction, make changes in source operations, or become subject to new or existing regulations (e.g., a NESHAP regulation).     In addition to the permit requirements, the Title V program shifted the burden of demonstrating compliance from the regulatory agency to the facility. Compliance demonstration and certification may be a significant undertaking depending on company processes, regulatory requirements, and the efficiency of the company's recordkeeping and reporting methodologies. Trinity Consultants has prepared more than 850 initial Title V operating permit applications, permit renewal applications, and permit modification applications in all ten EPA regions. Trinity's depth of experience benefits clients in developing Title V permit applications that maximize operational flexibility while assuring monitoring, recordkeeping, and reporting efficiency. Our experience in preparing permit modification applications across all industries allows Trinity to bring unique insight to each engagement and to develop the most beneficial strategies based on client needs.   Trinity built its reputation for excellence on air quality expertise. Air permitting is the foundation of our business and our staff of air quality experts is one of the largest in the country. Our focus on air quality and commitment to ISO 9000-based quality management has resulted in project delivery systems designed to complete jobs on time, accurately, and within budget.   Contact your local Trinity office at (800) 229-6655 for assistance.  

 

Ambient Monitoring Service and Integration

Trinity's 2014 merger with Meteorological Solutions, Inc. (MSI) of Salt Lake City enhanced our ability to provide comprehensive, turnkey meteorological and ambient air quality monitoring services to our clients.    Trinity's monitoring solutions include the highest quality instrumentation, installed by experienced professionals, as well as customized software for data monitoring, retrieval, analysis, reporting, and presentation. Our quality assurance and quality control programs ensure that collected data meet jurisdictional regulatory requirements for completeness, representativeness, precision, and accuracy, achieved by conducting performance and system audits using accepted guidelines and methods.      Our team provides a full range of air quality and meteorological services including: Complete siting services Agency negotiations  Turnkey design, installation, and operation of ambient and meteorological stations and networks Monitoring and quality assurance plan development Equipment installation and calibration Multiple telemetry options including cellular and satellite with data hosted and managed on Trinity's cloud servers Automated 24/7 data retrieval every 5 minutes Automated zero span and precision checks Complete data management and validation Official data reporting in state and EPA formats Secure client access to real-time data with extensive plotting and analysis features Iterative modeling site assessment Automated data evaluation and validation paired with analysis by experienced meteorologists  Meteorological towers from 2 meter tripods to 100 meter multi-level towers with solar powered option Continuous monitoring of all criteria pollutants (NO2, ozone, SO2, CO, PM10, PM2.5) Complete data requirements rule (DRR) SO2 monitoring services Learn more about our Ambient Monitoring Services Learn more about our Meteorological Monitoring Services Learn more about our Applied Meteorology Services   We are able to assist with the collection of data related to meteorological parameters, criteria pollutants, air toxics, and hydrocarbons. With our 1,200 sq. ft. state-of the art laboratory, we are able to acceptance test and integrate monitoring equipment, conduct site telemetry prior to deployment, and maintain the spare parts needed to keep installations operational.   Our monitoring services are led by technical director Casey Lenhart. Casey has more than 20 years of experience in monitoring site logistics and system development, equipment installation and maintenance, data quality assurance, and agency negotiations. Casey leads a team of specialists who configure, install, calibrate, data process, and quality assure stations across the country. For more information on how we can assist with your monitoring needs, call (801) 272-3000 or email clenhart@trinityconsultants.com.  

 

