- Salt Lake City, UT
- Corpus Christi, TX
- Columbia, SC
- Reno, NV
- Charleston, SC
For more than 20 years, Trinity Consultants has assisted facilities in the aerospace industry with regulatory compliance and environmental management issues.
Trinity has a long history of assisting facilities with their regulatory compliance and environmental management systems.
Trinity helps chemical and pharmaceutical manufacturers to achieve regulatory and environmental compliance.
Trinity has assisted clients with nearly 500 power-related projects, offering an array of services.
Due to their nature, “general manufacturing” facilities are often faced with reviewing a wide range of regulations to determine applicability.
Trinity provides a variety of services to government entities, including environmental permitting and compliance management.
Trinity Consultants has long been committed to assisting lime and aggregates facilities with their regulatory compliance needs.
Trinity takes pride in understanding the regulatory issues affecting our clients’ facilities and their industry.
Oil and gas facilities must contend with a variety of regulatory compliance and environmental management demands.
Trinity helps petroleum refineries to achieve compliance with complex environmental regulatory requirements.
Trinity Consultants has long been committed to assisting cement facilities with their regulatory compliance and environmental management needs.
Trinity has extensive experience assisting the pulp and paper industry with its regulatory compliance and environmental management requirements.
Railroads are faced with rapidly evolving state, regional, and federal regulatory framework in the United States.
For more than 25 years, Trinity Consultants has assisted facilities in the semiconductor industry.
Trinity Consultants has performed nearly 800 environmental permitting and compliance projects for clients with terminal operations, providing cost-effective, timely solutions that enhance compliance while maintaining operational flexibility.
For nearly 30 years, Trinity Consultants has assisted facilities such as those in the highly regulated wood products industry.
State and local air quality agencies are currently assembling information that will allow them to build their triennial minor source emission inventory for 2017. Agencies are required to report these inventories to U.S. EPA every three years. The »
Permitting requirements for nonroad engines in the state of New Mexico vary based on the agency authorizing your Air Quality Permit. The two agencies that will be discussed within this article include the New Mexico Environment Department (NMED) and »
Trinity Consultants announces that it recently opened an office in Birmingham, Alabama with a team of experienced Trinity leaders including Managing Consultant Chris Pool and Senior Consultants Jeremiah Redman and Katie Brubaker. While this marks »
Stakeholders are influencing how businesses operate more than ever before, in part by exerting increased pressure to disclose environmental, social, and governance (ESG) information. This is being achieved through reporting standards like the Global »
Leak Detection and Repair (LDAR) involves finding facility components that are leaking and fixing them. The U.S. Environmental Protection Agency (EPA) has a long history of regulating industries (such as petroleum refining and chemical »
Trinity's Environmental Quarterly (EQ) magazine covers environmental regulatory developments as well as topics related to corporate environmental performance.
all issues from 2009
These papers, presentations, and articles were authored by the staff of Trinity Consultants for presentation at various conferences.
all papers & presentations
Since its founding in 1974, Trinity has expanded its geographic footprint and breadth of services. We attribute our continued growth to a focus on cornerstone values of top-notch technical performance and excellence in client service.
The management of any facility requires a watchful eye to ensure regulations and procedures are followed and the intent of management is met. By conducting audits, companies can be assured that prescribed environmental and safety procedures are properly performed. It is an approach that makes good business sense. The lack of proper oversight can adversely impact not only local communities but also the health and well-being of employees. Regulatory fines, increased costs, a poor reputation, and low employee morale can result. Prevention — Trinity can help you evaluate environmental and safety systems to find issues before they become problems. With our extensive auditing resources, skills, and experience, we will help you maintain and improve compliance management systems so your company can achieve economic, employee, and community success. Staffing — Increased regulations for monitoring, recordkeeping, and reporting make it difficult to ensure proper oversight of operations, especially if an Environmental Health & Safety department is operating with minimal resources. Trinity’s professional staff provides the additional resources needed to perform EHS audits. We provide objective assessments of your compliance status, recommend changes to correct problems, and provide guidance on correcting the system to ensure improved performance in the future. The Process Approach — The most effective method of auditing a management system is to employ the Process Approach. It is a key to examining systems such as ISO 14001, RC 14001, OHSAS 18001, and EPA’s Performance Track Program. Following the Process Approach, we analyze the actions that precede each operation and the actions that follow. We determine which inputs are necessary for proper completion and which outputs are necessary for the next step to be successful. Originally applied to quality in manufacturing, the Process Approach is fundamental in evaluating environmental and safety performance. Examples of Our Work Rapid, multi-site deployment - A client company requested Trinity’s support regarding its potential acquisition of assets used to generate electricity and transport and store fuel. Because several of the assets were located in environmentally restrictive locations, the client needed a quantitative valuation of existing and future environmental obligations. Trinity used a rapid due diligence deployment of resources and played a vital role in the client’s overall bid package. To meet the tight time frame, we mobilized multiple teams to perform research, conduct site visits, and assess the environmental obligations. Management system selection and implementation - A multi-national building materials company engaged Trinity to assist in the creation, documentation, and implementation of an EHS management system. The project began with an evaluation of various models, including ISO 14001, RC 14001, and OHSAS 18001. After a model was selected, Trinity performed a gap analysis to compare current processes with the selected approach. Then we designed and implemented a pilot site and toolkit that was used for implementation at 50 company sites. Trinity provides three major kinds of EH&S Auditing: Regulatory Compliance Auditing Auditing systems to evaluate compliance with regulations is especially important because of potential liability issues. Trinity develops a protocol for compliance audits and assesses site performance related to EPA and OSHA regulations, including state and local requirements. Corporate EH&S Audits Audits are structured to assess a company’s performance against its own internal standards. These audits often exceed regulatory requirements and encompass industry best practices. Trinity can either develop a protocol or use an existing corporate protocol. In addition, audits can be performed by a Trinity team or a team that combines Trinity and client personnel. Management Systems Assessments Trinity’s auditing professionals evaluate an organization’s conformance with standards such as ISO 14001, RC 14001, OHSAS 18001, and other EHS management systems. The process includes elements such as the following: Gap analysis — A gap analysis compares an organization’s existing system with the requirements of an EHS standard in order to identify areas of nonconformance, or gaps. The work plan that results is a roadmap for implementation. Pre-registration readiness audits — A readiness assessment helps assure that all systems are implemented and that there is sufficient evidence available to move forward with certification. This process increases the likelihood of a successful registration experience, potentially reducing total cost. Additionally, Trinity provides a variety of customized services that include training and on-site assistance during the registration audit. Internal audits — Trinity can audit internal EHS systems to evaluate performance against standard requirements and corporate objectives. When problems are found, we advise on system improvements and maintenance. Enterprise-wide assessments — Trinity supports corporate staff in the unique challenge they face when planning and implementing an enterprise-wide EHS assessment process. This includes developing customized EHS standards, a best-in-class system rollout, communication procedures, and training. We also create implementation toolkits and guidance materials. During a compliance audit, Trinity reviews all relevant data, including applications, permits, plot plans, construction history, emissions calculations, monitoring information, regulatory reports, process flow diagrams, and operational data. We typically visit the site to ensure that all emissions sources have been identified. Our next step is to perform a regulatory applicability analysis to identify all federal, state, and local requirements for each emissions source. Based on this information, we determine unit-by-unit compliance and suggest corrective actions, classifying non-compliance findings based on severity and recommending best management practices. This allows our clients to make informed decisions on how to address compliance issues. The result is a complete picture of all regulatory requirements, a plan to attain and maintain compliance, and a basis for establishing an annual compliance audit plan. Benchmarking Study Trinity recently conducted a benchmarking study on EH&S auditing practices among industrial companies. More than 100 companies responded from a cross-section of industries. Read the Auditing Benchmarking Report to learn about common auditing practices as well as Trinity's recommended best practices. For EHS auditing assistance, contact your local Trinity office at (800) 229-6655.
