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EHS Performance and Risk Management Support


Auditing and Verification

There is growing recognition among organizations of all types that environmental, health. and safety (EHS) challenges represent genuine business enterprise risks. Trinity's EHS Performance & Risk Management team assists clients in addressing EHS challenges from various perspectives - strategic planning, program evaluation, and systems development. Trinity's expertise provides value to clients in characterizing enterprise-wide EHS impacts, addressing stakeholder expectations, managing EHS-related risks and opportunities, and improving EHS performance. EHS Auditing Services Trinity's auditing team assists organizations with auditing for compliance with regulatory requirements as well as conformance with management systems. Regulatory Compliance Auditing Auditing systems to evaluate compliance with regulations is especially important because of potential enforcement issues. Trinity develops a protocol for compliance audits and assesses site performance related to EPA and OSHA regulations, including state and local requirements. Trinity's audit team is experienced in conducting regulatory compliance audits for the following programs (among others): Environmental Air quality permitting and regulatory compliance, including Continuous Emissions Monitoring System (CEMS)Solid waste (including generator, transporter, TSDF, and waste receptor)Water (wastewater discharges, water reclamation and reuse, water appropriation, stormwater)Emergency preparedness (SPCC, FRP, and FSP)Risk Management Plans and Accidental Release Prevention (Program Levels 2 and 3)Hazardous Materials Reporting (Tier 2, TRI) Occupational Safety and Health Process safety management (PSM)OSHA general industry standardsOSHA shipbreaking standardsPermit-required confined space programsLockout/tagout programs Other Chemical Facility Anti-Terrorism Standards (CFATS) 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. Corporate EH&S Audits Internal Audits are structured to assess a company's performance against its own standards. These standards may exceed regulatory requirements and encompass industry best practices. Trinity can either develop a protocol or use an existing corporate protocol, and the audit can be performed by a Trinity team or a team that combines Trinity and client personnel. Management Systems Assessments Trinity's auditing professionals frequently evaluate organizations' conformance with standards such as ISO 14001, RC 14001, OHSAS 18001, and other EHS management systems, often in preparation for the certification process. 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.  Who needs Auditing and Verification Services? 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. In addition, 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 of concern 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 EHS 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.   Trinity Can Help - Contact Us Today For more than 45 years, Trinity has assisted facilities with ensuring compliance with applicable regulations, management system standards, and other requirements. This domain expertise combined with our knowledge of industry processes and our auditing experience provide a powerful auditing resource for industrial and commercial facilities. Trinity's staff includes auditors that meet a number of professional auditing qualifications including the following: Certified Professional Environmental Auditors (CPEAs) Certified Energy Auditors (CEA)  Certified ISO 14001 auditors American Chemistry Council Responsible Care® trained auditors Certified Practitioners for Energy Management Systems - Industrial Sector (CP EnMS) ISO 50001 and Superior Energy Performance ISO 9001 and OHSAS 18001 trained auditors For more information about how Trinity can help you with EHS audits, call Trinity at +1 (800) 229-6655 or Contact Us online. Related Articles Part 75 Auditing And Protocol Overview  -- Nov 10, 2019 Effective Preparation for EHS Compliance Audits: Stormwater and Industrial Wastewater Discharges -- Oct 10, 2019 Effective Preparation for EHS Compliance Audits -- July 25, 2019 U.S. Customs' New Audit Policy - Checkmate in Two Moves? -- May 08, 2019 Annual Audit Requirements for Facility Security Plans -- May 01, 2019 The Value of an EHS Gap Assessment to Prevent a Formal Audit -- May 01, 2019 EHS Auditing Best Practices, Enforcement Initiatives, and Improving the Culture of Self Governance -- December 05, 2018 Common Findings in OSHA PSM Audits -- Apr 26, 2017 Related Training Air Compliance Auditing for Industrial Facilities EHS Audit Skills and Techniques Internal EHS Management Systems Auditing Waste Compliance Auditing for Industrial Facilities Water Compliance Auditing for Industrial Facilities Training Webinar: Air Quality Audit Strategies for Oil and Gas Facilities - $99.00 Free Webinar: EPA's Proposed New Owner Audit Policy for Exploration and Production (E&P)   

 

Third-Party (Independent) Verification Services under California Assembly Bill 32 (AB 32)