Ambient Monitoring Services

Trinity provides comprehensive ambient air quality monitoring services encompassing the design and implementation of monitoring stations from simple to highly complex, and including routine operations, data validation and official reporting. Our goal is to provide solutions that are technically sound, cost-effective, and designed to meet your specific monitoring requirements. We provide customized software solutions for data monitoring, retrieval, and presentation. Only instrumentation which has proven to be of the highest quality and reliability are recommended and installed by our professionals. Our QA/QC programs are designed to ensure that your monitoring data meet EPA and state requirements for completeness, representativeness, precision and accuracy. Our experienced auditors conduct meteorological and air quality performance and system audits using EPA guideline methods and NIST-traceable reference standards. We offer customized software for automated data evaluation and validation to identify monitoring problems quickly and reduce data loss.   Our related services include: Complete siting services Agency negotiations Monitoring and quality assurance plan development Equipment installation and calibration Secure 24/7 data hosting Automated zero/span and precision checks Complete data management and validation Official data reporting in State and EPA formats Iterative modeling site assessment Air toxics sampling of mobile, industrial and biogenic sources Remote communication and interrogation of monitoring stations Continuous monitoring of criteria pollutants (NO2, ozone, SO2, CO, and particulate matter (PM10, PM4, PM2.5)) Data Requirements Rule (DRR) SO2 and meteorological monitoring HAP, toxics and special-purpose monitoring such as fenceline monitoring Meteorological and air quality system and performance audits EPA-approved methods NIST-traceable reference standards Automated data evaluation and validation paired with analysis by experienced meteorologist For more information on how we can assist with your ambient monitoring needs, call (801) 272-3000 or email clenhart@trinityconsultants.com.

 

Applied Meteorology Services

Trinity Consultants provides forecasting and climatological services to state and local government, as well as to the private sector in the industrial, legal, insurance, infrastructure, energy, nuclear, and the entertainment/media fields. Our meteorologists have decades of experience, and are highly skilled in providing their clients with detailed and accurate information. Our weather forecasts are developed to fit your needs and highly flexible to changes you may require over time. Our forecasts are highly specific, accurate and are developed by our meteorological staff and not taken directly from weather models. Climatology is used in a variety of business and scientific aspects. MSI will work closely with your organization to understand what specific climate data you need and organize this information in a manner that will make it easy to understand and utilize.   Trinity's meteorological/climatological services include: Forecasts from short term “Nowcasting” to long term seasonal outlooks for all applications Exclusion of air quality data due to exceptional conditions Climatology development for specific locations, including wind energy calculations and storm return period calculations Forensic meteorology providing detailed information on past weather events and expert testimony Meteorological/climatological database development from hardcopy and electronic data Development/compilation of solar, wind, and severe weather data for alternative energy Hydro-meteorological analysis of storm precipitation using radar and rain gauge data to estimate storm totals, precipitation rates and precipitation depth-area-duration maps and tables For more information on how we can assist with your applied meteorology needs, call Casey Lenhart at (801) 272-3000 or email clenhart@trinityconsultants.com.

 

Cap-and-Trade Services

Cap-and-Trade (C&T) programs have become increasingly important in the control and regulation of regional and global air pollutants. In contrast to traditional air pollution regulations, C&T programs require subject facilities to comply with a facility emissions cap that declines on an annual basis, while providing the flexibility to buy and sell excess emission reductions (referred as allowances or credits). Since the 1990 Clean Air Amendments, C&T programs have been used to regulate regional air pollutants, such as volatile organic compounds (VOCs), oxides of nitrogen (NOx), and oxides of sulfur (SOx). In recent years, C&T programs are being used as the primary regulatory vehicle for controlling greenhouse gas (GHG) emissions within the U.S. and internationally.   Where applicable, C&T programs can impact many different types of air pollution sources and industrial sectors, including heavy industry, manufacturing, power, transportation fuels, and utilities. Depending upon the specific rules developed by the regulatory authority, C&T facilities must contend with numerous compliance requirements that far exceed traditional air pollution regulations, which may include:   Declining annual permit limits Industry benchmarking for free credit allowances Daily, monthly and/or annual emissions reporting Quarterly and annual permit reconciliations Buying and selling of emission credits Forecasting future emissions and credit needs Developing air pollution control plans and strategies Continuous Emissions Monitoring (CEMS) Frequent regulatory audits, inspections and testing Independent 3rd party verifications Trinity's multi-disciplined staff provides the highest quality C&T support services that enhance strategic planning and regulatory compliance while maximizing operational flexibility. Trinity helps its clients accomplish this by combining regulatory expertise, technical proficiency, responsiveness, and creative thinking.    Trinity offers strategic advisory and consulting services to prepare and support clients in all phases of C&T regulatory programs, including:  Early stages of rule development Annual reporting and compliance Buying/selling of allowances  Air pollution control plans and compliance forecasting   Trinity regularly monitors the development of C&T programs and actively supports hundreds of regulated facilities throughout the United States and international territories. For more information on Trinity's C&T regulatory services, please contact Charles Lee or Steve Walters at (949) 567-9880.    