About California Assembly Bill 32 California’s Global Warming Solutions Act of 2006 (Assembly Bill 32 or AB 32) sets forth an aggressive program to reduce greenhouse gases (GHGs) from nearly every sector of the state’s economy, including manufacturing, electricity, transportation, agriculture, consumer products, and others. The primary objective of AB 32 is to implement emission reduction strategies and programs that reduce GHG emissions to 1990 levels by the year 2020 initially, with additional reductions by the year 2050. Independent Verification Requirement for GHG Reporting Program As part of AB 32, the California Air Resources Board (ARB) promulgated mandatory reporting regulations (MRR) in December 2007 that require entities to calculate and report their GHG emissions for specific industry sectors and for general stationary combustion sources with emissions greater than or equal to 10,000 metric tons (MT) of CO2e per year. In addition, for those facilities with emissions that equal or exceed 25,000 MT-CO2e per year, accredited third-party verification is required (and AB 32 cap-and-trade obligations apply). The independent verification of GHG emissions data by an accredited verification body (VB) is an important element of ARB’s MRR and cap-and-trade regulation to ensure reliable and accurate data. Independent Verification Requirement for Offset Projects Offset projects can be used to generate GHG offset credits, which represent a removal or reduction of GHGs by a measurable, quantifiable, and verifiable activity. All compliance offset projects must be developed according to ARB-approved compliance offset protocols. To be eligible providers of ARB offset credits, offset project operators must register their offset projects with an approved offset project registry. Furthermore, offset projects must be independently verified by an accredited offset verification body, which has the required verification staff who are trained and accredited for the specific type of offset project. Once verified, the offsets generated from the offset project may be sold to AB 32 subject entities, who can use a limited number of offset credits to satisfy up to 8% of their annual compliance obligations under the cap-and-trade program. Partnering with Trinity Consultants Our ARB-accredited offset verification and GHG verification services are performed by experienced environmental professionals with engineering backgrounds, most with advanced degrees and professional certifications. Our multidisciplinary staff provides the highest-quality verification services that enhance regulatory compliance while maximizing operational flexibility. Trinity serves its clients through an unparalleled combination of regulatory expertise, technical proficiency, responsiveness, and creative thinking. In addition, Trinity’s Quality Management System ensures that clients consistently receive high-quality verification services. Trinity’s AB 32 GHG verification team provides the following unique benefits to our clients: Accredited Verification Services for All Sectors: Trinity is an accredited offset and GHG verification body. Our team includes experienced ARB-accredited offset verifiers and GHG verifiers with all four types of sector specific accreditations (i.e., General, Oil and Gas, Process, and Transaction). Proven Track Record: As one of the most active ARB-accredited verification bodies in California, Trinity completes more than 50 verifications annually, with resoundingly positive feedback. Recognized Industry Leader: Trinity is recognized as an industry leader in air quality and climate change issues. In-depth Knowledge: Trinity’s team has extensive experience based on in-depth knowledge of GHG emission inventories and GHG-related regulatory requirements. High Quality Work Products: Trinity’s consulting and verification practices and operations are quality assured for delivery of superior technical products. Relevant Project Experience: Trinity has relevant experience in GHG verifications, GHG management and emission reduction plans, enterprise-wide inventories, and carbon foot-printing exercises for national and international corporations across various industry sectors and locations. Cost Effectiveness: Trinity offers cost-competitive project budgets and works efficiently using in-house checklists, protocols, and other tools developed during extensive GHG emissions verification/inventory projects. Local California Offices: Fully staffed offices with accredited verifiers are strategically located to cover the entire state, including Northern California, Central California, and Southern California. Industry Clients Trinity’s verification team has provided GHG verification services to the following industry sectors: Aerospace Agriculture Cement and lime manufacturing Chemicals production Colleges and universities Crude petroleum and natural gas extraction General manufacturing Metals and minerals mining Natural gas distribution Petroleum refining Power entities (electricity transactions) Power generation Pulp and Paper Related Services In addition to GHG and offset project verification services, Trinity offers a wide variety of other climate change, sustainability, and GHG-related services: ARB and EPA MRR reporting Cap-and-trade forecasting and compliance Cap-and-trade benchmark evaluation and rulemaking support GHG verification in other programs and registries (e.g., CDP, CAR, and VCS) GHG program training GHG emission reduction plans For more information on how Trinity can assist you, please contact: GHG and Offset Verification: Dr. Charles Lee, Principal Consultant - (949) 567-9880 x102 Other GHG-related assistance: Steve Walters, Principal Consultant - (949) 567-9880 x118
The international non-profit organization, CDP (formerly Carbon Disclosure Project) has established the world's largest repository of data on key environmental parameters (particularly carbon and energy) as reported voluntarily by companies and cities. Climate data is collected from over 5,000 companies annually and used for investment decisions by many organizations, including financial information platforms. Thus, it is important that the climate data submitted are accurate and supported by reasonable assumptions. One of CDP's strategic aims is to promote third-party verification as an integral part of the disclosure process to meet the growing demand for reliable and accurate data. Importance of Third-Party Verification Numerous benefits are realized by a reporting entity from an independent verification of CDP climate change and sustainability data and information. Higher CDP response scores Improved stakeholder perceptions Increased data reliability Carbon inventory improvement Trinity's GHG Verification Team consists of environmental professionals with science and engineering backgrounds, most with advanced degrees and professional certifications. Our multi-disciplined staff provides the highest quality verification services that enhance regulatory compliance while maximizing operational flexibility. Trinity helps its clients accomplish this by combining regulatory expertise, technical