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Air Quality Permitting and Compliance Support


Air Dispersion Modeling

What is Air Dispersion Modeling? Air Dispersion Modeling allows us to create a simulation of how atmospheric processes disperse pollutants in the ambient atmosphere using mathematical formulations to provide quantitative air concentration and surface deposition data. Trinity Consulting Services: 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. Trinity Consultants can assist you with the following: 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), and long range screening models such as CALPUFF and SCICHEM 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 AERMOD and 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.)   Specific 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 Class I area PSD impact and regional haze analyses Photochemical Grid Modeling Multi-pathway risk assessment dispersion modeling High performance computing solutions Model development and training   Trinity Can Help - Contact Us Today 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. 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

What is Air Permitting? In order to carry out the goals of the Clean Air Act, a number of permitting programs have been established and are implemented by EPA through its Regional Offices or, in most cases, carried out by states, local agencies, and approved tribes. Trinity Air Quality: Air Permitting 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 strategically crafted for maximum flexibility and expert negotiations with regulatory agencies, streamlining the permitting process. The following client services will be provided as needed: 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 What are the different types of air permits and who is required to obtain them? New Source Review (NSR) Permits What does a NSR permit do? Protects air quality when sources like the following are newly built or modified: FactoriesIndustrialboilersPower plants Assures the following take place: New/modified industrial sources are as clean as possibleAdvances in pollution control grow simultaneously with industrial expansion Who is required to obtain a permit? When sources of air emissions at a facility are built or modified, there are potentially 3 types of NSR permitting requirements (a facility may have to meet one or more of these requirements) Prevention of Significant Deterioration (PSD) Permits Required for new major sources or major sources making a major modification in areas that meet the National Ambient Air Quality Standards (NAAQS)Nonattainment NSR (NNSR) Permits Required for new major sources or major sources making a major modification in areas that don't meet the NAAQSMinor Source Permits For pollutants from stationary sources that don't require PSD or NNSR permits. Title V Operating Permits What does a Title V Operating Permit do? Legally enforceable documents designed to improve compliance by clarifying what facilities must do to control air pollution. Who is required to obtain a permit? Any major source that has actual or potential emissions at or above the major source threshold for any air pollutant Any source with a PSD permit or NNSR permit Affected sources under the Acid Rain rules Solid Waste Incineration Units under Section 129 of the Clean Air Act Certain non-major sources subject to NSPS/NESHAP/MACT/GACT requirements *Facilities must certify their compliance with permit requirements at least annually Tribal Permits Outer Continental Shelf Permits

 

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

Trinity Air Quality: Cap-and-Trade Trinity's multi-disciplined staff provides the highest quality cap-and-trade (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. We offer 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 What is the Cap-and-Trade Program? Cap - The government puts a limit, or “cap”, on the amount of Greenhouse Gas Emissions (GHG) facilities can produce in a given year. Companies are given a certain number of allowances that dictate the amount of emissions they're able to expose to the environment for the given year. The cap gets stricter every year. Trade - Facilities are able to buy and sell their allowances depending on what's necessary. For example, if a company has made mechanical updates that has reduced their GHG emissions, they may not need all of their allowances. They can then sell the unused allowances to companies who need them. Who is subject to the Cap-and-Trade Program? California Cap and Trade - If you are an owner or operator of a large electric power plant, large industrial power plant, or fuel distributor in the state of California the C&T rule applies to you. Regional Greenhouse Gas Initiative - If you are in the Power Industry, and are located in one of the below states, you are subject to the Regional Greenhouse Gas Initiative and must comply with established CO2 emissions limits. Connecticut Delaware Main Maryland Massachusetts New Hampshire New Jersey New York Rhode Island Vermont 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 Can Help - Contact Us Today! 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 call us at (800) 229-6655 or contact us online.