 

Emissions Monitoring Support

Industrial facilities subject to air permits and regulatory emissions limits must frequently implement sophisticated Continuous Emissions Monitoring Systems (CEMS) to demonstrate compliance. Without a solid understanding of the federal regulatory requirements under 40 CFR Parts 60, 63 and 75 (as well as state and local requirements) and the development of a good CEMS program, demonstrating compliance with the applicable requirements can be difficult.    For more than four decades, Trinity Consultants has assisted facilities with air quality permitting and compliance including CEMS related services. Trinity performs CEMS program audits, developing or reviewing existing Parts 60 and 75 Quality Assurance Plans (QAP), and associated permitting. Maintenance of CEMS is an integral part of any QA/QC program and Trinity can assist in creating or updating facility maintenance programs to ensure maximum CEMS data availability and efficient use of existing resources by providing best practice recommendations. We also provide related training courses which detail specific applicable regulations and CEMS maintenance and quality assurance. Trinity's experienced professionals have the expertise to help you ensure a CEMS program that meets your legal obligations and streamlines associated processes.   For assistance, contact Adam Jackson at (832) 483-0511 or ajackson@trinityconsultants.com or Wes Younger at (404) 219-0517 or wyounger@trinityconsultants.com.

 

Emissions Reporting

Emissions Inventories Many air quality permitting projects require a facility-wide inventory of all air emissions sources. An accurate accounting of emissions is also necessary for payment of annual permit fees to state and local regulatory agencies. In addition to common point sources, facilities often have emissions sources that are more difficult to identify and quantify, such as raw material storage piles, material handling operations, solvent cleaning of parts and machinery, surface coating operations, and dust from roadways and parking lots. Use of appropriate emission factors and rates is crucial for developing permitting strategies, determining applicable regulations, and performing air dispersion modeling analyses. Trinity has conducted emissions inventories for thousands of facilities, some with more than 1,000 individual emission points, including fugitive, mobile, point, area, and line sources. We utilize a variety of resources to arrive at the most appropriate emission factor for each source, including information developed by EPA, industry organizations, and equipment manufacturers. Upon completion of the emissions inventory, Trinity compiles the emissions data and corresponding calculations and prepares detailed reports documenting this information. An appropriate tracking and reporting methodology may be as simple as a customized spreadsheet or as sophisticated as a company-wide, fully integrated EHS management information system. Trinity, and its Digital Solutions team, has provided a broad range of emissions data management solutions, consistent with the complexity of the site and the budget of the client.

 

Emissions Testing

Trinity provides expert consulting services related to emissions measurement, also known as “stack testing.”  Services include:  Forensic analysis of test programs that yield questionable results Design and implementation of test programs Expert witness services related to test program issues Test program management  Assistance with test programs that involve unusual, non-standard emissions units and/or test methods While Trinity does not perform emissions testing in North America, our experts have decades of experience with EPA test methods and with a wide variety of emissions units that require periodic testing.  Trinity also offers professional training courses designed to familiarize environmental professionals with emissions measurement programs, common errors, and effective emissions measurement program management. For assistance, contact Richard Trzupek at (630) 495-1470 or rtrzupek@trinityconsultants.com.