Third-Party Verification for California GHG Mandatory Reporting Regulation (MRR), Compliance Offset Program (COP), and Low Carbon Fuel Standards (LCFS) Trinity's Verification Team has provided Greenhouse Gas (GHG) emission data verification services to a variety of industry sectors over a decade in California. Our verification services are conducted following applicable industry standards and/or regulatory programs, including but not limited to: Regulation for Mandatory Reporting of Greenhouse Gas Emissions (Title 17, California Code of Regulations (CCR), sections 95100-95157) Compliance Offset Program in the Cap-and-Trade Regulation (Title 17, CCR, sections 95801-96022) Low Carbon Fuel Standard (LCFS) Regulation (Title 17, CCR, sections 95480-95503) ISO Standards - Greenhouse Gases Part 3: Specification with Guidance for the Validation and Verification of Greenhouse Gas Assertions (ISO 14064-3:2019) ISO Standards - Greenhouse gases - Requirements for greenhouse gas validation and verification bodies for use in accreditation or other forms of recognition (ISO 14065:2013) Important Dates: California GHG MRR - Verification Deadlines August 10 - Final verification statements due for all emission data reports, including emissions, supplier data, and product data for all industry sectors (e.g., general, oil & gas, process, and transactions) California COP - Verification Deadlines The COP program does not include fixed reporting and verification deadlines, instead, it allows Reporting Periods to run over any 12-month period All Offset Verification Statements are due to an Offset Project Registry within nine (9) months after the conclusion of the Reporting Period for which offset verification services were performed  California LCFS - Verification Deadlines August 31 - Final verification statements for all LCFS annual report types except for the following report types: Fuel Pathway Applications - Validation statement is due within six (6) months of application submission to CARBQuarterly Project Reports - If an entity chooses quarterly reporting, the verification statement is due within five (5) months of each quarterly project report deadline What is Third-Party Verification Under California's AB 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. Third-Party Verification Requirements for GHG Mandatory Reporting Program (MRR) As part of AB 32, the California Air Resources Board (CARB) promulgated mandatory reporting regulations (MRR) in December 2007 that require entities to calculate and report their GHG emissions for specific industry sectors and general stationary combustion sources with emissions greater than or equal to 10,000 metric tons (MT) of CO2e per year. Also, 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. Third-Party Verification Requirements for Compliance Offset Program (COP) Compliance 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. Third-Party Verification Requirements for Low Carbon Fuel Standards (LCFS) The main objective of LCFS is to decrease the carbon intensity of California's transportation fuel pool and to provide an increasing range of low-carbon and renewable alternatives, which would benefit air quality from reducing petroleum dependency. The LCFS relies on accurate data monitoring, reporting, and verification to support implementation and tracking of effectiveness. In 2018, CARB amended the LCFS regulation to add third-party verification requirements to ensure data completeness, accuracy, and conformance with the regulation, consistent with the verification programs under California's Cap-and-Trade Program and international best practices. Trinity Can Help - Contact Us Today Our CARB-accredited 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. Also, Trinity's Quality Management System ensures that clients consistently receive high-quality verification services and deliverables. Trinity's AB 32 GHG verification team provides the following unique benefits to our clients: Accredited Verification Services: Trinity is an accredited verification body for MRR, COP, and LCFS programs. Our team includes experienced CARB-accredited lead verifiers and non-lead verifiers with specialist credentials in a wide range of industry and report types. Proven Track Record: As one of the most active ARB-accredited verification bodies in California, Trinity completes more than 50 third-party 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 industry practice, GHG emission inventories, and carbon footprint-related regulatory requirements. High-Quality Work Products: Trinity's consulting and verification practices and operations are quality assured consistent with ISO 9001 standards for the delivery of superior technical products. Relevant Project Experiences: Trinity has relevant experience in GHG verifications, GHG management, and emission reduction plans, enterprise-wide inventories, and carbon foot-printing, life cycle analysis, and fuet pathway development 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 lead and non-lead verifiers are strategically located to cover the entire state, including Northern California, Central California, and Southern California. For more information on how the Trinity can assist you, please contact:  Third-party verification: Dr. Charles Lee, Principal Consultant - (949) 567-9880 x102 Other GHG-related assistance: Steve Walters, Principal Consultant - (949) 567-9880 x118 Related Services In addition to the aforementioned third-party 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 suppor GHG verification in other programs and registries (e.g., CDP, CAR, and VCS) GHG program training GHG emission reduction plans  Related Training California AB 32 GHG Compliance and Strategies Introduction to Environmental Reporting in California Free Webinar - How to Prepare for California Low Carbon Fuel Standard LCFS Verification Requirements in 2020 and Beyond Free Webinar - California Low Carbon Fuel Standard Amendments: What You Need to Know Webinar Free Webinar - Webinar Series: Practical Guide to Air Quality Compliance for the Oil & Gas Industry - Part 2: GHG Mandatory Reporting Rule (Subpart W)  External Resources California LCFS Verification Program California Offset Verification Program California GHG MRR Verification Program

 

CDP Verification and Assurance

Trinity's Greenhouse Gas (GHG) Verification Team has provided climate data verification and assurance services to a variety of industry sectors for numerous voluntary and mandatory reporting programs. Third-party verification ensures data credibility and accuracy and that is why it is highly recommended. As a verification service provider, Trinity brings the required expertise, skills, and experience to the assurance process with benefits of credibility, trust, and conformity. What is CDP Verification and Assurance?​ 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 7,000 organizations annually and used for investment decisions by many entities, 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. Established in 2000, CDP has expanded its purview from investor climate change disclosure only to now also including supply chain disclosure, water and forest footprint disclosure, development of disclosure and performance leadership indices, and other programs. Important Dates Last Wednesday of July - Questionnaires for both investor and supply chain requests annually are due to CDP. CDP reporting and disclosure is performed on an annual cycle. The requests for information (RFI) on behalf of investors are issued in February and directed primarily to Chief Executive Officers of Global 500 companies, as well as companies designated as high impact or voluntary reporters. Supply chain members receive their RFIs in April. Companies can disclose regardless of whether they receive the RFI and can participate in either or both requests under any of the disclosure programs. Who needs to submit environmental data via CDP? Increased pressure for business transparency is compelling companies to disclose environmental, social, and governance (ESG) information. Whether through sustainability reporting to standards like the Global Reporting Initiative, indices such as the Dow Jones Sustainability Index, disclosure guidelines such as those of the Sustainability Accounting Standards Board, or investor and supply chain disclosure through EcoVadis or CDP, stakeholders are influencing how businesses operate like never before. According to CDP, in 2019, over 7,000 companies responded to its climate change, water, forests, and supply chain questionnaires, and over 525 investors with $96 trillion in assets under management, requested information on climate change, water, or forests. CDP's influence is spreading through its supply chain program as well, with 115 companies requesting disclosure by their enterprise partners, comprising $3.3 trillion in procurement spending for 5,600 suppliers. Trinity Can Help - Contact Us Today​ 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 related professional credentials, including: 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 CDP climate data verification services, please contact Charles Lee, Principal Consultant, at (949) 567-9880, or Rich Pandullo, Director, at (919) 462-9693. Related Articles​ ​Vision 2020 - Centralized Data for Environmental Reporting -- Oct 10, 2019 Voluntary GHG Reporting via CDP -- Oct 10, 2019 CDP Climate Change Disclosure Opportunities for Performance Improvement -- May 01, 2019 Climate Change Performance Excellence Through CDP Reporting and Disclosure -- Jun 05, 2018 Improving CDP Disclosure Performance through Verification -- May 08, 2017 Corporate Performance Excellence through CDP Reporting and Disclosure -- Apr 26, 2017 Related Training​ Best Practices in Carbon Disclosure Project (CDP) Reporting Free Webinar - CDP Reporting & Disclosure: Overview & Best Practices