 

Emissions Monitoring Support

Trinity Air Quality: Emissions Monitoring Support Trinity Consultants assists facilities with air quality permitting and compliance including Continuous Emissions Monitoring Systems (CEMS) related services. Trinity's experienced professionals have the expertise to help you ensure a CEMS program that meets your legal obligations and streamlines associated processes. When you work with Trinity for Emissions Monitoring Support, you can expect the following: CEMS program audits Customized training Development or review of existing Parts 60 and 75 Quality Assurance Plans (QAP) Associated permitting Assistance in creating or updating facility maintenance programs Best practice recommendations to ensure maximum CEMS data availability and the safe, efficient use of facility resources Quarterly electronic data reports (EDR ) and semi-annual reporting assistance CEMS equipment selection and operational assessment What is Emissions Monitoring? There are two types of emissions monitoring. Though there are two different approaches, there is some overlap. Continuous Emission Monitoring System (CEMS) - Some facilities require specialized analytical equipment that measures the concentrations and/or emission rates of one or more smokestack pollutants. When a CEMS is present, it is almost always because it is required by the facility's air permit, and the CEMS data is generally used to determine both emission limit compliance and stack output performance. All CEMS data is subject to the review of your regulatory agency and can trigger enforcement action where applicable. Although there are certain costs and difficulties associated with these types of systems, they are installed for the purposes of pollutant measurement and additional quantification for state and federal emissions reporting. Periodic Stack Testing - Occasionally, facilities contract with a specialized testing firm to come to the facility and take similar measurements on more of a snap-shot basis, usually for just a few hours. Some of the measurement methods are almost identical to the CEMS equipment, providing instant results on a minute-by-minute basis; other methods provide one number for an hour or two of sampling. For many methods, samples must be sent to a lab for analysis and results are received weeks later. Stack testing can be done on an unofficial basis (an “engineering test”) or an official basis, the point of which is to determine if the facility is meeting its emission limits. At that point, it is a compliance test, and it is performed under the oversight of the regulator. Who Needs Emissions Monitoring Support? If you are an owner or operator of a facility that needs one of the following, Trinity Consultants can help. CEMS auditing & compliance Ensuring quality control CEMS operational training CEMS certification and QA/QC plan development Facilitating reporting CEMS installation project planning and oversight Contact Trinity Today Whatever your CEMS-related challenges may be, Trinity can partner with you to ensure an appropriate, stream-lined program that meets your regulatory compliance obligations. For assistance, contact Steve Argabright at 972-661-8100 or sargabright@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.

 

Health Risk Assessments

Air Toxics There are numerous local, state, and federal environmental, health and safety (EHS) regulations which regulate airborne toxic releases from industrial operations and other sources. Trinity has assisted industrial clients across the United States with various air toxic projects, including emission inventories, Air Toxics Inventory Reports (ATIRs), Health Risk Assessments (HRAs), and Risk Reduction Plans (RRPs). In addition, Trinity has conducted numerous air dispersion modeling studies, population exposure assessments, health risk characterizations, ambient monitoring and related air toxics work, which specifically include:  Preparing ATIRs using the California Air Resources Board's (CARB's) HARP 2.0 / Emissions Inventory Module (EIM) format Preparing HRAs using the CARB's HARP 2.0 / Air Dispersion Modeling and Risk Tool (ADMRT) software Preparing multi-pathway HRAs in accordance with the U.S. EPA's Human Health Risk Assessment Protocol for Hazardous Waste Combustion Facilities (HHRAP) Dispersion modeling with U.S. EPA air quality model AERMOD Reporting of Air Toxics Emissions Inventories consistent with California Air District specific regulations Preparation of Toxic Emission Inventory Plans and Reports (TEIP/TEIR) for various California Air Districts Compliance with South Coast (CA)Air Quality Management District (SCAQMD)'s Guidelines for Participating in the Rule 1402 Voluntary Risk Reduction Program Submission meeting the CARB Emission Inventory Criteria and Guidelines Emission estimation techniques using emission factors, source test data, and other methods of emission quantification used to estimate air toxics emissions Preparation of public notification packages and participation in public notification meetings for facilities with elevated risk levels Why are Health Risk Assessments (HRAs) required? Many air pollution and other EHS regulations specify human health risk standards for stationary source permitting, community protection, and accidental release planning. These include California Proposition 65, U.S. EPA Maximum Achievable Control Technology (MACT) standards, California Environmental Quality Act (CEQA), environmental justice, and other regulatory programs. HRAs are required to determine the extent of health risk impacts from existing and new industrial operations which emit Hazardous Air Pollutants (HAPs) and other air toxics. Exposure to air toxics can result in carcinogenic, acute and/or other chronic health effects. Humans can be exposed to toxics either directly, through inhalation, or indirectly, through ingestion or dermal contact. The magnitude of the risk varies as a function of the characteristics of the substance, duration and frequency of the exposure, meteorological conditions, geographical characteristics of the surrounding area, the emission characteristics of the facility, and the age of the individuals exposed.  Software Modeling Expertise Trinity's staff has intimate working knowledge of numerous air dispersion modeling and health risk assessment tools, including BREEZE Risk Analyst, California's Hot Spots and Assessment Program (HARP) model, AERMOD, AERMET, HARP 2.0, CALPUFF, and CalEEMod. Our clientele spans multiple industrial sectors which reflects the diverse industrial base of major source facilities including cement plants, incinerators, power generation, aerospace, electronics, chemical plants, biomedical, oil & gas, transportation, marine, light manufacturing, agricultural processors, and numerous others. ArcGIS based-BREEZE Risk Analyst is designed to perform human health assessment modeling. It incorporates equations provided in the HHRAP and is well refined in its selection and use of coordinate systems, data handling, calculations, and management of georeferenced data systems. This highly flexible GIS-based analysis platform seamlessly combines the necessary tools, databases, GIS functionality, and modeling equations into one easy-to-use package that is designed to support the evolving requirements and challenges of today's health assessment applications. Trinity Can Help - Contact Us Trinity's extensive expertise in air quality related issues and understanding of the applicable air toxic regulations and HRAs, including California AB 2588, other California air district health risk guidelines and relevant rules, National Emission Standards for Hazardous Air Pollutants (NESHAPs), and Office of Environmental Health Hazard Assessment (OEHHA) Health Risk Assessment Guidelines.  For assistance with health risk assessments, Trinity offers unmatched expertise and service quality. Call Trinity at +1 (800) 229-6655 or Contact Us online. Related Articles Combined Use of AERMOD, ArcGIS, and Risk Analyst for Human Health Risk Assessment -- Apr 13, 2016 Related Training Free Webinar - Managing HAPs in Air Permits: A Challenging New Reality in New Jersey