 

LDAR Support

Trinity Consultants provides Leak Detection and Repair (LDAR) assistance for the oil and gas, refining, chemical, and petrochemical industries. Trinity is knowledgeable regarding LDAR regulatory requirements and has provided compliance and field support to many facilities nationwide.    Trinity's LDAR experience includes applicability and compliance support for facilities subject to New Source Performance Standards (NSPS), National Emission Standards for Hazardous Air Pollutants (NESHAP), Maximum Achievable Control Technology (MACT) standards, the Resource Conservation and Recovery Act (RCRA), and state specific requirements, including but not limited to: NSPS - 40 CFR 60, Subparts VV, VVa, GGG, GGGa, KKK, and OOOO NESHAP - 40 CFR 61, Subparts F, J, V, and FF MACT - 40 CFR 63, Subparts H, I, S, CC, HH, SS, TT, UU, YY, GGG, MMM, EEEE, FFFF RCRA Subpart BB   Trinity performs gap assessments of facilities' LDAR programs, reviewing them for compliance with applicable requirements. We also facilitate the development and implementation of LDAR programs including the following tasks:  Defining LDAR program and training requirements Acquiring equipment and providing the associated training Implementing monitoring equipment capable of logging data for upload to tracking software Assisting in software selection for long-term program compliance documentation Integration with multiple LDAR databases such as LeakDAS, FEMS, and GuideWare   Trinity also conducts third-party LDAR audits for clients in the chemical and refining industries. Trinity has performed multiple third-party LDAR audits as required by client's Consent Decrees. And, Trinity provides professional training, Compliance Management for Fugitive Emissions & LDAR, as well as custom training on Method 21 and other related topics.     Trinity provides a wide range of assistance related to LDAR, including the following:  Applicability determination Enforcement assistance Response to Section 114 requests Reporting assistance Performing LDAR emission calculations Training (e.g., custom courses) Preparation of written programs   For LDAR assistance, please contact Inaas Darrat at (713) 552-1371 or idarrat@trinityconsultants.com.    

 

Meteorological Monitoring Services

Trinity's monitoring team sets the bar when it comes to meteorological monitoring programs of all sizes and complexities. Our extensive experience includes single tripod based stations, large-scale networks utilizing multiple free-standing or guyed 100-meter towers with multiple measurement heights, and everything in between. We excel in near real-time data collection and data management of meteorological monitoring programs located in urban and remote areas utilizing a variety of communication packages, as well as off-grid power systems.   Our team is particularly proficient in meteorological programs with respect to AERMOD model requirements. Whether an existing station modification or a new construction, we have the knowledge and experience you need to produce a valid, defendable, and complete data set - the first time, every time. Our maintenance and calibration services are absolutely critical to keeping meteorological equipment in good working order and producing accurate data. We also provide the ultimate convenience of complete and custom web-based data access.   Our monitoring team provides specialize in these meteorological monitoring services: NRC-compliant meteorological towers  PSD-compliant meteorological towers Complete siting services Agency negotiations Equipment installation and calibration Secure 24/7 data hosting AERMOD-ready towers (new/upgrades) Wind energy towers Complete turn-key installation NIST-, A2LA-, and NVLAP-certified audits and calibrations standards All major brands of meteorological sensors Very high data recovery (typically > 99%) Iterative modeling site assessment Simple to complex datalogging systems Customized real-time data access Phone modems/radio telemetry/cellular/IP communications Automated data evaluation and validation paired with analysis by experienced meteorologists Calibration services/Audit services For more information on how we can assist with your meteorological monitoring needs, call Casey Lenhart at (801) 272-3000 or email clenhart@trinityconsultants.com.

 

NESHAP/MACT and NSPS Compliance

The U.S. EPA has completed its mandated development of the vast majority of the New Source Performance Standards (NSPS) and Emissions Guidelines (EG) in 40 CFR 60 and the National Emissions Standards for Hazardous Air Pollutants (NESHAP) in 40 CFR 61 and 40 CFR 63 (“MACT standards”).  Trinity has tracked these regulations from their genesis in the 1970 Clean Air Act (CAA) and the CAA Amendments of 1977 and 1990. Trinity has an extensive history of providing industry with related compliance assistance such as applicability determinations, compliance plan development, development of testing and monitoring programs, and more.   Additionally, Trinity monitors the ongoing development and promulgation of new NSPS and NESHAP rules. Trinity has partnered with companies and trade organizations to prepare rule development surveys, comment on EPA's proposals, and analyze the surveyed actual emissions data from which Maximum Achievable Control Technology (MACT) standards are developed. Today, equipment in nearly every facility in the U.S. is affected by one or more NSPS/EG or NESHAP rules. The requirements in these rules are often the first area of consideration in many air permitting studies. With more than four decades of experience in air regulations and permitting, Trinity can be of great value in helping you interpret EPA's rulemaking information and determine effective compliance solutions for your operations.   For assistance, contact your local Trinity office at (800) 229-6655.  