 

Due Diligence Support

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 Trinity at (800) 229-6655.      

 

EHS Business Risk Management

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 jfillo@trinityconsultants.com.

 

EHS&Q Management Systems Support

  NOTE: In response to the challenges posed by COVID-19, the International Accreditation Forum (IAF) has extended the migration deadline from OHSAS 18001 to ISO 45001 certification to Sept 11, 2021 (previously March 2021).     For more than 45 years, Trinity has assisted organization by addressing EHS compliance and performance issues. This experience, combined with the knowledge of Trinity's management system experts, ensures successful implementation and maintenance of our clients' management systems. Trinity's professionals bring decades of management system experience to client engagements, encompassing a complete spectrum of EHS&Q systems: ISO14001, RC14001, ISO 45001, ISO 50001, and ISO 9001. What is a Management System? A management system is a set of systematic processes and practices that enable an organization to effectively manage its interactions with the environment, occupational health and safety, and/or its customers. A management system that is well conceived and implemented can provide many benefits to an organization, including: Enhancing compliance with regulatory requirements  Managing risks and opportunities  Improving confidence among stakeholders Improving corporate image  Meeting customer demands Achieving competitive advantages (reduced energy usage and raw material consumption, improved environmental stewardship, decreased production losses, reduced accidents and incidents, etc.) There are several recognized standards that an organization can use as a model when developing a management system. All of these standards have been updated in recent years and follow the “ Plan-Do-Check-Act Model.” ISO 14001 Environmental Management System (EMS)  ISO 9001 Quality Management System (QMS) ISO 45001 Occupational Health and Safety Management System (OHSMS) ISO 50001 Energy Management Systems (EnMS) How should a company prepare? Most organizations should expect to expend at least a modest level of effort in reconfiguring their existing management systems to align with the new standards. With significant expertise in relevant regulatory issues and effective management systems, Trinity assists clients with the following implementation services. Important considerations include the following: Gap Analysis - Conduct a gap analysis and establish a development plan for aligning current procedures with the new organizational structure and underlying themes. Particular emphasis should be given to assessing how new themes can be incorporated in the following management system areas: Context, Leadership, Planning, Support, Operation, and Improvement. Needs and Expectations of Interested Parties - Identify interested parties, along with their influence on the organization and its dependence on those interested parties. Interested parties have a more prominent influence on the scope and requirements of an EHS&Q Management System than in the prior versions of these standards. Risk and Opportunity Evaluation - Establish a risk and opportunity evaluation process to prioritize how EHS&Q issues will be addressed. Ideally, this should be done in conjunction with the revised EMS aspects/impacts and OHSMS hazards identification/risk evaluation procedures. Management of Change - Establish a management of change process to ensure that the organization maintains an acceptable level of risk when changes occur to equipment, processes, products, personnel, etc., and to ensure that the objectives of the change are achieved. This requirement is more prominent for the OHSMS. Supply Chain Engagement - Increase engagement with supply chain partners to enhance EHS&Q management actions. Evaluate how such engagement can help with addressing the Procurement theme within ISO 45001. Leadership Evaluation - Examine internal policies and practices to ensure that top management is obligated to demonstrate visible support for the EHS&Q management systems, and assumes responsibility, accountability, and authority for ensuring its success. This examination also should include ensuring that objectives are incorporated into organizational strategy and decision-making processes. ISO 14001 What is ISO 14001? ISO 14001 is an internationally recognized environmental management standard with its origins in sustainable development. In contrast to a regulatory-driven approach to environmental management, ISO 14001 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. The standard was reissued in 2015 and the three-year transition period has been completed. Who should consider the ISO 14001? While not for all organizations, ISO 14001 certification may be appropriate for multi-national organizations or for those being required to obtain certification by their key customers or other critical stakeholders. 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. ISO 45001 What is 45001? The ISO 45001:2018 Occupational Health and Safety Management System (OHSMS) standard was published in March 2018, replacing the OHSAS 18001:2007 OHSMS standard. Publication of this new standard is part of a broader effort by the International Organization for Standardization (ISO) to update and align all the specification standards for the management of Environmental, Energy, Health and Safety, and Quality (EEHSQ). Important Dates September 11, 2021 -- In response to the challenges posed by COVID-19, the International Accreditation Forum (IAF) has extended the migration deadline from OHSAS 18001 to ISO 45001 certification to Sept 11, 2021 (previously March 2021). The official transition period for converting to the new standard is three years; the OHSAS 18001 standard will be superseded by ISO 45001 as of Sept 11, 2021. In practice, many registrars may not want to issue certificates under the OHSAS 18001 standard beyond 2020 because in those cases the certificate would be valid for much less than a year (instead of