proficiency, responsiveness, and creative thinking. Trinity's GHG Verification Team provides the following unique benefits to our clients: Subject matter expertise: Trinity is experienced with sustainability scoring assessments and corporate responsibility disclosure programs, including CDP Industry leader recognition: Trinity is recognized as an industry leader in air quality and climate change issues In-depth knowledge: Trinity's team has in-depth knowledge and understanding of GHG emission inventories and GHG-related regulatory requirements Verification accreditation: Trinity is an accredited verification body through the California Air Resource Board (ARB) with team members that have accreditations including the following: Accredited Lead Verifiers, with all three sector specific accreditations (Oil and Gas, Process, and Transaction)ARB accredited Offset Project Lead Verifiers Professional Credentials: Trinity team members have various professional credentials, as well as:Certified Professional EHS Auditors through the Institute of Internal Auditors (IIA)Certified RABQSA (Exemplar Global) Environmental Management Systems Lead AuditorsCertified Practitioners for Energy Management SystemsCertified Energy Auditors High quality product: Trinity's consulting and verification practices and operations follow ISO 9001 standards, ensuring the delivery of high quality technical products Relevant project experiences: Trinity has relevant experience in GHG verifications, GHG management plans, enterprise-wide inventories, and carbon footprinting exercises for national and international corporations across various industry sectors and multiple locations Streamlined process: Trinity works efficiently with in-house checklists, protocols, and other tools developed during prior GHG emissions verification/ inventory projects Proven track record: Trinity's sector leading track record includes the completion of over 100 GHG emission inventory projects and over 50 GHG verification projects annually For any questions regarding the CDP climate data verification services, please contact Dr. Charles Lee, Principal Consultant, at (949) 567-9880 or email@example.com, or Mr. Rich Pandullo, Director, at (919) 462-9693 or firstname.lastname@example.org.
Originally implemented in 2007, the Chemical Facility Anti-Terrorism Standards (CFATS) is a Department of Homeland Security (DHS) regulatory program that addresses security at high-risk chemical facilities. DHS evaluates security risk based on three criteria: Consequence – anticipated result of a successful attack on a facility Vulnerability – likelihood that an attack would be successful Threat – intent and capability of an adversary attacking the facility DHS implements the CFATS program through a risk-tiering methodology for subject facilities. The CFATS program consists of first determining if a facility has chemicals of interest (COIs) that exceed the regulatory thresholds (applicability determination). If subject, the facility must prepare a Top-Screen Analysis (TSA), and potentially a Security Vulnerability Assessment (SVA) and Site Security Plan (SSP). DHS has an Expedited Approval Program to streamline SVAs and SSPs for lower risk facilities and allows facilities to develop Alternative Security Programs (ASP) as long as they meet all the SSP requirements. Trinity assists with CFATS compliance, from applicability determination through DHS Compliance Inspection. Trinity has valuable experience in each critical step of the CFATS program. Conducting Applicability DeterminationsEvaluating facility chemicals for CFATS applicabilityPreparing threshold calculations for chemicals of interestPreparing non-applicability determinations to document the facility’s compliance statusEvaluating alternatives to opt out of the CFATS reporting requirements Performing Top-Screen AnalysesPreparing a TSA using DHS’s Chemical Security Assessment Tool (CSAT)Providing CSAT and Chemical-terrorism Vulnerability Information (CVI) training guidanceEnsuring reporting consistency with other safety and environmental programs (e.g., RMP, PSM, Tier II, Toxic Release Inventory, etc.), including CFATS implications for these other programs Preparing Security Vulnerability Assessments using CSATCharacterizing critical assetsAssessing internal, external, and internally-assisted threatsIdentifying potential security vulnerabilities and existing countermeasuresAssessing risk of an attackAnalyzing countermeasures and evaluating additional measures to lower risk Developing Site Security Plans using CSATAddressing each vulnerability identified in the SVAEvaluating the 18 risk-based performance standards (as applicable) and developing cost-effective strategies for compliance with these standards Preparing for and assisting with DHS Authorization and Compliance Inspections Maintaining CFATS ComplianceUpdating existing TSAs, SVAs, and SSPsConducting mock DHS Authorization and Compliance Inspections For assistance with CFATS applicability determinations or TSA, SVA, and SSP reporting requirements, contact Mr. Jose Orsini at (407) 982-2891 or email@example.com, or Mr. Taylor Wilson at (913) 894-4500 or firstname.lastname@example.org.
Trinity helps clients minimize business and environmental risk and maximize enterprise value with critical due diligence support. We are able to respond to demanding transaction deadlines and deliver timely and valuable assessments for key decision makers. We support buyers and sellers with a variety of due diligence assessments, including: Evaluating the true operating capacity of assets based on restrictions and representations in environmental documents and permits Determining the financial impact of future regulations (recently promulgated, still in the proposal stage, or under consideration by regulatory bodies) on specific facilities, companies, and industry sectors Conducting Phase I Environmental Site Assessments for prospective buyers, which characterize potential environmental liabilities (e.g., spills, leaks, or groundwater contamination) with respect to key environmental regulations such as Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)/Superfund Preparing Enhanced Phase I reports, which combine traditional Phase I components with a regulatory compliance review Performing Full Risk Impact Evaluations, which consider economic factors by examining current and future applicable environmental requirements and their impacts on operational costs and expansion opportunities Our experienced staff supports due diligence assessments for industrial clients, financial institutions, and law firms as representatives of buyers and sellers during asset transfers. As an integral part of the due diligence team we strive for innovative solutions that reduce environmental risks for sellers prior to a transaction. Similarly, we utilize our environmental and business knowledge and technical resources to identify and quantify potential risks and expenditures for buyers, and develop plans to minimize or eliminate those risks post transaction. For assistance, contact your local Trinity office at (800) 229-6655.