 

Photochemical Grid Modeling

The U.S. Environmental Protection Agency (EPA) widely recognizes and routinely utilizes Photochemical Grid Modeling (PGM) for regulatory analysis and attainment demonstrations. PGM simulates the impacts from single and multi-source studies by estimating pollutant concentrations and deposition for chemically reactive pollutants over large spatial scales. Similar regional scale modeling can be performed for inert pollutants as well. Trinity provides comprehensive modeling for both PGM and regional air quality studies by offering such modeling services to our clients nationally and internationally. For more than 10 years, experts at Trinity have been supporting clients with the following PGM and regional scale modeling services.   Photochemical grid modeling: Comprehensive Air Quality Model with extensions (CAMx) and Community Multiscale Air Quality (CMAQ) modeling system Emissions processing: Emission Preprocessing System, version 3 (EPS3), Motor Vehicle Emission Simulator (MOVES), Sparse Matrix Operator Kernel Emissions (SMOKE), and Model of Emissions of Gases and Aerosols from Nature (MEGAN) Meteorological data processing: Weather Research & Forecast (WRF) and 5th Generation Mesoscale Model (MM5) Post Processing and data visualization: Modeled Attainment Test Software (MATS), Visualization Environment for Rich Data Interpretation (VERDI), and ArcGIS Data analysis: Statistical data analysis, Hybrid Single Particle Lagrangian Integrated Trajectory Model (HYSPLIT), wind rose, and pollution rose Key Application Areas Trinity has utilized PGM in key application areas including, but not limited to, the following:   Single source impact evaluations for Prevention of Significant Deterioration (PSD)  and Federal Energy Regulatory Commission (FERC) permitting Visibility Studies for Regional Haze Best Available Retrofit Technology (BART) and Reasonable Progress (RP) analyses and control strategy evaluations State Implementation Plan (SIP) modeling and planning support Speciated Model Attainment Test (SMAT)Unmonitored Area Analysis (UMAA)Motor Vehicle Emissions Budget (MVEB)Reasonable Further Progress (RFP) Control measure evaluations Precursor contribution and sensitivity demonstrationsReasonably Available Control Technologies and Measures (RACT/RACM)Best Available Control Technologies and Measures (BACT/BACM)Most Stringent Measures (MSM) Source apportionment analyses including Ozone Source Apportionment Technology (OSAT) and Particulate Source Apportionment Technology (PSAT) studies Sensitivity analyses using brute force and Decoupled Direct Method (DDM) Conceptual ozone model Site selection and fatal flaw analyses Inter-Pollutant (IP)/Inter-Basin (IB) credit demonstrations High Performance Computing Solutions Trinity has high performance computing (HPC) clusters that are run using state-of-the-art processors supported by high speed networks and high performance storage. The HPC's computational nodes utilize Intel processors with Linux operating environment. Trinity's HPC clusters can simultaneously run several scenarios of resource intensive PGM that has saved an incalculable number of computer processing hours, enabling more in-depth analyses and faster project completion. Trinity periodically upgrades the clusters to maintain the speed and efficiency in meeting clients needs. Why Choose Trinity Our experience is multi-faceted and extensive.  Our strategies are innovative, time saving, and cost-effective.  Our staff and tools are the second to none, embodying our company's principle in every way to provide environmental solutions delivered uncommonly well. 