the typical three-year time period). In general, organizations likely will find it most convenient to transition to the new ISO 45001:2018 standard at the time of their next recertification. However, much depends on the timing of recertification and the estimated level of effort necessary for realignment (as driven by the Gap Analysis task noted above). Currently certified organizations should contact their registrar as soon as possible to discuss transition timing. Who should consider the ISO 45001 standard? Companies who already have OHSAS 18001 certification will need to transition to ISO 45001. Additionally, companies that may be self-declared or those that do not have a formal OHS management program in place may consider enhancing and certifying their programs. ISO 9001 What is ISO 9001? The ISO 9001 standard provides a framework for a facility's QMS. There are several new themes presented in the ISO 9001:2015 standard that were not included in the last version of the standard (ISO 9001:2008). The new standard also brings a significant restructuring to the standard since it now follows the same overall high-level structure of other ISO management systems (called “Annex SL” format). The standard was reissued in 2015 and the three-year transition period has been completed. Who should consider the ISO 9001 standard? ISO 9001 is the most widely implemented management system intended to formalize a structured approach to managing the quality of products and services. Because the scope of any management system must be strictly defined, changes in products/services, adding facilities or excluded operations at an existing certified facility may precipitate further implementation efforts. ISO 50001 What is ISO 50001? ISO 5001 provides a framework for organizations to establish policy, targets, and objectives for more efficient use of energy. It provides a basis to use data to better understand and make decisions about energy use and to measure the results. As with any management system, it provides a mechanism for continual improvement-in this case, for energy management. Important Dates August 2021 -- The official transition period for converting to the new standard is three years; the ISO 50001:2011 standard will be superseded by ISO 50001:2018 as of August 2021. In practice, many registrars may not want to issue certificates under the original standard beyond 2020 because in those cases the certificate would be valid for much less than a year (instead of the typical three-year time period). In general, organizations likely will find it most convenient to transition to the ISO 50001:2018 standard at the time of their next recertification. However, much depends on the timing of recertification and the estimated level of effort necessary for realignment (as driven by the Gap Analysis task noted above). Currently certified organizations should contact their registrar as soon as possible to discuss transition timing. Who should consider the ISO 50001 standard? Energy consumption can be a significant cost of doing business for certain industry sectors. Thus, implementation of a formal system and processes to manage energy is a business imperative. ISO 50001 implementation also may be a way to demonstrate commitments to improved operational efficiency for the company and the products it manufactures. Trinity Can Help - Contact Us Today Trinity Consultants supports organizations in developing management systems and preparing for certification to EHS&Q-related ISO standards. Available support includes the following: Performing a gap analysis between existing EHS&Q management systems and current management systems or informal EHS&Q programs Developing and implementing missing management system elements/processes Coaching clients on how to achieve real, measurable value from a management system Training management and employees Management system auditing to document conformity with the standard(s) Assisting with self-certification For assistance, please contact Rich Pandullo or John Fillo or complete the Contact Us form. Related Articles ISO 45001:2018 Occupational Health and Safety Management System Standard: Addressing Expectations of Other Interested Parties -- Oct 04, 2019 ISO 45001: 2018 Occupational Health and Safety Management System Standard: Operational Planning and Control -- Jul 25, 2019 ISO 45001: 2018 OHS Management System Standard: The Role of Effective Governance  -- Dec 05, 2018 The New ISO 45001:2018 OH&S Management System Standard: Overview and Key Changes -- Jun 05, 2018 ISO 14001:2015 Environmental Management System Standard: Addressing Risk and Opportunity -- Oct 05, 2017 Efficiently Upgrading to the New ISO 9001:2015 Standard -- Oct 02, 2017 ISO 14001: 2015 Implementation Challenges - Addressing Life Cycle Perspective -- Feb 14, 2017 ISO 50001, Energy Management System: The Other Boiler MACT Option -- Apr 06, 2016 Improving Corporate Performance through Effective Management of EHS Business Risks - May 29, 2013 Related Training​ Implementing a Best-in Class ISO 45001:2018 OHS MS Implementing a Best-in-Class Corporate Sustainability Reporting Program Implementing a Best-in-Class ISO 14001:2015 EMS Implementing a Responsible Care RC14001:2015 and Responsible Care Management System (RCMS:2013) Technical Specification Internal EHS Management Systems Auditing Corporate Performance Improvement through Effective Management of EHS Risks Using Life Cycle Analysis to Reduce Environmental Footprint On-Demand Webinars ISO 45001: 2018 Overview & Actions to Address Risks & Opportunities  - Free Complimentary Webinar: Lessons Learned From Developing and Implementing an Effective Environmental Management System for ISO 14001:2015 Standards.  - Free ISO 45001: 2018 Overview & Key Changes  - Free Realize Your Organization's Strategic Objectives by Implementing an Effective ISO 14001:2015 EMS  - Free ISO 14001:2015: Managing Compliance with the Standard  - Free

 

Energy Management

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 Mr. Rich Pandullo at rpandullo@trinityconsultants.com or (919) 469-9693, or call (800) 229-6655.