 

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.    Do You Need LDAR Support? 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   How Trinity Can Help Trinity's LDAR team 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 and NSPS Compliance

Trinity Air Quality: NSPS and NESHAP Compliance Services Working in concert with your company's environmental department and other stakeholders in the compliance management process, Trinity Consultants can assist with all aspects of the New Source Performance Standard (NSPS) and National Emissions Standards for Hazardous Air Pollutants (NESHAP) compliance program development and implementation. From the earliest project planning stages to the advanced stage of maintaining well established compliance NSPS/NESHAP programs, Trinity can provide compliance program documents, guidance, and recommendations. Trinity's experience extends across a wide array of technical and regulatory issues pertaining to NSPS/NESHAP. Trinity monitors the ongoing development and promulgation of new and revised NSPS and NESHAP rules and works with clients and industry trade groups to actively participate in the rulemaking process. Learn more about our full range of NSPS and NESHAP compliance services by regulatory program at the relevant links below: NSPS Compliance Support Part 61 NESHAP Compliance Support Part 63 NESHAP Compliance Support What are NSPS and NESHAP Programs New Source Performance Standards (NSPS) ( 40 CFR 60) and National Emissions Standards for Hazardous Air Pollutants (NESHAP) ( 40 CFR 61 & 63) are the two major federal air regulatory programs applicable to industrial facilities in the U.S. NSPS Program - First established in 1971 and now expanded to include more than 100 individual subparts, NSPS apply to an affected facility constructed, reconstructed, or modified after a classification date. Affected facilities are designated by industrial category (e.g., petroleum refineries) or source type (e.g., boilers, storage tanks, engines, etc.). In accordance with Section 111(a)(1) of the Clean Air Act (CAA), NSPS establish emissions standards based on the “best system of emissions reduction (BSER)” that has been adequately demonstrated taking into account costs, non-air quality environmental impacts, and energy requirements.Every eight years, the U.S. Environmental Protection Agency (EPA) is required to review and revise where appropriate each NSPS subpart to ensure the standards continue to meet BSER. NESHAP Program - The NESHAP program covers pollutant-specific regulations derived from Section 112 of the 1970 Clean Air Act Amendments (CAAA) found in 40 CFR 61 and the industry or source category-specific standards derived from the 1990 CAAA found in 40 CFR 63. NESHAPs apply to both new and existing sources meeting the specified applicability criteria in the regulations: Part 61 NESHAPs establish risk-based emissions standards for eight designated hazardous air pollutants (asbestos, benzene, beryllium, coke oven emissions, inorganic arsenic, mercury, radionuclides, and vinyl chloride).Part 63 NESHAPs establish risk-based and technology-based emissions standards for a discrete list of source categories initially established in response to the 1990 CAAA. The initial list has been periodically updated resulting in more than 125 individual Part 63 subparts applicable to major and some area (a.k.a., minor) sources of HAP.Technology-based emissions standards under Part 63 NESHAPs implement Maximum Achievable Control Technology (MACT) for major sources and Generally Available Control Technology (GACT) for area sources.A residual risk and technology review (RTR) is required to be conducted within eight years of setting the MACT standards, and subsequent Part 63 NESHAP regulation reviews are required every eight years thereafter to account for improvements in air pollution controls and/or prevention. Who Needs NESHAP and NSPS Compliance Support If you are an owner or operator of a stationary source with an affected facility under NSPS or NESHAP regulations, you are obligated to follow all applicable requirements irrespective of whether these requirements are noted as specific terms and conditions in your facility's air permit. Initially establishing and maintaining ongoing compliance under NSPS and NESHAP regulations is a complex and constantly evolving process. Changes in technology, regulatory updates, and shifting U.S. EPA and state/local agency policy and guidance may prompt a need for NSPS/NESHAP compliance support services. For more details on whether your facilities are affected under NSPS or NESHAP regulations, please review our NSPS Compliance Support page, Part 61 NESHAP Compliance Support page and/or Part 63 NESHAP Compliance Support page.

