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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.