 

Environmental and Sustainability Reporting

Regulatory reporting of an organization's environmental data involves data collection, validation and analysis, and report preparation and submittal to the U.S. Environmental Protection Agency (EPA), state or local agencies, or other authorities with jurisdiction. Required reports may cover a variety of environmental programs and media: air, waste, stormwater, wastewater, hazardous substances, and hazardous chemicals. Many of these reports must be submitted annually, and some environmental data are required for multiple reports. During the first half of every year, many environmental professionals are engaged in the task of environmental reporting which can consume much of their immediate attention and energy, leaving little time for typical day-to-day responsibilities. By partnering with Trinity to perform streamlined, integrated environmental reporting, the pressure on environmental professionals can be greatly reduced. Centralized data for environmental reporting also increases accuracy, efficiency, and consistency among various environmental reports. Environmental Reporting Requirements Air Quality Air emissions reporting is typically the most onerous of aspects of environmental reporting due to the technical complexity and the variety of programs and requirements. Air emissions inventories - In order to complete an annual emissions inventory (EI), a facility must collect data such as material throughput, equipment operating hours, monitoring data, sampling data, scheduled maintenance activities, emission event reports, etc. Emissions are then calculated using the data collected and emission calculation methodologies, based on the facility's New Source Review (NSR) permit or other EPA/State EI guidelines. Greenhouse gas reports - EPA's GHG Mandatory Reporting Rule requires that greenhouse gases (GHG) from certain industries/sources be reported on an annual basis to EPA. GHG reports include unique information that may align with the air emissions inventory and additional information such as industry-specific GHG emission factors and reporting requirements. MACT/NSPS/Title V Compliance Reports - Typically, the same data used to develop annual EI is needed for these MACT, NSPS, and Title V compliance reports to determine any exceedance of permitted emission rates. Additional information related to compliance with the specific permit conditions and applicable state and federal requirements must also be collected and reported. Waste Management With respect to waste reporting, Large Quantity Generators (LQG) and Treatment, Storage, and Disposal Facilities (TSDF) must submit a Hazardous Waste Biennial Report by March 1st of each even-numbered year for hazardous waste activities during the previous odd-numbered calendar year. Many states and territories require reporting on an annual basis and may require reporting by facilities other than LQG and TSDF (e.g., Small Quantity Generator (SQG), Very Small Quantity Generator (VSQG), any facility that ships hazardous waste, shipping state hazardous waste, etc.). The report summarizes the amount of hazardous waste and state specific waste generated or managed at the site during the calendar year. Water Quality EPA and state agencies with stormwater permitting jurisdiction develop general permits for stormwater and wastewater discharges. The federal program is the National Pollution Discharge Elimination System (NPDES); some states developed different types of general stormwater/wastewater discharge permits applicable to specific types of facilities. A facility holding a Stormwater Multi-Sector General Permit (MSGP) must submit a discharge monitoring report (DMR) in the case of any non-compliance with an effluent limit for any of the hazardous metals as well as all results of sampling for effluent limits or benchmark monitoring in accordance with Sector-specific requirements regardless of if there was an exceedance or not. Wastewater sampling and analysis is an integral part of Clean Water Act (CWA) compliance. The CWA and EPA's NPDES regulations require permitted facilities to monitor the quality of their stormwater/wastewater discharge and report the monitoring data to their permitting authority on a DMR or a Benchmark Monitoring form. Hazardous Chemicals Reporting Under the Emergency Planning and Community Right-to-Know Act (EPCRA) Section 312, facilities must submit an emergency and hazardous chemical inventory form to the Local Emergency Planning Committee (LEPC), the State Emergency Response Commission (SERC) and the local fire department annually. Most states allow or require that the Tier II form be submitted in an electronic format. EPA makes available free Tier2Submit software. Electronic reporting via this software may be recommended or required by many states. Other states may use state-specific software or an on-line reporting tool. EPCRA Section 313 requires facilities in covered NAICS codes to file a Toxics Release Inventory (TRI) report annually for each Section 313 chemical exceeding an activity threshold. The Section 313 chemicals list contains over 600 chemicals and chemical categories. Pollution prevention (P2) is any practice that reduces, eliminates, or prevents pollution at its source. The facilities that must prepare a P2 Plan include facilities that report to EPA using the Toxics Release Inventory Form R or LQGs or SQGs of hazardous waste that report to the state agency on the Annual Waste Summary Sustainability Reporting - Carbon Disclosure The CDP is an investor-sponsored, non-profit organization based in the United Kingdom which represents the collective interest of more than 800 institutional investors with over $100 trillion in assets. Given the strong investment community influence, CDP's objectives have always centered on gathering, analyzing and reporting environmental data (initially carbon/energy, then water and forest ecosystems) as a means for investors to improve the management of long-term risk in their portfolios. Through a focus on measure, report, manage, CDP firmly believes that companies will pay appropriately close attention to long-term sustainability issues and develop effective strategies for mitigation, while in the process, improving business performance. Optimized Reporting Since annual environmental and sustainability reporting involves large amounts of data collection and analysis, understanding how these annual reports are related and implementing an efficient data management system is important to effectively and accurately meet all reporting requirements. Much of the data gathered in the first quarter of the year can be used for various reporting programs, and efficient data collection and utilization can significantly increase the accuracy and efficiency for the annual reports. Trinity Consultants is unmatched in our understanding of regulatory and sustainability reporting requirements and implementation of best practices to streamline reporting and ensure accuracy. Our processes, deployed for the benefit of hundreds of organizations annually, help lower the cost of compliance, free up valuable staff time, and drive down the likelihood of missed deadlines or non-compliance issues. Our expertise on the regulations and experience in effective management of the related data provide the building blocks for an optimized reporting process that is custom designed to individual client needs. For more information, please contact Trinity at  (800) 229-6655 or Contact Us online. Related Resources Articles Vision 2020 - Centralized Data for Environmental Reporting Voluntary GHG Reporting Via CDP Training Classroom Training Introduction to Environmental Reporting and Recordkeeping Requirements Environmental Reporting Requirements in Arizona Introduction to Arkansas Environmental Reporting Requirements Environmental Reporting Requirements in Florida Environmental Reporting Requirements in Illinois Environmental Reporting Requirements in Iowa Environmental Reporting Requirements in Kansas Louisville Metro Air Reporting Workshop Environmental Reporting Requirements in Maryland Environmental Reporting Requirements in Minnesota Environmental Reporting Requirements in Missouri Environmental Reporting Requirements in Nebraska Environmental Reporting Workshop in New Jersey Environmental Reporting Requirements in New York Environmental Reporting Requirements in Ohio Texas Boot Camp - Environmental Reporting Texas Reporting Refresher Workshop Environmental Reporting in West Virginia Environmental Reporting Requirements in Wisconsin On Demand Webinar - Digital Transformation - Finding Ways to Balance the Resources Crunch During Peak Reporting Season