 

NSPS Compliance Support

The majority of industrial operations in the U.S. operate sources affected by one or more New Source Performance Standard (NSPS ) subparts. Determining applicability of NSPS requirements to your facility's operation sets the stage for all future compliance activities. After the framework of applicability is established, facilities must then demonstrate compliance with the applicable NSPS emissions standards, control requirements, and work practice standards by satisfying the appropriate testing, monitoring, recordkeeping, and reporting obligations. Trinity can help you navigate these requirements by offering a full range of NSPS compliance support services: NSPS Applicability Determination - Does NSPS apply? Get the right answer the first time. Trinity has extensive experience interpreting relevant NSPS source category-specific and general provision definitions that guide the process of determining whether an NSPS affected source is constructed, reconstructed, or modified.Through our Knowledge Management System (KMS), Trinity maintains a library of proposed and final NSPS regulations, rule preambles, U.S. EPA applicability determinations/guidance documents, background information/technical support documents, and relevant court cases.Trinity uses our NSPS program skills, experience, and resources to provide well documented, technically justified, and regulatorily supported NSPS applicability determinations. NSPS Initial Compliance Notifications - You've triggered NSPS, now what?NSPS requires initial notifications for start of construction/reconstruction, initial startup, modification, performance testing, and continuous monitoring system certification.On behalf of our clients, Trinity prepares and submits NSPS notifications that meet the applicable requirements, satisfy regulatory deadlines, and set the stage for future NSPS compliance program success. NSPS Initial Compliance Demonstrations - Does my source meet the NSPS limits?NSPS commonly require an initial inspection, performance test, continuous monitoring system certification, design analysis, or some other type of assessment to verify that the new/modified/reconstructed source can meet the applicable emissions standards.Trinity has successfully identified NSPS compliance solutions across a wide range of industries that are cost effective, streamlined, and innovative but simultaneously conform to all applicable requirements. Trinity works seamlessly with your staff and external stakeholders (continuous monitoring system vendors, equipment suppliers, and source sampling providers, etc.) to develop robust NSPS compliance strategies.Trinity develops and provides implementation assistance for initial compliance demonstration programs involving all of the common types of compliance assessments including stack testing, continuous emissions monitoring system (CEMS) certification, process equipment/control device inspections, and engineering design evaluations. NSPS Ongoing Compliance Monitoring - What is the best option for my source?Installing, operating, calibrating, and maintaining parametric or emissions monitoring systems for ongoing demonstration of compliance with NSPS standards can represent a significant equipment/operating cost and labor resource load for affected facilities.Trinity understands the regulatory options and engineering fundamentals to help your facility choose the optimum NSPS compliance monitoring system. NSPS Recordkeeping - What records must be kept?Satisfying all applicable NSPS recordkeeping requirements related to testing, monitoring, and inspections can generate mountains of data even for a single affected source.Trinity has developed NSPS-focused recordkeeping systems ranging from simple, hand-written forms and checklists applicable to a single affected source to enterprise-wide Environmental Information Management Systems (EMIS) using customized software tools and applications across multiple sites.Trinity creates custom recordkeeping solutions to centrally log and summarize NSPS compliance data that are best suited to your facility's unique needs without magnifying your environmental compliance burden. NSPS Reporting - Submit my reports to who/when/where?Stack test reports, CEMS initial certification/quality assurance reports, and excess emissions and monitoring systems performance reports are among the most commonly submitted NSPS reports.U.S. EPA is continuing to expand the use of electronic reporting under the NSPS program through the deployment of its Compliance and Emissions Data Reporting Interface (CEDRI) hosted on the Central Data Exchange (CDX). However, many state/local agencies are not yet equipped to use CEDRI submittals for satisfying their own state/local-level reporting requirements which can create a parallel set of NSPS reporting obligations.For sites across the U.S., Trinity prepares NSPS reports to satisfy federal/state/local requirements using the appropriate agency contacts and implementing the correct electronic and/or paper-based submittal systems. With more than four decades of experience in air regulations and permitting, Trinity can be of great value in helping you interpret U.S. EPA's NSPS rulemaking information and determine effective NSPS compliance solutions for your operations. For assistance, contact Trinity at (800) 229-6655.