 

Regional Haze Rule Background

The 1977 Amendments to the Clean Air Act (CAA) set a national goal to restore the 156 federally mandated Class 1 Areas to pristine conditions by preventing any future, and remedying any existing, man-made visibility impairment, or “regional haze”.  Protection of visibility impairment from new sources was established in a 1980 rulemaking where requirements for visibility impairment in terms of “reasonably attributable” impairment and regional haze were addressed. Regulations specifically targeting visibility impairment in Class 1 Areas were finalized in the 1999 Regional Haze Rule (RHR). Over the course of the past two decades these regulations have evolved: July 1, 1999 - EPA promulgated the RHR to address regional haze. As part of the RHR, it established applicability criteria for defining Best Available Retrofit Technology (BART) eligible sources. States were also required to developed regional haze State Implementation Plans (SIPs) to establish a uniform rate of progress (URP) or “glidepath” for each Class I area, reasonable progress goals (RPGs), and long term strategies (LTS) for attaining natural visibility conditions by 2064. July 6, 2005 - Amendments to the 1999 RHR were finalized. These amendments (often called the BART rule) applied to the provisions of the RHR that require BART emission controls and included definitions for BART applicability criteria and guidance for making source-specific BART determinations. 2007-2018 - States completed source-specific BART determinations with SIPs due to EPA in 2007 describing the strategy for achieving RPGs through 2018. There are still pending BART analyses in various states that are undergoing litigation; however, the end of the 1st planning period, and BART, occurred on December 31, 2018. July 8, 2016 - EPA issued draft guidance for states in the development of their regional haze SIPs and progress reports for the 2nd planning period (2018-2028). January 10, 2017 - EPA finalized revisions to the RHR including clarifying a state's LTS and RPGs for SIPs, finalizing the requirement to select the 20% most impaired days from anthropogenic sources, and allowing the adjustment to URPs for international anthropogenic impacts. September 11, 2018 - EPA released the Regional Haze Reform Roadmap outlining a path for EPA to work collaboratively with states to implement the RHR including converting any remaining BART FIPs to SIPs. December 20, 2018 - Technical Guidance issued for the 2nd planning period. Details on this Guidance and strategies for industrial sites are provided in the next section. Learn more about the Regional Haze Rule, the 2nd planning period and how Trinity can help.

 