 

Litigation Support

Trinity Consulting Services: Litigation Support 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.  Do you need litigation support? Trinity can help! Trinity Consultants has a team of litigation support experts who can assist you.    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.

 

Environmental Impact Assessment

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 dstrohm@trinityconsultants.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 documents for 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 at (949) 567-9880 or vmasuraha@trinityconsultants.com, or Ms. Valerie Rosenkrantz at (352) 562-1520 or vrosenkrantz@trinityconsultants.com.    

 

Noise and Vibration Services

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 Noise and vibration propagation modelling Siting studies for new plants and expansions NEPA Environmental Assessments (EA) noise reports FERC Resource Report 9 noise section preparation Noise impact mitigation assistance Building and architectural acoustics Occupational noise monitoring, mapping, and mitigation design What is Noise and Vibration? Noise and vibration are inherent to industrial, commercial, entertainment, and transport activities. Sources of noise can include: Fans and exhausts and other industrial control systems Vehicle operations including loading and unloading Baghouses and pollution control equipment Rotating crushers and other machinery Material handling processes Generators, motors, engines and turbines; Steam and gas venting and pressure drops in piping systems Transport including road, rail, air and shipping Entertainment noise including music and crowd noise Commercial operations including mechanical plant, car parking, and loading docks Who needs Noise and Vibration Services? 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 noise measurements and noise impact analyses at 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 Can Help - Contact Us Today Trinity personnel have performed noise and vibration monitoring and impact assessment projects in numerous US states, Canadian provinces and Australian states. Projects have ranged from the predictive modeling of impacts at noise sensitive areas to assistance with selection of mitigation methods. Assessment includes measurement of acoustic emission data for noise sources and characterization of ambient noise and vibration levels. 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 Mining and extractive industries Sporting and music venues Educational and health facilities Transportation projects including road, rail, air and shipping 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. Trinity Consultants assists clients with noise and vibration in a variety of ways: 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 visualization 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, or to identify issues to be treated. 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. Architectural Acoustics Trinity can determine design criteria for and develop detailed design of noise sensitive spaces to achieve acceptable internal acoustics such as room finishes, building envelope and façade treatment, internal partitioning, and control of mechanical plant noise. For assistance with Noise and Vibration Services, contact: Canada: Chris Scullion at (416) 391-2527 USA: Angie Wanger at (651) 275-9900 or David Strohm at (208) 472-8837 Australia: Gillian Adams at or +61 7 3255 3355 Or Contact Us online Related Articles Trinity Consultants Acquires ASK Consulting Engineers of Brisbane, Australia -- Feb 08, 2019 When Odor and Noise are a Nuisance -- Aug 28, 2018 Requirements for Development of Best Management Practices Plan (BMPP) for Industrial Sources of Odour -- Nov 24, 2017 Noise and Odor Issues -- Aug 28, 2017 Industrial Noise and Community Impacts -- Mar 29, 2017 Related Training Managing Environmental Nuisances: Odor and Noise

 