Companies traditionally manage EHS risks and performance through establishment of management systems, compliance programs, and compliance auditing programs. Even though these measures may be implemented systematically, they’re often designed specifically to address established EHS standards and requirements and measure associated conformance. However, business risks map across strategic, operational, compliance and reporting (financial and non-financial) dimensions, and across the entire enterprise (i.e., corporate, regions, businesses, functions, facilities). Because EHS risks are inexorably embedded in business risk areas, they can be difficult to segregate and effectively manage. And, because it is not just a company’s EHS professionals that perform work to address EHS requirements, risks and performance, many other functions can be involved (e.g., finance and accounting, human resources, legal, operations, maintenance, supply chain). Trinity raises the bar on how we help our clients by applying an enterprise-wide business risk view to addressing EHS compliance, risk and performance management: EHS business risk assessments and implementation consulting that incorporate environmental, health and safety, sustainability/carbon, and business/operational considerations Assessment of EHS function/organization and infrastructure effectiveness and improvement Assessment, improvement, and development of EHS compliance auditing programs EHS business risk management training Trinity’s EHS business risk assessment encompasses several of the following stages: Understand the tone-at-the-top, including overall governance, control environment, and objectives, as well as roles and responsibilities between corporate, business and facility level organizations Assess the existence and effectiveness of procedures, management controls and systems for EHS and associated business functions Ascertain how effectively corporate-level requirements and expectations are being implemented and integrated into business- and site-level operations Benchmark the client’s EHS program to those of competitors and customers to provide insight into attributes of EHS compliance, risk and performance management programs, and to identify potential improvement opportunities Identify strengths, gaps, and improvement opportunities as a basis to plan and implement program improvements Following this process provides our clients with a holistic approach to assessing and improving EHS functional effectiveness, and management of EHS compliance, risk and performance. For assistance, please contact John P. Fillo, PhD, CPEA at email@example.com.
ISO 14000 is an internationally recognized environmental management standard with its origins in sustainable development. While not for everyone, ISO 14001 certification may be appropriate for multi-national organizations or for those being required to obtain certification by their customers (e.g. suppliers to IBM, Ford, and GM). It may also provide a strategic business advantage for companies attempting to enter new markets or promote a record of environmental stewardship. Additionally, the American Chemistry Council (ACC)’s Responsible Care® program for environmental, health, and safety management has merged with ISO 14001 to create the Responsible Care 14001 initiative. Companies that are ACC members have the option to use one certification process to register that their management systems conform with both the Responsible Care program and ISO 14001. In contrast to a regulatory-driven approach to environmental management, ISO 14000 challenges organizations to establish their own environmental objectives, develop effective implementation strategies, measure progress, commit to continual improvement, improve employee awareness, and establish individual and collective responsibilities. Trinity Consultants assists clients in preparing for ISO 14001 certification in a variety of ways. Performing a gap analysis between existing environmental management systems and ISO 14001 (Environmental Management System – Specification with Guidance for Use) or Responsible Care 14001 requirements Developing and implementing missing EMS elements Coaching clients on how to achieve real, measurable value from an EMS Training management and employees Documenting ISO 14001 conformity Assisting with self-certification For assistance with selection, implementation, or preparing for certification under a management system, please contact your local Trinity office at (800) 229-6655.
Trinity recognizes the unmistakable connection between energy efficiency and greenhouse gas (GHG) emissions mitigation. Our climate change specialists assist industrial organizations in developing energy management strategies and implementing cost-saving measures to improve operational efficiency while lowering GHG emissions. Our interdisciplinary team analyzes the technical, economic, and regulatory factors critical for determining the feasibility of energy improvement options. Trinity's energy management specialists deliver value in the following areas: Analyzing energy cost and usage data to identify priority areas for potential improvements Evaluating technology changes (e.g., compressor, refrigeration systems), fuel switches, and energy conservation options related to operational practices Ranking energy reduction options by feasibility, costs, and business impact in the near-term and over time using carbon, fuel, and electricity price escalators Identifying financing options for renewable energy technology implementation Conducting energy audits and facilitating the implementation of priority improvements Delivering energy efficiency awareness training to staff to improve conservation efforts Examining the feasibility of relevant market mechanisms - especially the banking versus purchase of renewable energy credits and carbon offsets In addition, Trinity partners with specialty partners to target energy management in process-intensive sectors and to maximize the monetary benefit of operational changes including alternative energy technology implementation. For assistance with energy management, contact Rich Pandullo at firstname.lastname@example.org or (919) 469-9693, or your local office at (800) 229-6655.