 

Part 61 NESHAP Compliance Support

What is the Part 61 NESHAP Regulation? Through the Clean Air Act Amendments (CAAA) of 1970, Congress required U.S. EPA to publish a list of hazardous air pollutants (HAP) and to subsequently establish emissions standards for these listed HAP. In response to this directive, U.S. EPA listed eight Hazardous Air Pollutants (HAP) between 1971 and 1984 in 40 CFR 61.01(a) including the following compounds: Asbestos (36 FR 5931; Mar. 31, 1971) Benzene (42 FR 29332; June 8, 1977) Beryllium (36 FR 5931; Mar. 31, 1971) Coke Oven Emissions (49 FR 36560; Sept. 18, 1984) Inorganic Arsenic (45 FR 37886; June 5, 1980) Mercury (36 FR 5931; Mar. 31, 1971) Radionuclides (44 FR 76738; Dec. 27, 1979) Vinyl Chloride (40 FR 59532; Dec. 24, 1975) Between 1971 and 1990, EPA published 23 pollutant-specific National Emissions Standards for Hazardous Air Pollutants (NESHAP) in 40 CFR Part 61 (i.e., Part 61 NESHAP) addressing each of the eight identified HAP. Part 61 NESHAP regulate HAP based on listed activities and emissions source types as opposed to by industrial source category (like the more widely applicable Part 63 NESHAP). Each Part 61 NESHAP set human health risk-based emissions standards which, in the judgement of the EPA Administrator, provides an ample margin of safety to protect public health from the listed HAP. How Trinity Can Help - Contact Us Today! Trinity has broad experience developing and implementing compliance programs for the most commonly applicable Part 61 NESHAP regulations, primarily including those regulating asbestos (Subpart M), benzene (Subparts J, Y, BB, and FF), coke oven emissions (Subpart L), and vinyl chloride (Subpart F). Building from our experience with the Part 61 NESHAP program since the inception of these long-standing requirements, Trinity understands the applicability criteria, common control/emissions minimization strategies, and best practices for meeting testing, monitoring, recordkeeping, and reporting requirements. For assistance, contact Trinity at (800) 229-6655.

