EHS Performance and Risk Management Support

Auditing and Verification

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. Third Party Waste Handler/Receptor Audits: Ensuring Compliance of Your 3rd Party Waste Receptors Legal:  All companies are responsible for the proper disposal of their waste. Once a third party is handed the waste stream there is now a shared responsibility to properly dispose of the waste material. The waste generating company is not off the hook once the waste is accepted by a third party. This waste handling process is defined as “Cradle to Grave” Liability, Joint and Several. The types of waste can range from non-hazardous waste to hazardous waste. There are many different types of treatment/disposal sites: Landfill: Hazardous / Non-Hazardous, Surface impounds, Injection well, Incinerators, Beneficial use, Waste water treatment, Land Treatment facilities, Salt Dome or salt bed formations, Underground mines or caves, Concrete vaults, Disposal bunkers, Container re-conditioners / washes and Universal waste processing. Trinity staff has conducted more than 1,500 of these audits for our waste generating industrial clients. Below is an outline of the audit process: The Waste Review Audit Process General Information  - Collect the following Company name & address, company profile information (Corp.), Site profile, Facility staffing, Site history, Facility setting and surrounding use, Site security & Emergency response Operations Review - Collect the following Summary & Critique, Hazardous Waste TSD, Container Management, Recycling and Non-Hazardous Waste TSD, Bulk Storage, Transportation & Laboratory Operations and Documentation Residuals Management - Collect the following: Residuals Generated  & Offsite Receivers, Storm Water Management Summary of Permits - Collect the following: Permit/Registration Summary, Authorized Waste, Prohibited Waste Regulatory Compliance Status -  Collect the following: SPCC/RCRA Contingency Plans, Agency Reporting, OSHA Compliance, Agency Contact, Regulatory Inspection History, Regulatory Violations, Corrective Actions, Facility Investigations, Litigation, Reportable Quantity (RQ) Releases & Review of Federal Databases  Company Financial Review - Collect the following: Income Statements, Balance Sheets, Financial Statements, Financial Ratios, Site Closure & Insurance Summary Inspection and Interview Checklists Complete the inspection/review of the physical siteComplete the checklists Attachments - Collect the following: Notice of Indemnification by Redstone, Site Location Map, Site Layout, Insurance Certificate, Listing of permits, Financial Statements, Photographs & Other misc. items. Once a complete report is written, conclusions are provided that explain:  Risks of using the facility and;  Corrective actions required 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 Trinity at (800) 229-6655. Related articles for more information: 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    


California GHG and Offset Project Verification Services

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  


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 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, or Mr. Rich Pandullo, Director, at (919) 462-9693 or  


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


EHS Management Systems

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 Trinity at (800) 229-6655. Related articles for more information: 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 ISO 14001: 2015 Implementation Challenges - Addressing Life Cycle Perspective -- Feb 14, 2017      


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 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

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.


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 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, or Ms. Valerie Rosenkrantz at (352) 562-1520 or    


Noise and Vibration Services

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


Odor Analysis

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 com, or Chris Scullion at (416) 391-2527 or  


Tank Services

Trinity provides broad support for tank owners to assist with environmental compliance as well as broader 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. With the addition of TGB Partnership in 2017, we have added 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.   TGB Partnership Joins Trinity In 2017, Trinity Consultants acquired TGB Partnership, a consulting and software firm that specializes in the control of air emissions, the development of standards and regulations, data analysis, and the design of aluminum structures. TGB was founded in 1993 by Robert L. (Rob) Ferry and J. Randolph (Randy) Kissell, structural engineers and renowned experts on atmospheric storage tanks and aluminum structures. Rob is a trusted consultant to several trade associations and private sector clients and has led the petroleum industry's development of recommendations to EPA regarding standards and emissions calculations for storage tanks. Randy is a long-standing consultant to the Aluminum Association, as well as numerous private sector clients, serving as technical expert and primary author for the Aluminum Association's Aluminum Design Manual. TGB's powerful TankESP Software is now available through Trinity, with single site or corporate-wide licenses available.   Environmental, Health, and Safety Compliance   Trinity works routinely with tank owners to determine applicable environmental regulations and demonstrate 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] permits 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 Tank Emissions Software Tools Phasing Out of EPA's TANKS 4.09D  Since its release in October 2006, EPA's TANKS 4.09D software tool has been widely used by regulatory agencies, the regulated community, and consultants to estimate VOC and HAP emissions from fixed- and floating-roof storage tanks. Because this model was developed using software that is now outdated, EPA no longer supports the program and has issued certain disclaimers regarding the use of this program: “…we can no longer provide assistance to users of TANKS 4.09D. The model will remain on the website to be used at your discretion and at your own risk…” - EPA EPA has clarified that use of the TANKS program provides no enforcement protection for inaccuracies in tank emissions estimation data. Furthermore, there are a number of issues regarding the use of the TANKS program, and several limitations. Namely, TANKS 4.09D SHOULD NOT be used for the following: Heated tanks without insulation Tanks storing warm product Tanks with significant variations in throughput month by month Monthly/Ozone season emissions for all tanks In addition, TANKS does not calculate the following: Tank landing emissions (included in AP-42 Section 7.1) Tank cleaning emissions Short-term emissions Flashing emissions View a detailed description of many of the issues associated with TANKS 4.09D.   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, contact Trinity at (800) 229-6655.   Tank Emission Calculation Tools  Depending on your organization's needs, Trinity has several options for automating tank emission calculations. These include:   TankESP Software Product Suite - robust software product suite that addresses a variety of stored products and related emissions (site and corporate licensing available). To receive a quote or for more information, please contact the BREEZE Team.   Trinity's tank tool - a cost-effective tool with some limitations on number of tanks (slower performance for > 100 tanks) Data Integration/Automation (DIA) with Tank Module - links with plant process historian to generate accurate “net throughput” and service information and automate tank emission calculations  Custom solutions to meet your organization's needs Tank Calculations Training Trinity routinely provides training for environmental professionals on tank emissions calculations. Our courses include the Fundamentals of Tank Emissions Calculations and Tank Emission Calculation Workshop with TankESP Software , which are taught consecutively several times a year. Attendees to both courses save 25% on the course fees. We also provide custom training to meet the needs of individual organizations.   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.  For broad environmental assistance for your storage tanks, Trinity offers unmatched expertise and service quality. Contact us online or at (800) 229-6655.