Odor Analysis

Odor Management Services While odor issues are often addressed on a case-by-case basis when nuisances are reported, 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 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 criterion 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, and its hedonic tone or relative unpleasantness Location - mapping impact location and identifying potential off-property contributing sources How Trinity Can Help Trinity has extensive experience in conducting ambient field studies using olfactometers operated by 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 and CALPUFF 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. Trinity Consultants assists clients with odor analysis in a variety of ways: Odor Source Testing & Ambient Air Monitoring Source testing is used to collect samples of odor directly at the source and these are submitted for analysis to accredited odor panels or analytical laboratories to obtain reliable, quantifiable results. We offer services for mapping site‐wide and community‐wide ambient odors using field olfactometry and GIS techniques. Trinity conducts baseline odor surveys and investigative analyses through ambient odor monitoring using portable field olfactometers and trained assessors. Establishing background odor through ambient monitoring is also an important technique in understanding the impacts of odor from off‐property sources. Odor Modeling and Assessment Quantifying odor levels at sensitive points of reception using atmospheric dispersion modeling is paramount for assessing odor impact and compliance. We have a strong understanding of regulatory standards and guidelines spanning U.S., Canadian, and Australian jurisdictions and have utilized air dispersion models such as AERMOD and CALPUFF to conduct odor dispersion modeling analyses. Odor Emissions Analysis and Controls Review Trinity is experienced in reviewing odor emissions information, completing building envelope studies to confirm capture/routing of odor emissions, and analyzing effectiveness of odor control technologies. Peer Reviews and Expert Testimony Trinity offers odor peer review services for consultants and industry. Our qualifications and past experience allow us to provide reliable expert testimony and opinion. Odor Training Trinity offers professional training through its Managing Environmental Nuisances: Odor & Noise course taught by senior‐level consultants who are odor experts that have contributed on numerous odor compliance and mitigation projects. Custom training courses on odor topics are also available. For assistance with odor management, please contact: USA: Angie Wanger at (651) 275-9900 Canada: Chris Scullion at (416) 391-2527 Australia: Andrew Martin at +61 7 3255 3355 Project Experience Trinity's strategic office locations are staffed by resident consultants with an intimate understanding of the state and local air permitting processes as well as strong working relationships with local regulatory agencies. Trinity assists multiple facilities with ongoing odor compliance requirements related to their existing permits and local odor ordinances.  Trinity has assisted with odor projects in a wide range of industries, including:  Aggregates Production Agriculture Processing Animal Production and Processing Asphalt Roofing Manufacturing Automotive Manufacturing  Chemical Manufacturing Food Processing Landfills & Waste Management Operators Wastewater Collection and Treatment Mining Oil & Natural Gas Extraction and Production Organics Recycling    Petroleum Refining and Distribution Pharmaceutical Manufacturing Pipelines and Compressor Stations Pulp and Paper Manufacturing  Semiconductor Manufacturing Surface Coating and Commercial Printing Textile Manufacturing  In addition, we frequently collaborate with attorneys, environmental consulting and olfactory service firms, and government and regulatory agencies.  Latest News Odor Impact Service Offerings Available in Texas -- Aug 16, 2019 BAAQMD Public Workshop Series for Proposed Climate Pollutant Regulations -- May 23, 2019 NJDEP Evaluating New Rulemaking for Hazardous Air Pollutants -- Feb 25, 2019 Trinity Consultants Acquires ASK Consulting Engineers of Brisbane, Australia -- Feb 08, 2019 Kansas Tip of the Month - Annual Storm Water Inspections -- Dec 03, 2018 Odour Study Descriptions -- Sep 14, 2018 When Odor and Noise are a Nuisance -- Aug 28, 2018 South Coast Air Quality Management District - Proposed Amended Rule 408 -- Apr 30, 2018 Kansas Multi-Media Tip of the Month -- Mar 23, 2018 Updates to Maricopa County Adopted Rule 316 and Rule 320 -- Jan 31, 2018 Requirements for Development of Best Management Practices Plan (BMPP) for Industrial Sources of Odour -- Nov 24, 2017 Noise and Odor Issues -- Aug 28, 2017 Nuisance Pollutants and the Megaphone of Social Media: New Challenges for Industry -- May 08, 2017 Industrial Noise and Community Impacts -- Mar 29, 2017 Addressing Odor Complaints -- Apr 13, 2016 Part 1, Part 2, and Part 9 Final Air Pollution Control Rule Revisions Issued -- Jan 25, 2017 Media CALPUFF in Odor Modeling-State of the Practice, Recent Developments, and Future Improvements -- Apr 13, 2016

 

Pandemic Response Plan

Trinity Pandemic Response Plan In early 2020, the world was introduced to a new pandemic, COVID-19, that impacted everyone's life and business operations. It also created a great challenge to EHS professionals who are responsible to establish, manage, and monitor company policies and programs to ensure the health and safety of their workforce. With our expanded health and safety capabilities, Trinity assists clients in essential industry sectors with business continuity planning, workplace evaluations, and practices to address employee wellbeing. Our pandemic response team closely monitors new rules, policies, and recommended practices established by the Centers for Disease Control, federal and state OSHA programs, and recognized associations including the American Biosafety Association (ABSA), American Industrial Hygiene Association (AIHA), American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE), American Association of Safety Professionals (ASSP), and World Health Organization (WHO), as well as state and local public health authorities. We assist clients in the following areas to ensure safe and effective operations during a pandemic: Identification of site specific hazards and risk assessment for pandemic control measures following the latest guidance from federal and state authorities (EPA, CDC, OSHA, etc.) Development of pandemic response plans that can be effectively implemented via employee communications/training for critical steps including: Onsite screening and monitoring activities involving contractors, visitors, and customersPersonal protective measures as appropriate for specific jobs Recommendations for business continuity during pandemic including back-to-work considerations What is a Pandemic Response Plan? When a pandemic occurs, affected individuals who come in contact with an organization can disrupt business continuity and put others at risk. Employers should prioritize the health and safety of their employees, customers, supply chains, and the communities they serve. In order to promote health and safety while maintaining operations and complying with OSHA requirements, employers should consider developing a Pandemic Response and/or Preparedness Plan to establish the requirements that address health concerns caused by pandemic diseases such as COVID-19. The plans should be based on the latest guidelines and recommendations published by the U.S. Centers for Disease Control and Prevention (CDC), Occupational Safety and Health Administration (OSHA), local/state public health authorities, and professional organizations with subject matter expertise. Who should be involved in developing a Pandemic Response Plan? Typically, EHS Managers/Directors, in partnership with company senior leadership, take the lead on developing the organization's Pandemic Response Plan. Trinity Can Help! Trinity's Health & Safety team creates Pandemic Response Plans, including back-to-work considerations that assist clients to prepare needed action items for COVID-19 and future potential pandemics. Please call us at 800.229.6655 or contact us online.