 

Part 63 NESHAP Compliance Support

Don't get lost in the “alphabet soup” of Part 63 NESHAP Subparts A to ******* (up to 7 letters with 125 subparts and counting)!   With the 1990 amendments to the Clean Air Act (CAA), EPA mandated significant new air quality programs including an expanded list of 189 hazardous air pollutants (HAP) [Section 112(b)] and a list of source categories for which new NESHAP regulations for both major and area sources of HAP must be developed [Section 112(c) and (d)]1. Emissions standards for major sources are established on the basis of Maximum Achievable Control Technology (MACT) with differing requirements for new and existing sources. A less stringent emissions standard basis, known as Generally Available Control Technology (GACT) standards, is allowed for area sources. The Part 63 NESHAP designated source categories typically represent an industrial source classification (e.g., Synthetic Organic Chemical Manufacturing Industry in Subparts F, G, and H) but can also represent an emission source type (e.g., Industrial, Commercial, and Institutional Boilers and Process Heaters in Subpart DDDDD or “Boiler MACT”). After the initial round of technology-based emissions standards are established, EPA is required to perform an additional round of NESHAP rulemaking to assess any remaining risk to public health. If "residual risk" (determined through an air dispersion modeling-based human health risk assessment) for a source category is found, EPA issues revised health-based emissions standards for that source category to further reduce HAP emissions. Every eight years thereafter, EPA must revisit the NESHAP standard to determine if any developments in technology or human health risk require updates to the regulations. Prompted by the plain writing initiative for all U.S. government agencies, EPA organizes Part 63 NESHAP following a question and answer (Q&A) format intended to be more approachable for the public. While this format may represent an improvement to previous regulatory schemes, Part 63 NESHAP require specialized experience and skills to decrypt EPA's not so plain language intended for a “layman.” Whether your facility has triggered a Part 63 NESHAP for the first time or you have been complying with the same regulation since the 1990's, Trinity has you covered with a full range of NESHAP compliance support services.   Am I subject to this subpart? - NESHAP Applicability Determination SupportDetermining the boundaries of the NESHAP affected source at your facility is not always straightforward and can require interpretations of process details, regulatory definitions, and industry precedent. Trinity maintains an extensive library of technical and regulatory resources to ensure your affected source determinations take full advantage of all possible exemptions and alternative means of compliance. Empowered with the right applicability determinations supplied by Trinity, you can be sure the costs and resources for your Part 63 NESHAP compliance program are being spent wisely and consistent with the regulations.What limitations/work practice standards must I meet? - NESHAP Program Development SupportPart 63 NESHAPs often contain multiple compliance options with differing emissions standards, operating limits, and work practice standards. Choosing the right option for your source can minimize future compliance risk and minimize the costs/labor resources for demonstrating compliance. Trinity understands the advantages and disadvantages of many NESHAP compliance approaches and can provide strategic guidance for your site in choosing the best option.What are my initial/ongoing compliance requirements? - NESHAP Program Implementation SupportDemonstrating initial compliance under the Part 63 NESHAP regulations often involves the preparation and submittal of a comprehensive Notice of Compliance Status Report (NOCSR) demonstrating that your source not only can comply with the applicable emissions standards but also has met all of the associated testing, monitoring, recordkeeping, and reporting requirements along the path of initial compliance. Since the inception of the Part 63 NESHAP program, Trinity has developed hundreds of NOCSRs across many NESHAP source categories, so we are uniquely positioned to support your facility in preparing high quality initial compliance reports.Demonstrating ongoing compliance under the Part 63 NESHAP covers a wide range of monitoring activities from the most stringent continuous emissions monitoring systems (CEMS) and continuous parametric monitoring systems (CPMS) to the least stringent annual (or less frequent) visual inspections. Trinity knows the engineering fundamentals, practical applications, and regulatory implications of many common emissions or parametric monitoring systems that can be leveraged for your facility . Trinity can also develop inspection programs that satisfy all regulatory requirements and are built on solid personnel workflows and documentation platforms. Work with Trinity to develop and implement a successful NESHAP compliance monitoring program, including the appropriate regulatory plans and documentation, that maximizes the opportunity for consistent and sustainable compliance.What records must I keep? What notifications/reports must I submit and when? - NESHAP Recordkeeping and Reporting System SupportTimely, well-organized, and clearly documented records are the cornerstone of any NESHAP compliance program. Whether your facility relies on paper forms, user-entered electronic databases, or mobile/cloud-enabled solutions, Trinity can help enhance and streamline your NESHAP recordkeeping systems to ensure optimum performance.Periodic NESHAP reports can span volumes of regulatory citations, compliance statements, and supporting documentation. Responsible parties for preparing or contributing to these reports must initiate work weeks in advance of the regulatory deadline and still experience “crunch time” right up to the due date. Partnering with Trinity on a NESHAP reporting project will remove a significant resource burden on your staff and instill confidence that regulatory requirements are being met.With more than four decades of experience in air regulations and permitting, Trinity can be of great value in helping you interpret EPA's Part 63 NESHAP rulemaking information and determine effective Part 63 NESHAP compliance solutions for your operations. For assistance, contact Trinity at (800) 229-6655.1Major sources of HAP are those with source-wide annual potential emissions exceeding 10 tons per year (tpy) of an individual HAP or 25 tpy of total HAP. An area source is a facility with HAP emissions below the major source threshold (also referred to as a minor source under other air programs).