NEPA Support The National Environmental Policy Act (NEPA) was enacted by Congress in 1970 (42 U.S.C.A. §4321-4370d) with the main goal of incorporating a “stop and think” step into the procedural aspect of the federal project review process. The Act requires that all federal agencies consider the environmental impacts of their actions and possible alternatives to those actions during the planning phases. Under NEPA, the agency making the decision on the action (the Lead Agency) will determine the adequate level of NEPA review required for a specific project. There are three possible levels of review. The simplest level of review is a Categorical Exclusion (CatEx). This level is reserved for proposed actions which have been historically deemed not to cause significant impacts (actions which have been thoroughly evaluated previously and determined not to pose significant effects). The second tier of review is the Environmental Assessment (EA). This represents a more thorough level of review than a CatEx, and may yield either a finding of no-significant impact (FONSI) or the need for an Environmental Impact Statement (EIS). Finally, the Environmental Impact Statement (EIS) is the highest level of environmental review reserved for “major federal actions” which may have “significant effects” on the quality of the “human environment.” Trinity Consultants’ team of scientists, consultants, and project managers are experienced in developing and managing diverse NEPA projects and compliance activities. Trinity staff assist with all aspects of NEPA compliance including: Development of purpose and need Alternatives development and evaluation Direct and cumulative study area development Characterization of the affected environment Categorical Exclusion (CX) determinations Environmental baseline surveys Environmental Assessments (EA) development Environmental Impact Statements (EIS) development Findings of No Significant Impact (FONSI) drafting Records of Decision (ROD) review Trinity Consultants’ diverse staff also has related expertise in air quality and noise modeling, ambient monitoring, and technical support. Consequently, Trinity can assist NEPA project proponents and lead agencies with needed resources that often require additional technical expertise and time. For assistance with NEPA/EIA, please contact David Strohm at email@example.com or (208) 472-8837. CEQA Compliance View CEQA Services Brochure The California Environmental Quality Act (CEQA) was enacted in 1970 (Public Resources Code Section 21000 et seq). The CEQA Guidelines (14 CCR 15000 et seq) incorporate and interpret both the statutory mandates of CEQA and the principles advanced by judicial decisions and new statutes. CEQA and the CEQA Guidelines require state and local government agencies to inform decision makers and the public about the potential environmental impacts of proposed projects, and to reduce those environmental impacts to the extent feasible. CEQA and its guidelines are immensely important to California businesses and public agencies, as these regulations affect every sector of the California economy and thousands of “projects” within the state. A “project” is generally defined to include a vast array of private and public sector actions, including commercial construction, industrial facility expansions, modifications to a power plant, highways and other public works, utility projects, residential developments and many others. CEQA Documents The public agency approving the CEQA “project” is known as the Lead Agency. The Lead Agency is initially responsible for preparing a brief CEQA Checklist (also known as an Initial Study) to assess whether the project has the potential for significant adverse environmental impacts. If a project will not cause any significant adverse environmental impacts, the Lead Agency may issue a “Negative Declaration” or “Mitigated Negative Declaration” document. If the project may cause significant adverse environmental impacts, the Lead Agency must prepare an Environmental Impact Report (EIR). An EIR contains in-depth technical studies of potential impacts and measures to reduce or avoid those impacts, as well as an analysis of project alternatives. The CEQA process provides a mechanism to inform decision makers and the public of the potential environmental impacts and to facilitate public review and input. Air Quality and Other Technical Studies An in-depth air quality technical study is typically required in air basins or districts which exceed state and federal ambient air quality standards and for projects which have the potential to exceed air quality impact thresholds. These air quality impact analyses (AQIAs) become the basis of an Air Quality Chapter in an EIR and include complex emission estimates and modeling to comply with CEQA and other regulatory requirements, including the following: Ambient air quality modeling Criteria pollutant emission estimates for all construction and operational activities – stationary, mobile, and area sources Cumulative criteria pollutant emission impacts Greenhouse gas emission estimates, inventories, reduction strategies, and climate action plans (AB 32) Health risk assessments (AB 2588) Odor assessments Trinity Consultants’ experienced environmental professionals provide CEQA documentation and AQIA services. Trinity’s CEQA regulatory expertise, technical proficiency, responsiveness, and creative thinking are key to ensuring complete client satisfaction. Trinity’s Quality Management System, ISO 9001-certified in its Dallas headquarters office, ensures that clients receive consistent, high quality CEQA services. Trinity’s CEQA team has diverse project experience covering a wide range of industry sectors. Our CEQA-related services also include: Power plant environmental compliance documentsfor the California Energy Commission Air and multi-disciplinary permit coordination Agency negotiation and strategic planning Due diligence and records review Enforcement, litigation, liability, and expert witness support Trinity’s California team works effectively with all California air quality districts, the California Air Resources Board, and city/county agencies statewide. For assistance with CEQA, please contact Mr. Vineet Masuraha, Regional Director, at (949) 567-9880 or firstname.lastname@example.org, or contact your local Trinity office at (800) 229-6655.
When environmental and industrial safety issues become litigious, our senior staff work with clients' legal counsel to provide the appropriate support. Our senior staff are familiar with and experienced in discovery, deposition, settlement, and trial proceedings. Trinity's experienced environmental litigation support group assists legal counsel in several ways: Regulatory interpretation - We provide practical and historical interpretation of regulations as various regulatory authorities implement them. Our extensive historical environmental regulatory library is without parallel. Technical support - We perform the technical analyses and provide scientific evidence necessary to evaluate the merits of a case. Expert testimony - We provide expert testimony on a host of environmental and safety-related issues. Trinity staff have assisted legal counsel in litigation support as both Consulting and Testifying Experts. In one or both roles, Trinity staff have provided expert opinions on a wide range of matters, including: Air dispersion modeling, including gaseous dispersion and particle deposition analyses Emissions quantification, including forensic emission inventories going back nearly 100 years Emissions and air quality measurement, and associated data interpretation and trend analysis, including forensic speciation analysis of complex mixtures of pollutants from a number of sources and various environmental media Regulatory interpretation of complex programs including state and federal permit programs (Nonattainment New Source Review, Prevention of Significant Deterioration and Title V) Administrative variance and enforcement proceedings Licensing, permitting, and certification proceedings before local, state and federal regulatory agencies Product liability and patent litigation Litigation alleging harm to individuals and/or property (toxic tort litigation) Consulting expertise – We render legal advice to parties involved in environmental litigation. As a Consulting Expert, Trinity senior staff work closely alongside legal counsel, assisting with strategic advice and testifying experts, reviewing draft discovery materials briefs, and draft expert reports, evaluating settlement proposals and options, and preparing the testifying team for deposition and trial. Counsel and witness training - We provide training to attorneys faced with unfamiliar technical issues, and to testifying witnesses from the perspective of a scientific witness operating in a contentious legal environment. Our litigation support experts include: John P. Iwanski – Air quality regulations and permitting, pollutant dispersion, enforcement resolution Dan Risch - Forensic meteorology, expert testimony, forecasting, climatology Hung-Ming (Sue) Sung, Ph.D. – Air quality and noise impact analysis For assistance, contact one of our experts listed above or your local Trinity office at (800) 229-6655.