 

Tank Services

Trinity provides broad support to tank owners regarding environmental compliance as well as design and inspection support. We routinely assist tank owners with identifying applicable regulations, obtaining proper permits, addressing ongoing compliance obligations, and quantifying emissions associated with storage tanks. We have expertise in regulatory development, tank emission factors, tank emission calculation software, and floating roof design and inspection. Trinity's unmatched credentials regarding tank emissions and design can help you streamline compliance with complete peace of mind. Regulatory Updates AP-42 Emission Factor Revisions The selection of reliable tank emission calculation tools is made even more important by recent revisions to Chapter 7.1 of EPA's AP-42 document (guidance for estimating emissions from storage tanks). For information on AP-42 changes that would impact tank emissions estimation, call Trinity at +1 (866) 830-0796 or complete the Contact Us form. Tank Services from Trinity Consultants Environmental, Health, and Safety Compliance  Trinity works routinely with tank owners to determine applicable environmental regulations and document compliance, including the following: Environmental permitting support Clean Air Act (CAA) new construction and operating permits Minor New Source Review (NSR)Prevention of Significant Deterioration (PSD)Nonattainment NSRMajor Source Maximum Achievable Control Technology (MACT)Title VClean Water Act (CWA) Spill Prevention, Control, and Countermeasure [SPCC] permit Tank emissions calculations based on the latest emission factors NESHAP and NSPS compliance NESHAP Subparts G, R, CC, WW, EEEE, and BBBBBBNSPS Subpart K, Ka, Kb, OOOO, and OOOOa Dispersion modeling to estimate the impact of tank emissions for air quality permitting, compliance, capital planning, design, and safety Emissions reporting Annual Emission Inventory (EI)Toxic Release Inventories (TRI)Tier II Reporting (EPCRA, CERLCA Risk Management Planning (RMP) / Process Safety Management (PSM) Compliance auditing Floating Roof Design and Inspection Our expertise in floating roof design allows Trinity to assist you in selecting and specifying the appropriate type of floating roof based on structural and emissions concerns. Furthermore, we can assist with developing your inspection program including review of inspection forms and templates and training of in-house personnel on how to properly perform inspections. Alternatively, we can perform the inspections for you. Software Expertise for Tank Services Tank Emissions Calculation Tool TankESP Software Product Suite - BREEZE TankESPTM is a tank emissions calculation software product suite that uses the emission estimation procedures from Chapter 7.1 of U.S. EPA's Compilation of Air Pollutant Emission Factors (AP-42) for volatile organic compound (VOC) emissions from storage tanks. BREEZE TankESP is widely regarded as the most accurate tank emission calculation tool on the market because it was designed by Rob Ferry, a key contributor to AP-42 Chapter 7.1. BREEZE TankESP also resolves many of the technical issues with TANKS 4.09d as is discussed in this detailed description and provides additional functionality for non-routine emissions events. The software product suite is available for purchase in three separate editions that vary in capability and price so that you can choose the one that will best satisfy your needs. Tank Emissions Calculation Tool Implementation and Maintenance If you are responsible for multiple tanks with a variety of tank stocks and operating styles, Trinity can help. Our expert consultants have the in-depth understanding of tank emission calculation methodologies, tank emission calculation tools, and federal and local tank related regulations to effectively assist you with the initial implementation of BREEZE TankESP. We help maintain monthly tank emission calculations and tracking with TankESP and can develop customized reports to meet your specific reporting requirements. Trinity Can Help - Contact Us Today! For broad environmental assistance for your storage tanks, Trinity offers unmatched expertise and service quality. Call Trinity at (800) 229-6655 or Contact Us online. Related Articles BREEZE TankESP 5.1 Software Includes Recently Updated AP-42 Tank Emission Factors -- Jan 28, 2020 Calculating Tank Emissions with TankESP -- Jan 07, 2020 Finalized Changes to AP-42 Chapter 7.1 - Organic Liquid Storage Tanks -- Dec 09, 2019 AP-42 Chapter 7 Storage Tank Updates Are Finally Here -- Nov 21, 2019 PADEP Guidance on Storage Tank Modification and Maintenance, Operator Training Requirements -- Aug 30, 2019 PADEP Guidance on AST Emergency Containment Structure Verification -- Aug 30, 2019 Upstream Storage Tank Non-compliance and EPA's Newly Finalized Audit Policy -- Apr 29, 2019 Proposed Changes to AP-42 Chapter 7.1 - Organic Liquid Storage Tanks -- Dec 07, 2018 Estimating Tank Emissions - Changes May Be Coming - March 02, 2018 Tank Experts Rob Ferry and Randy Kissell Join Trinity - December 04, 2017 Related Training Fundamentals of Tank Emission Calculations Tank Emission Calculation Workshop with TankESP Software Tank Regulations Primer Clean Air Act Workshop for the Liquid Terminal Industry Free Webinar - AP-42 Chapter 7.1 Storage Tank Updates and TankESP Software Release Free Webinar - TankESP Software Product Suite Version 5.0 Overview Tutorial