 

Photochemical Grid Modeling

Trinity Consulting Services: Photochemical Grid Modeling Trinity provides comprehensive modeling support for both Photochemical Grid Modeling (PGM) and regional air quality studies to organizations in the U.S. and internationally. The expertise of our modeling team includes: 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) including post-processing through EPA's Mesoscale Model Interface (MMIF) 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 What is Photochemical Grid Modeling? Photochemical grid modeling is the most effective way to run experiments that test different strategies for controlling air pollution on a regional scale or for photochemically reactive pollutants. Different models are used to simulate and predict pollutant concentrations within various control scenarios. Who Needs Photochemical Grid Modeling Services? PGM services can benefit facilities in various industries. If your facility emits a photochemically reactive pollutant, such as a precursor to ozone or fine particulate matter (PM2.5) and is being considered in control strategies to reduce ambient concentrations, PGM may be required for this assessment. PGM is also being increasingly used in regional haze assessments that are required by the Clean Air Act to provide for continuing visibility and air quality improvements in National Parks and other protected Class I areas. Trinity Can Help - Contact Us Today Our experience is multi-faceted and extensive. Our strategies are innovative, time saving, and cost-effective. Our staff and tools are second to none, embodying our company's principle in every way to provide environmental solutions delivered uncommonly well. Contact us online or via phone at (800) 229-6655 for a consult with one of our local modeling experts.

 

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

Comprehensive Visibility Protection Program for Class 1 Areas Trinity Consultants worked extensively with clients during the first Regional Haze planning period (2004-2018), which included Best Available Retrofit Technology (BART) and Reasonable Progress (RP) analyses, litigation support across the U.S., and numerous strategy discussions and negotiations with states, EPA and Federal Land Managers. From this experience, we recommend industrial sites be involved in the stakeholder process for the second and future planning periods (2019-2028, 2029-2038, and so on), and ensure the performance of the following steps. Trinity can provide guidance for your site(s) through this process: Analyze Interagency Monitoring of Protected Visual Environments (IMPROVE) data by species to determine impact per species on Class 1 Area Compare actual visibility impairment as measured for a Class 1 Area to the Uniform Rate of Progress (URP) or "glidepath" 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 areas managed by Regional Planning Organizations (RPOs) and in 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 advise on recent EPA guidance on issues such as 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. What is the Regional Haze Rule? 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. On August 20, 2019, EPA published a final memorandum for Guidance on Regional Haze State Implementation Plans for the Second Implementation Period. This guidance provides additional insight for states as they select sources to evaluate for potential additional control based on the four statutory factors listed in 40 CFR 51.308(f)(2)(i): cost of compliance, time necessary for compliance, energy and non-air environmental impacts, and remaining useful life of the source. Additional factors, including the visibility benefits of controls, may also be considered in these evaluations. Learn more about the Four Statutory Factors versus Five Considerations here Important Dates: 2nd Planning Period Overview July 31, 2021 - SIPs are due 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 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 > Software Expertise for Regional Haze Trinity has performed regional haze analyses for Best Available Retrofit Technology (BART) and Reasonable Progress (RP) evaluations in support of the Regional Haze Rule with the CAMx photochemical model. 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 the SCICHEM and CMAQ models.  Download Presentation PDF - Use Of Camx In Evaluating Impacts For The Regional Haze Rule -- 2017 Trinity Can Help - Contact Us Today Is 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. Related resources: Download presentation PDF - Regional Haze for the Rest of the United States - Building off WRAP Analyses Related articles for more information: Oregon - Oregon DEQ has Published Significant Sources for Regional Haze Planning -- Jan 24, 2020 Four-Factor Source Analysis: Guidance on Regional Haze SIPs for the Second Implementation Period -- Oct 17, 2019 Utah - 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)

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.