Noise and vibration are inherent to industrial equipment and operational activities. Sources of noise can include: fans and exhausts; vehicle operations; baghouses and control equipment; rotating machinery; material handling; motors; reciprocating engines; turbines; steam and gas venting; pressure drops in piping systems; and many others. Potentially an environmental nuisance, noise and vibration are becoming increasingly regulated by federal, state and local agencies. For example, certain natural gas projects under the jurisdiction of the Federal Energy Regulatory Commission (FERC) are required to conduct detailed ambient sound measurements and noise impact analyses at noise sensitive areas to demonstrate compliance with federal noise standards. Increasingly more municipalities are adopting noise ordinances that set technical noise standards at plant fence lines and residential receptors. Failure to comply with these standards can lead to community relations issues and potential lawsuits. Trinity provides a wide range of noise and vibration services including the following: Industrial noise impact assessments Ambient sound and vibration measurement and characterization Federal, state and local noise standard compliance planning and verification Background noise studies Siting studies for new plants and expansions NEPA Environmental Assessments (EA) noise reports FERC Resource Report 9 noise section preparation Noise impact mitigation assistance Predicting Noise Impacts Trinity can predict the impact of noise sources at fence lines and noise sensitive areas using both vector modeling software packages (e.g., CadnaA and SoundPLAN) and our workbook-based calculation tools. Vector modeling software enables accounting for complex scenarios, such as industrial facilities having multiple sources spread over large areas, widely varying topography, structure reflections, ground cover, barriers, atmospheric effects, etc. It also provides a means of determining which noise sources have the largest impact on any given receptor, and allows the testing of proposed noise mitigation measures. Trinity’s workbook–based calculation tools along with a database of acoustical data for many types of noise sources, typically offer a conservative prediction at modest expense for uncomplicated scenarios. Trinity’s modeling tools allow us to: Incorporate complex building and terrain geometry Generate noise contour plots Efficiently quantify multiple noise sensitive areas Generate 2D and 3D visualizations Avoid costly field studies by using source data and predictive analysis Measurement and Characterization When appropriate, Trinity uses research-grade sound level meters (SLMs) in the field to measure ambient sound levels and characterize sound sources at noise sensitive areas and fence lines. This is a requirement for certain federal rules, and is often necessary and prudent before undertaking construction of new noise sources in municipalities with noise standards and when investigating noise related complaints. Trinity can also measure the magnitude and frequency of ground vibrations as needed to demonstrate compliance with vibration standards. Project Experience Trinity personnel have performed noise and vibration monitoring and impact assessment projects in numerous US states and Canadian provinces. Projects have ranged from the predictive modeling of impacts at Noise Sensitive Areas and assistance with selection of mitigation methods to measurement and characterization of ambient noise and vibration levels and sources, and measurement of acoustic emission data for noise sources. Facilities and emission sources for which we have performed noise and vibration assessments include the following: Stationary reciprocating and combustion-turbine powered electrical generating systems Many types of manufacturing facilities Natural gas compressor stations and storage facilities Reciprocating engines, turbines, cooling systems, dehydrators, pressure reduction valves and vents, substations, etc., at natural gas compressor stations Construction projects involving heavy equipment Horizontal directional drilling and salt cavern development activities Trinity has prepared and conducted the modeling and monitoring work and prepared the sections of Resource Report 9 necessary to characterize ambient sound quality and predict noise impact for natural gas projects in many states. Our experience includes responding to FERC data requests, and conducting post-operational compliance demonstration monitoring. Understanding and Selecting Noise Mitigation Trinity can assist its clients in understanding and selecting noise mitigation measures, including exhaust and vent silencers, acoustic insulation for buildings, ventilation systems and piping, noise berms and barriers, work practices, proper equipment specifications, etc. Trinity has a library of noise mitigation equipment and vendor data for use in selecting appropriate mitigation measures. For assistance with noise and vibration services, please contact Chris Scullion at email@example.com.
While odor issues are often addressed on a case-by-case basis when nuisances occur, state laws and local ordinances are increasingly adopting specific odor guidelines and criteria. Some jurisdictions have even established odor testing protocols and air dispersion modeling practices tailored specifically for odor. Hence, odor measurement, modeling, minimization, and management are becoming more critical for industry. Many jurisdictions in North America define odor criteria using a relative strength scale in terms of “odor units,” or simply, OU. As a reference, one odor unit (or 1-OU) represents the level where 50% of the population can begin to detect an odor. For example, if an established odor criteria was 7-OU, then the odors present in the air would be at a strength that would require 7 dilutions with 'clean' air to meet the threshold where half the population could no longer smell the odor. Odor is inherently complex and difficult to quantify because it is often caused by a mixture of chemical substances. Odor is also quite subjective by its nature and can affect individuals differently. Therefore, odor assessments typically employ FIDOL observations to further characterize impacts. Frequency - how often the odor impacts occur Intensity - the relative odor strength (faint to overwhelming) Duration - the length of time for a given odor event Offensiveness - the character or description of the odor Location - mapping impact location and identifying potential off-property contributing sources Trinity conducts ambient field studies using olfactometers using pre-screened, certified assessors. (Pre-screened assessors fall into a specific range of odor tolerance to ensure assessors are not overly sensitive or insensitive to odor.) We also use atmospheric dispersion models such as AERMOD for assessing odor impacts and compliance at sensitive points of reception. Odor modeling assessments typically employ a source testing component to quantify odors directly at the source. Samples collected at the source are sent to a certified odor panel for analysis. For assistance with odor analysis, please contact Angie Wanger (651) 275-9900 or firstname.lastname@example.org com, or Chris Scullion at (416) 391-2527 or email@example.com.