Regional Haze Support

The Regional Haze Rule (RHR) establishes a comprehensive visibility protection program for certain national and international parks and wilderness areas ( Class 1 areas) and requires states to set reasonable progress goals (RPGs) towards achieving natural visibility conditions in all Class 1 areas by 2064. EPA released Regional Haze Rule  Technical Guidance on Tracking Visibility Progress for the Second Implementation Period outlining the methods by which states should develop their State Implementation Plans (SIPs) for the 2nd planning period (2018-2028). The guidance includes methods previously not allowed in the 1st planning period. Learn more about the background and history of the Regional Haze Reform here. 2nd Planning Period Overview SIPs are due July 21, 2021 for the 2nd planning period. The SIPs should include a state's calculations of baseline and natural visibility conditions, including scientific data documenting an adjustment to the uniform rate of progress (URP) if international emissions impact a state's Class 1 area(s), the long-term strategy for regional haze reduction, and RPGs to achieve natural conditions by 2064. Unlike the 1st planning period, where Best Available Retrofit Technology (BART) -subject sources were the focus, the 2nd planning period can target any large source of NOX, SO2, and/or PM across industries, including sources previously evaluated under BART. There are five  regional planning organizations (RPOs) that evaluate technical information related to how their States and Tribes impact Class 1 areas. RPOs are developing proposed methodologies for screening sources to determine whether sources could potentially impact a Class 1 area. The data collected and methodologies proposed are then passed to states for their SIP development.  Will you be targeted for the regional haze second planning period? Learn more > Trinity Can Help Trinity worked with clients during the 1st planning period, which included involvement in BART and Reasonable Progress (RP) analyses, litigation support across the U.S., and numerous strategy discussions, and negotiations with states and EPA. From this experience, we recommend industrial sites be involved in the stakeholder process for the 2nd planning period, and ensure the following steps are evaluated. Trinity can provide guidance for your site(s) through this process: Analyze IMPROVE data by species to determine impact per species on Class 1 Areas Compare actual visibility impairment as measured for a Class 1 Area to the URP Determine source contribution to impairment by type Assess impact of international sources on Class 1 Areas Assess individual source contributions and test alternative emission rates Conduct Four-Factor analyses, including control cost evaluations For those sites located in RPOs and states that have not defined their screening methodology, Trinity can assist with this analysis to determine if your site might be screened into this program, or we can help you be more prepared in the stakeholder process and subsequent evaluation phase. We can help discuss the most recent EPA guidance, where options may exist for optimizing modeling, and what steps the regulated community may want to take now as the states decide about NOx, SO2, and PM10 control measures for the next ten years. As the 2nd planning period evolves, Trinity will continue to follow the RPOs/states to remain current with developments. For more information, contact Trinity at (800) 229-6655 for assistance in determining what your RPO/state is planning, helping to decipher RPO methodologies and how they may impact your site, preparing comments on proposed methodologies and photochemical modeling, and conducting site-specific evaluations. Software Expertise for Regional Haze Trinity has performed regional haze analyses for Best Available Retrofit Technology and RP evaluations in support of the Regional Haze Rule with CAMx. For the 2nd planning period, photochemical modeling has gained favor and is recommended by EPA because of its superior consideration of chemical reactivity as well as other options. We are also versed in the use of SCICHEM and CMAQ.  Download Presentation PDF - Use Of Camx In Evaluating Impacts For The Regional Haze Rule -- 2017 Related articles for more information: Four-Factor Source Analysis: Guidance on Regional Haze SIPs for the Second Implementation Period -- Oct 17, 2019 Utah Finishes 1st Planning Period SIP and Prepares for 2nd Planning Period -- Jul 25, 2019 Will You Be Targeted for the Regional Haze Second Planning Period? -- May 09, 2019 Power Targets for the Regional Haze Second Planning Period  -- Apr 30, 2019 Oil and Gas Potential Targets for the Regional Haze Second Planning Period -- Apr 30, 2019 Regional Haze Rule Second Planning Period -- Apr 19, 2019 Iowa - Regional Haze and Prong 4 SIP Revisions -- Apr 24, 2019 Montana - Montana CAAAC Meeting Updates -- Feb 27, 2019 Oklahoma - Strategy for the Regional Haze Rule 2nd Planning Period -- Feb 19, 2019 Alabama - Proposed Rule: Air Plan Approval; Regional Haze Progress Report -- Jan 08, 2019 Arizona - Regional Haze Updates -- Nov 02, 2018 On-Demand Webinar: Complimentary Webinar - Regional Haze 2nd Planning Period - General Overview Regional Haze 2nd Planning Period in the WRAP Region - Part 1: General Overview Complimentary Webinar - In Association with Alpine Geophysics - Regional Haze 2nd Planning Period in the WRAP Region - Part 2 State Specific Updates ad Q&A

 

Texas Air Quality Permits by Rule (PBR)

Attend For Free! Texas Permits by Rule (PBR) Primer Webinar Jun 18, 2019 10:00 - 11:30 AM CST/CDT Register now Use promo code: FREETXPBR Texas Permits by Rule Overview As part of the Clean Air Act, Permits by Rule (PBRs) are a type of authorization required for new sources, the addition of a facility, or due to a change in source operations.  PBRs have associated technical requirements such as emissions quantification, control technology evaluations, air quality analyses (including regulatory dispersion modeling), emission standards applicability, and compliance assurance.   Some Common PBRs: Boilers, Heaters, and Other Combustion Devices Soldering, Brazing, Welding Facilities (General PBRs 106.261 and 262) Routine Maintenance, Startup and Shutdown of Facilities, and Temporary Maintenance Facilities Surface Coating Facilities Liquid Storage Tanks and Loading Portable and Emergency Engines and Turbines Stationary Engines and Turbines PBRs for Oil & Gas Industry Trinity Consultants can assist with all types of air permitting, including PBRs. Although PBRs are a streamlined approach to permitting, applying them correctly can be challenging. We have completed thousands of   permitting projects and our experience translates into accurate, timely permit applications that are strategically crafted for maximum flexibility, and expert negotiations with regulatory agencies, in turn streamlining the permitting process.