Compliance Audit is one of the fourteen required elements of the Process Safety Management (29 CFR 1910.119) and Risk Management Plan (40 CFR 68) Program Level 2 and Program Level 3 programs. The Process Safety Management (PSM) and Risk Management Plan (RMP) programs are intended to be self-governing regulatory programs where facility management personnel monitor internal program performance and audit their PSM and RMP program every three years. The compliance audit is typically conducted by an unbiased third-party but may also be performed in house with appropriate training and expertise. Trinity routinely supports clients in developing and implementing successful compliance audit programs. The intent of the compliance audit is to internally assess and discover potential gaps in an organization's PSM/RMP program. It reviews PSM/RMP covered operations, documentation, and culture, and compares them against regulatory requirements, recognized and generally accepted good engineering practices (RAGAGEP), and site-specific written procedures. In short, it's a reality check of how well a facility “walks their talk” with respect to their PSM/RMP programs. PSM/RMP Compliance Audit Scheduling and Recordkeeping To ensure a facility stays in compliance with the requirements of the PSM/RMP standards, an appropriate audit schedule is developed from the date when the first PSM/RMP covered chemical exceeds its threshold quantity in the system. From this initial date, the facility must conduct a compliance audit within three years and every three years thereafter. Staff should allow three to six months prior to the three-year milestone to adequately prepare for a compliance audit, to compile necessary process safety and risk management program information, hold audit project planning meetings, complete the audit, and prepare the final report. Completing the site audit two to four weeks prior to the compliance date should provide the facility the necessary time to safely finalize the audit within compliance. A facility must keep records of the last two compliance audits on site, including a method of tracking the identified action items and their status, completion dates, and responsible party. The site should be able to demonstrate that all previous compliance audit items were addressed appropriately. Carryover action items from one compliance audit to the next could be perceived by OSHA and/or EPA as compliance violations, up to and including willful violations. PSM/RMP Compliance Audit Preparation While there is no one “correct” way to prepare for a compliance audit, Trinity's auditors will help ensure you have a well-planned, successful audit. Some facilities develop a “war room” or a LAN location to gather representative PSM/RMP documents and evidence for easy access to the audit team. A kickoff meeting with the auditor and site team is helpful to review the audit agenda and documents requested for review prior to the onsite work. Pre-audit meetings that discuss the audit procedure and schedule with key audit project stakeholders and affected employees will help cultivate PSM/RMP culture and a team-based approach to auditing. Ideally all affected employees will have at least fundamental PSM/RMP awareness prior to the audit. Trinity Consultants frequently provides associated training for affected employees. PSM/RMP Compliance Audit Approach Trinity Consultants utilizes an optimized auditing approach, using recognized and generally accepted practices at its core. Our approach is a simple three step process that includes aligning with facility planning goals, conducting a qualified representative audit, and delivering a final report with reasonable and clear recommendations that put your facility on a path to compliance success. We provide detailed metrics identifying key focus areas that are statistically significant to improve a facility's overall safety and compliance score. With our audit results, you will understand how to prioritize your time and resources to improve your PSM/RMP program for greatest improvement. For example, a facility may have several findings in mechanical integrity but few in process safety information. We will address findings in a manner that maximizes resolution with minimal effort. Trinity's auditors are respected experts in the industry with decades of PSM/RMP knowledge and experience. Our auditors have varied backgrounds and experience including PSM/RMP management, EHS management, operations, maintenance, and plant management in multiple industries such as chemical refining, oil and gas, power generation, and ammonia refrigeration. We understand that a good auditor understands equipment, operations, and people just as much as the regulations. Trinity's auditors have supported clients on OSHA and EPA surprise inspections and have successfully worked with regulators to reduce violation status, create abatement plans, and implement recommendations from OSHA violation notices and EPA agreed orders. Trinity Consultants' auditors understand what OSHA and EPA look for and we use this valuable perspective to enhance focus and provide relevant results. We are deeply connected to PSM/RMP goals and see every compliance audit as a fresh opportunity to deliver industry best practices and meaningful results to our clients. After the Audit: PSM/RMP Continuous Improvement Trinity Consultants' PSM/RMP experts help build fully-compliant programs from scratch, improve existing programs, and optimize mature, successfully implemented PSM programs. We have performed hundreds of PSM and RMP audits and have represented clients successfully through multiple OSHA and EPA inspections through which we have developed an efficient process for continuous improvement of client programs. When the audit is complete and the final report is in your hands, it is time to start resolving the findings. Using technology, we document the PSM and RMP rules, combine the rules with real-world tasks, and enable management to track and validate PSM compliance performance on a routine basis. When the next compliance audit cycle occurs, our clients are well informed, ready to audit, and typically perform better on compliance audit score results. Contact us to learn about our continuous improvement methodology. Successful PSM/RMP Compliance Solutions If your compliance audit is past due or if you're unsure how to address previous compliance audit recommendations, contact Trinity Consultants at 800 229-6655 or at trinityconsultants.com/ContactUs. We can assist you in developing solutions that avoid or minimize enforcement consequences from lingering audit recommendations. Our compliance auditors will work with you to find an optimal compliance solution and address the potential compliance audit issues. If your facility is likely to carry over compliance audit recommendations to the next audit, please contact us for assistance. We can often address recommendations utilizing your existing program or by developing a solution for resolution. Carrying over unresolved compliance audit recommendations into the next audit can result in regulatory violations, fines, and a record of non-compliance for the next two audit cycles. A serious compliance situation like this is avoidable; if this situation applies to your facility, please contact us immediately for assistance.
What is Mechanical Integrity? OSHA Process Safety Management (29 CFR 1910.119(j)) and EPA Risk Management Program (RMP) Level 3 (40 CFR 68.73) define the Mechanical Integrity (MI) element as a systemized approach utilizing recognized and generally accepted good engineering practices (RAGAGEP), written procedures, and training to manage the on-going maintenance program and integrity of process equipment. EPA's RMP Program Level 2 Maintenance element (40 CFR 68.56) is almost identical in approach to the MI element and requires the facility to have a written maintenance program. EPA's RMP Program Level 1 does not require MI or maintenance programs, but you may want to consider implementing them as best practices relative to OSHA and EPA General Duty clauses. How to Start Implementing MI Achieving MI compliance begins with an assessment of the facility's equipment and maintenance records. The following equipment is required to be included in the MI program (29 CFR 1910.119(j)(1)(ii), 40 CFR 68.73(a)): Pressure vessels and storage tanks Piping systems (including piping components such as valves) Relief and vent systems and devices Emergency shutdown systems Controls (including monitoring devices and sensors, alarms, and interlocks) Pumps Trinity can assist in developing an inventory of existing equipment, spare parts, and components for the covered process and utilizing existing resources to streamline this process. We are fluent in computerized maintenance management software systems (CMMS) such as MP2, Maximo, and SAP and can deliver optimized solutions working within the client environment. Industry faces major MI enforcement and implementation hurdles to demonstrate that site-specific maintenance procedures, testing, and inspections comply with RAGAGEP for their covered process equipment and instrumentation. We facilitate a thorough review of original equipment manufacturer (OEM) manuals; codes such as API, ASME, IEEE, NFPA, and IIAR; and best practices drawn from industry trade groups and Trinity's experience providing MI services nationwide. We develop a site-specific MI program that meets your current requirements and includes a strategy to maximize efficiency for planned “downtime” for the process. Building unique preventive maintenance schedules that coordinate facility production schedules, learned component duty cycles, and OEM requirements poses a challenge that Trinity is well suited to address. Our goal is to map existing maintenance procedures, work orders, and PM inspections to the MI standard and provide a document that identifies potential gaps and recommends the best path forward for an effective MI program. Facility management is required to assure its covered processes are built, maintained, inspected, and tested consistent with design specifications, manufacturer's instructions, and RAGAGEP, and that spare parts are managed accordingly. Trinity's approach results in an MI program designed to satisfy these required assurances for maximized safety benefits and successful agency and internal triennial PSM/RMP compliance audits . MI Support Services PSM/RMP Covered Process Boundary Determination and Process Equipment Inventory Understanding the PSM/RMP applicability boundary at your facility is crucial to properly implementing the MI standard. Common questions involve whether utility systems, such as process air or cooling water, fall under the MI standard, and each case should be evaluated against its location and importance to the covered process. Trinity will review your process operations and facility siting study to assist in determining an accurate, realistic approach for PSM/RMP boundaries. Additionally, MI cannot be properly implemented without a full inventory of what constitutes the “covered process” equipment and instrumentation. Creating this database can be a daunting challenge, for legacy operations and greenfield construction alike. Our consultants are skilled in efficiently gathering field data and inventorying covered process equipment to identify the equipment that must be addressed in the MI program. Trinity Consultants can provide data gathering and database management solutions for numerous purposes: Developing a comprehensive equipment and spare parts inventory for the covered process; Gathering and creating a database for technical data and specifications for covered process equipment; Labeling equipment as PSM/RMP MI in CMMS systems such as MP2, Maximo, or SAP; and Determining non-applicable equipment and documenting its basis for exclusion. OEM and RAGAGEP Standardization Greenfield construction, existing operations, and legacy covered process systems all require that the facility owners assure the equipment construction and inspection and testing programs comply with manufacturers' recommendations and code requirements, known as RAGAGEP. These OEM manuals, standards, and best practices must be compiled and identified for each piece of equipment in the covered process. An OSHA or EPA auditor may ask the facility maintenance department for specific PMs and the site's documentation demonstrating that those PMs are following RAGAGEP. Auditors will scrutinize the PM frequency, methodology, and tools, parts, and labor used against their expectations, derived from OEM/Code documents, historical MI implementation, field data, previous audits, and agency publications. Trinity Consultants is experienced in navigating the immense database of RAGAGEP information and providing a roadmap for compliance success. Maintenance Procedures Technical Writing The PSM/RMP MI standard requires covered processes to have “written procedures” for maintaining the integrity of process equipment. While many facilities have a CMMS implemented with a dedicated PM or work order system in place that defines routine maintenance tasks and activities, we often find that these work orders do not fully address the MI written procedure requirement. For facilities that do not utilize a CMMS for work orders, there is usually an even larger compliance gap for maintenance procedures. Trinity will provide your facility with the following documents that comply with PSM/RMP requirements: Written MI Administrative Program Written MI Inspection and Testing Procedures that follow RAGAGEP Written MI PM procedures for on-going integrity management Trinity Consultants has developed full written MI programs for a wide range of facilities and we have established industry best practices and standards in our approach. Trinity Can Help Trinity Consultants leverages its combined environmental, safety, and process engineering experience to create comprehensive and well-managed PSM and RMP maintenance solutions. Our nationwide consulting staff has a generous database of best practices, lessons learned, and OSHA/EPA auditing experience to ensure we continuously add value to your process safety systems. Contact Trinity Consultants today at (800) 229-6655 to start the discussion about your process safety maintenance programs.
NEWS: Don't miss our upcoming webinar on the RMP Reconsideration Rule - June 22, 2018 at 12:00 pm Central. Trinity serves a broad cross-section of industries with Process Safety Management (PSM) and Risk Management Program (RMP) support. We work with clients to determine whether the facility uses any of the listed chemicals in quantities that exceed program applicability thresholds. If so, we evaluate options to modify processes in order to opt out of the applicable program or step down to a less rigorous level (in the case of RMP). Once program applicability is determined, we can assist with the development of the PSM/RMP applicable components - Hazard Assessment, Prevention Program, Emergency Response, and the RMPlan. RMP Hazard Assessment The primary element of the Hazard Assessment is an off-site consequence analysis to determine the potential impact of “worst case” and “more likely” accidental release scenarios. The worst-case analysis determines which program level is required under the rule. Trinity's modeling and regulatory compliance experience is invaluable in helping clients determine the appropriate program level. Depending upon the results of the worst case analysis, alternative scenario analyses may be required. The first step in the Hazard Assessment is to identify the appropriate release scenarios based on a facility's process safety information. An experienced risk assessor then reviews the site's operations and layout. The scenarios should be selected by balancing the likelihood of an incident, the estimated distance to a predicted endpoint, and effective communication of actual plant risks. Using realistic, credible analytical methods helps prevent public miscommunication. Whatever the local concerns and type of hazards, Trinity can assist in the development of scenarios that are representative and reasonable. Prevention Program Development and Review The Prevention Program includes the most technically demanding and labor-intensive elements in a PSM/RMP program. All of the following elements may be required in a Prevention Program: Process safety information Process hazard analysis Operating procedures Training Mechanical integrity Management of change Pre-startup review Compliance audits Incident investigation Employee participation Hot work permit Contractor safety Emergency response (PSM) Trade Secrets (PSM only) Trinity's staff has participated in the development, review, and implementation of all elements of the Prevention Program. With client staff, Trinity conducts safety reviews and hazards analyses, identifies weaknesses, and makes recommendations. If a facility has an existing program, Trinity reviews the program to ensure that it meets all legal requirements and is consistent with good engineering and management practices. Trinity also works with the client to develop an effective, grass-roots accident prevention program if needed. Risk Management Plan and Community Relations Once the necessary analyses have been performed and programs developed, Trinity can assist with documentation and communication of the plan, which includes completing EPA's checklist, submitting the plan, documenting the assumptions behind the analysis and program development, and communicating the results to the public. Our experience teaching technical material, along with our experience providing expert testimony, help us communicate complex technical issues, implement public communication programs, and prepare a timely and accurate response to any issues raised as a result of the assessment. Trinity also helps facilities ensure that they meet their requirements under the General Duty clause to provide employees with an environment that is free from recognized hazards that cause or are likely to cause death or serious physical harm. Finally, Trinity offers turnkey chemical safety program services for industrial clients in the following areas: Tracking applicable regulatory developments PSM/RMP applicability determinations Assisting with preparation and implementation of prevention program elements Conducting program audits including required triennial regulatory compliance audits Facilitating Process Hazard Analyses (PHAs) for existing and new operations Conducting off-site consequence analysis (OCA) modeling Preparing the Risk Management Plan, updates and submittals Training personnel on PSM/RMP elements and program execution Assisting clients during agency inspections and meetings For assistance, please contact Natalie VanLiew at (913) 894-4509 x102 or firstname.lastname@example.org.